Technical Committee on Multiple Burner Boilers

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Technical Committee on Multiple Burner Boilers AGENDA Salt River Project PERA Club 1 Continential Drive Tempe, AZ January 14-15, 2014 1. Chair s welcome, call to order, and opening remarks at 8:00 a.m. CST. 2. Self-Introduction of Committee Members and Guests 3. Approval of Minutes from the February 2013 First Draft meeting in New Orleans, LA. See www.nfpa.org/85next. 4. Staff Liaison Report A. Committee membership update (For the period Feb. 5, 2013 Dec 10, 2013) Name Category Change Date Thomas J. Murphy M (Alt to B. Basile) Appoint 07/29/2013 Sanda Brumaru SE (Alt to G. Keller) Resign 04/05/2013 George Keller SE (Principal) Resign 04/05/2013 Farshad Hendi SE (Alt to G. Raney) Resign 04/10/2013 Glenn Raney SE (Principal) Resign 04/10/2013 Gary Norman M (Alt to J. O Rourke) Resign 05/20/2013 (Total Voting Members 27; M=33%, SE=30%, U=30%; I=7%) B. Revision Cycle Review and timeline (Attachment A) 5. Old Business (See Also Pre-FD Actions in Attachment C.) A. Referenced Documents in Fundamentals Chapters. Mr. Switzer will review the documents referenced in mandatory text in subsection 6.6.2 B. Design Pressures Task Group. The scope of the task group is to review section 6.5 and its subparagraphs to determine how the head developed by booster fans in series with ID fans should be addressed. The task group looked at how the various combinations of fans affect boiler/furnace design and considered how NFPA 85 should respond to that. Task group chairman B. Smith submitted several public inputs for consideration by the committee.

The task group also came up with other questions, including the following: i. Current applications have fan capabilities up to 80 in., but the duct work is addressed only in the annex as a consideration. Is it time to establish structural requirements for the duct work? ii. Does the committee need to review 35 in. limitation to reflect current designs/practices? iii. The fan requirement is based on cold, dense air. Is that a realistic requirement, or should the code reflect typical ambient conditions. The task group will continue to discuss these new questions for further consideration in the Second Draft meeting. The task group members are B. Smith (chair); D. Evely; J. Frazier; K. Gamble; D. King; J. Lehman; H. Wong; and A. Zadiraka. C. Annexes B and C (Supervised Manual Systems). A task group was established to discuss this issue further. The task group members are: D. Dressel (chair); J. Eibl ; S. Yates; and A. Zadiraka. In the First Draft meeting, the committee discussed the use and continued need for these annexes, which are not actively maintained by the committee. The annexes address interlocks that are designed to operate with operator supervision. The material is still in use by some chemical and petrochemical companies, and is not covered by any other NFPA document. 6. New Business A. Review Public Comments on Chapter 6 and Related Annex Material. Review the Public Comments (Attachment B) and revise chapter 6 of NFPA 85 as appropriate. B. Review BCS-FUN Second Revisions. The committee members are asked to review the actions of the Fundamentals committee (Attachment C) and bring forward any items warranting further discussion. C. Boiler Enclosure Definition/Purge Times. It has been reported that some boilers are being purged for much longer than 5 minutes because of the volume calculation and the requirement for 5 air changes. This issue was referred to the BCS-MBB committee for further discussion by the Correlating Committee. (NFPA85/AAC Minutes Item 7B) 7. Plasma Arc Igniter. The committee briefly discussed the use of plasma arc igniters, indicating awareness of some installations or planned installations outside of the US. A representative from SmartBurn LLC will make a presentation on this new technology. 8. Other Items? 9. Date/Location of Next Meeting. This concludes the committee work for the Fall 2014 revision cycle. The next meeting will be scheduled as needed. 10. Adjournment.

Attachment A: Fall 2014 Revision Cycle

2014 FALL REVISION CYCLE *Public Input Dates may vary according to documents and schedules for Revision Cycles may change. Please check the NFPA Website for the most up to date information on Public Input Closing Dates and schedules at www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab Process Stage Public Input Stage (First Draft) Process Step Dates for TC Dates for TC with CC Public Input Closing Date* 1/4/2013 1/4/2013 Final date for TC First Draft Meeting 6/14/2013 3/15/2013 Posting of First Draft and TC Ballot 8/2/2013 4/26/2013 Final date for Receipt of TC First Draft ballot 8/23/2013 5/17/2013 Final date for Receipt of TC First Draft ballot recirc 8/30/2013 5/24/2013 Posting of First Draft for CC Meeting 5/31/2013 Final date for CC First Draft Meeting 7/12/2013 Posting of First Draft and CC Ballot 8/2/2013 Final date for Receipt of CC First Draft ballot 8/23/2013 Final date for Receipt of CC First Draft ballot recirc 8/30/2013 Post Final First Draft for Public Comment 9/6/2013 9/6/2013 Public Comment closing date 11/15/2013 11/15/2013 Final Date to Publish Notice of Consent Documents (Documents That Received No Comments) 11/22/2013 11/22/2013 Appeal Closing Date for Consent Documents (15 Days) (Documents That Received No Comments) 12/7/2013 12/7/2013 Final date for TC Second Draft Meeting 5/2/2014 1/24/2014 Posting of Second Draft and TC Ballot 6/13/2014 3/7/2014 Comment Stage Final date for Receipt of TC Second Draft Ballot 7/7/2014 3/28/2014 (Second Draft) Final date for receipt of TC Second Draft ballot recirc 7/14/2014 4/4/2014 Posting of Second Draft for CC Mtg 4/11/2014 Final date for CC Second Draft Meeting 5/23/2014 Posting of Second Draft for CC Ballot 6/13/2014 Final date for Receipt of CC Second Draft ballot 7/7/2014 Final date for Receipt of CC Second Draft ballot recirc 7/14/2014 Post Final Second Draft for NITMAM Review 7/18/2014 7/18/2014 Tech Session Preparation (& Issuance) Notice of Intent to Make a Motion (NITMAM) Closing Date 8/22/2014 8/22/2014 Posting of Certified Amending Motions and Consent Documents 10/17/2014 10/17/2014 Appeal Closing Date for Consent Documents (15 Days) 11/1/2014 11/1/2014 SC Issuance Date for Consent Documents (25 Days) 11/11/2014 11/11/2014 Tech Session Association Meeting for Documents with CAMs 6/22 25/2015 6/22 25/2015 Appeals and Issuance Appeal Closing Date for Documents with CAMs (20 Days) 7/15/2015 7/15/2015 SC Issuance Dates for Documents with CAMs 8/27/2015 8/27/2015

Attachment B: Public Comments

6 of 109 11/18/2013 11:57 AM Public Comment No. 28-NFPA 85-2013 [ Section No. 6.4.1.1.14 ] 6.4.1.1.14 The mandatory master fuel trip sensing elements and circuits shall be independent of all other control elements and circuits. Exception No. 1: Individual burner flame detectors also shall be permitted to be used for initiating master fuel trip systems. Exception No. 2: Airflow measurement, auctioneered furnace draft, drum water level, and feedwater flow signals or equivalent signals specified by boiler manufacturer, from the boiler control system shall be permitted to be used for a master fuel trip, provided all the following conditions are met: (1) These interlocks are hardwired into the burner management system. (2) Tripping set points are protected from unauthorized changes. (3) Any single component failure of these sensing elements and circuits does not prevent a mandatory master fuel trip. Statement of Problem and Substantiation for Public Comment To accommodate for various types of once-through boiler designs and different operating conditions, recommend leaving the method of meeting the intent of Feedwater Flow Low trip to boiler manufacturer. Some existing methods of detecting Feedwater Flow issues are: 1) Loss of all Boiler Feedwater Pumps (BFP); 2) Waterwall Outlet Pressure High (possible blockage downstream); 3) Waterwall Outlet Pressure Low (possible tube leak downstream); 4) Waterwall Outlet Temperature High (Feedwater Flow Low relative to Fuel Flow). 5) Pressure differential low between Waterwall Outlet Pressure and Throttle Pressure headers. Alternative parameters such as P, T, dp, and equipment status can be used to detect Feedwater Flow Low as specified by boiler manufacturer. Submitter Full Name: SINMING KWONG Organization: EMERSON PROCESS MANAGEMENT PWS Submittal Date: Mon Nov 04 21:52:23 EST 2013 Copyright Assignment I, SINMING KWONG, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am SINMING KWONG, 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

9 of 109 11/18/2013 11:57 AM Public Comment No. 50 Figure 6.4.1.2.1 and Table 6.4.1.2.1(a) through Table 6.4.1.2.1(c) show the minimum required system of interlocks that shall be provided for basic furnace protection for a multiple burner boiler operated in accordance with this code. Figure 6.4.1.2.1 Interlock System for Multiple Burner Boiler. Table 6.4.1.2.1(a) Interlock System for Multiple Burner Boiler Block Number Block 1 Block 2a1 Block 2a2 Block 2b Blocks 3 through 13 Action Loss of an individual igniter flame shall cause the following actions: (1) Close the individual igniter safety shutoff valve(s) and de-energize the spark(s). (2) Open the vent valve (fuel gas ignition only). (3) Signal the main flame protection system that the igniter flame has been lost. High or low igniter fuel gas header pressure shall be interlocked to initiate the tripping of the igniter header and individual igniter safety shutoff valves and de-energize sparks. Low igniter fuel oil header pressure shall be interlocked to initiate the tripping of the igniter header and individual igniter safety shutoff valves and de-energize sparks. Where fuel oil is used for ignition fuel with air or steam atomization, atomizing air or steam pressure out of range shall trip the igniter header and individual igniter safety shutoff valves and de-energize sparks. Where direct electric igniters are used, blocks 1 and 2 shall not apply. However, the master fuel trip system shall de-energize sparks and prevent re-energizing until all conditions for light-off have been re-established. These blocks represent conditions that initiate the tripping of all main and ignition fuel supplies through a master fuel trip relay contact(s). The master fuel trip relay(s) shall be of the type that stays tripped until the unit purge system interlock permits it to be reset. Whenever the master fuel trip relay(s) is operated, it shall trip all fuel header, burner, and igniter safety shutoff valves and de-energize all sparks and all ignition devices within the unit and flue gas path through master fuel trip relay contact(s). Master fuel trip relay contacts shall also trip the fuel oil system circulating and recirculating valves. If the design of the fuel oil supply system is such that backflow of fuel oil through the recirculating valve is inherently impossible or positively prevented, this valve shall be permitted to be manually operated and shall not be required to be interlocked to close automatically on a master fuel trip.

0 of 109 11/18/2013 11:57 AM Block Action Number Table 6.4.1.2.1(b) Fuel Inputs Shutoff When Class 1 Igniters Are Used Condition (1) First Class 1 igniter(s) fails to light after successful unit purge. [See 6.6.5.2.1.3(B)(9), 6.6.5.2.1.3(B)(10), and 6.8.5.2.1.3(B)(7).] (2) Any igniters proven on, all other fuel sources off, all igniter valves subsequently closed. (3) Any Class 1 igniter(s) proven on, any burner valve leaves closed limit, all burner valves subsequently closed, no other main fuel in service, igniter(s) remain proven. (4) Any Class 1 igniter(s) proven on, any pulverizer startup initiated, all pulverizers subsequently stopped, no other main fuel in service, igniter(s) remain proven. (5) All igniter and burner valves closed and all feeders or pulverizers stopped. Action Required (1) Igniter valve(s) shall be closed immediately. Master fuel trip not required, but a 1-minute delay shall be required before retrial of that or any other igniter. (2) Master fuel trip shall be actuated. (3) Associated main fuel gas trip valve and/or fuel oil trip valve shall be closed (fuel gas trip and/or fuel oil trip), proven igniters shall be permitted to remain in service. (4) Proven igniters shall be permitted to remain in service. (5) Master fuel trip shall be actuated. Table 6.4.1.2.1(c) Fuel Inputs Shutoff When Class 2 or Class 3 Igniters Are Used Condition (1) First Class 2 or 3 igniter(s) fails to light after successful unit purge. [See 6.6.5.2.1.3(B)(9), 6.6.5.2.1.3(B)(10), and 6.8.5.2.1.3(B)(7).] (2) Any igniters proven on, all other fuel sources off, all igniter valves subsequently closed. (3a.1) Class 2 igniter(s) proven on, first main burner trial for ignition fails. (3a.2) Class 2 igniter(s) proven on, last main burner is taken out of service in a normal shutdown. (3a.3) Class 2 igniter(s) proven on, last main burner is taken out of service in an abnormal shutdown. (3b.1) Class 3 igniters proven on, first main burner trial for ignition fails. (3b.2) Class 3 igniter(s) proven on, last main burner is taken out of service in a normal shutdown. (3b.3) Class 3 igniter(s) proven on, last main burner is taken out of service in an abnormal shutdown. (4) Any Class 2 igniter(s) proven on, any pulverizer startup initiated, all pulverizers subsequently stopped, no other main fuel in service, igniter(s) remain proven. Action Required (1) Igniter valve(s) shall be closed immediately. Master fuel trip not required, but a 1-minute delay shall be required before retrial of that or any other igniter. (2) Master fuel trip shall be actuated. (3a.1) Master fuel trip shall be actuated. (3a.2) Associated main fuel gas trip valve and/or fuel oil trip valve shall be closed (fuel gas trip and/or fuel oil trip), proven igniters shall be permitted to remain in service. (3a.3) Master fuel trip shall be actuated. (3b.1) Master fuel trip shall be actuated. (3b.2) Master fuel trip shall be actuated. (3b.3) Master fuel trip shall be actuated. (4) (a) If first pulverizer fails to ignite as described in 6.8.5.2.1.3(B)(12), master fuel trip shall be actuated. (b) If last pulverizer in service is tripped, master fuel trip shall be actuated. (c) If last pulverizer in service is taken out of service in a normal shutdown sequence by an operator, proven igniters shall be permitted to remain in service.

1 of 109 11/18/2013 11:57 AM Condition (5) All igniter and burner valves closed and all feeders or pulverizers stopped. Action Required (5) Master fuel trip shall be actuated. Statement of Problem and Substantiation for Public Comment Referring to Block 10b, to accommodate for various types of once-through boiler designs and different operating conditions, recommend leaving the method of meeting the intent of Feedwater Flow Low trip to boiler manufacturer. Some existing methods of detecting Feedwater Flow issues are: 1) Loss of all Boiler Feedwater Pumps; 2) Waterwall Outlet Pressure High (possible blockage downstream); 3) Waterwall Outlet Pressure Low (possible tube leaks downstream); 4) Waterwall Outlet Temperature High (Feedwater Flow low relative to Fuel Flow); 5) dp Low between Waterwall Outlet and Throttle Pressure headers. Alternative parameters such as P, T, dp, and equipment status can be used to detect Feedwater Flow Low as specified by boiler manufacturer. Related Public Comments for This Document Related Comment Public Comment No. 51-NFPA 85-2013 [Section No. A.6.4.1.2.1] Relationship Submitter Full Name: SINMING KWONG Organization: EMERSON PROCESS MANAGEMENT PWS Submittal Date: Mon Nov 11 16:13:34 EST 2013 Copyright Assignment I, SINMING KWONG, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am SINMING KWONG, 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

4 of 109 11/18/2013 11:57 AM Public Comment No. 71 Figure 6.4.1.2.1 and Table 6.4.1.2.1(a) through Table 6.4.1.2.1(c) show the minimum required system of interlocks that shall be provided for basic furnace protection for a multiple burner boiler operated in accordance with this code. Figure 6.4.1.2.1 Interlock System for Multiple Burner Boiler. Table 6.4.1.2.1(a) Interlock System for Multiple Burner Boiler Block Number Block 1 Block 2a1 Block 2a2 Block 2b Blocks 3 through 13 Action Loss of an individual igniter flame shall cause the following actions: (1) Close the individual igniter safety shutoff valve(s) and de-energize the spark(s). (2) Open the vent valve (fuel gas ignition only). (3) Signal the main flame protection system that the igniter flame has been lost. High or low igniter fuel gas header pressure shall be interlocked to initiate the tripping of the igniter header and individual igniter safety shutoff valves and de-energize sparks. Low igniter fuel oil header pressure shall be interlocked to initiate the tripping of the igniter header and individual igniter safety shutoff valves and de-energize sparks. Where fuel oil is used for ignition fuel with air or steam atomization, atomizing air or steam pressure out of range shall trip the igniter header and individual igniter safety shutoff valves and de-energize sparks. Where direct electric igniters are used, blocks 1 and 2 shall not apply. However, the master fuel trip system shall de-energize sparks and prevent re-energizing until all conditions for light-off have been re-established. These blocks represent conditions that initiate the tripping of all main and ignition fuel supplies through a master fuel trip relay contact(s). The master fuel trip relay(s) shall be of the type that stays tripped until the unit purge system interlock permits it to be reset. Whenever the master fuel trip relay(s) is operated, it shall trip all fuel header, burner, and igniter safety shutoff valves and de-energize all sparks and all ignition devices within the unit and flue gas path through master fuel trip relay contact(s). Master fuel trip relay contacts shall also trip the fuel oil system circulating and recirculating valves. If the design of the fuel oil supply system is such that backflow of fuel oil through the recirculating valve is inherently impossible or positively prevented, this valve shall be permitted to be manually operated and shall not be required to be interlocked to close automatically on a master fuel trip.

5 of 109 11/18/2013 11:57 AM Block Action Number Table 6.4.1.2.1(b) Fuel Inputs Shutoff When Class 1 Igniters Are Used Condition (1) First Class 1 igniter(s) fails to light after successful unit purge. [See 6.6.5.2.1.3(B)(9), 6.6.5.2.1.3(B)(10), and 6.8.5.2.1.3(B)(7).] (2) Any igniters proven on, all other fuel sources off, all igniter valves subsequently closed. (3) Any Class 1 igniter(s) proven on, any burner valve leaves closed limit, all burner valves subsequently closed, no other main fuel in service, igniter(s) remain proven. (4) Any Class 1 igniter(s) proven on, any pulverizer startup initiated, all pulverizers subsequently stopped, no other main fuel in service, igniter(s) remain proven. (5) All igniter and burner valves closed and all feeders or pulverizers stopped. Action Required (1) Igniter valve(s) shall be closed immediately. Master fuel trip not required, but a 1-minute delay shall be required before retrial of that or any other igniter. (2) Master fuel trip shall be actuated. (3) Associated main fuel gas trip valve and/or fuel oil trip valve shall be closed (fuel gas trip and/or fuel oil trip), proven igniters shall be permitted to remain in service. (4) Proven igniters shall be permitted to remain in service. (5) Master fuel trip shall be actuated. Table 6.4.1.2.1(c) Fuel Inputs Shutoff When Class 2 or Class 3 Igniters Are Used Condition (1) First Class 2 or 3 igniter(s) fails to light after successful unit purge. [See 6.6.5.2.1.3(B)(9), 6.6.5.2.1.3(B)(10), and 6.8.5.2.1.3(B)(7).] (2) Any igniters proven on, all other fuel sources off, all igniter valves subsequently closed. (3a.1) Class 2 igniter(s) proven on, first main burner trial for ignition fails. (3a.2) Class 2 igniter(s) proven on, last main burner is taken out of service in a normal shutdown. (3a.3) Class 2 igniter(s) proven on, last main burner is taken out of service in an abnormal shutdown. (3b.1) Class 3 igniters proven on, first main burner trial for ignition fails. (3b.2) Class 3 igniter(s) proven on, last main burner is taken out of service in a normal shutdown. (3b.3) Class 3 igniter(s) proven on, last main burner is taken out of service in an abnormal shutdown. (4) Any Class 2 igniter(s) proven on, any pulverizer startup initiated, all pulverizers subsequently stopped, no other main fuel in service, igniter(s) remain proven. Action Required (1) Igniter valve(s) shall be closed immediately. Master fuel trip not required, but a 1-minute delay shall be required before retrial of that or any other igniter. (2) Master fuel trip shall be actuated. (3a.1) Master fuel trip shall be actuated. (3a.2) Associated main fuel gas trip valve and/or fuel oil trip valve shall be closed (fuel gas trip and/or fuel oil trip), proven igniters shall be permitted to remain in service. (3a.3) Master fuel trip shall be actuated. (3b.1) Master fuel trip shall be actuated. (3b.2) Master fuel trip shall be actuated. (3b.3) Master fuel trip shall be actuated. (4) (a) If first pulverizer fails to ignite as described in 6.8.5.2.1.3(B)(12), master fuel trip shall be actuated. (b) If last pulverizer in service is tripped, master fuel trip shall be actuated. (c) If last pulverizer in service is taken out of service in a normal shutdown sequence by an operator, proven igniters shall be permitted to remain in service.

6 of 109 11/18/2013 11:57 AM Condition (5) All igniter and burner valves closed and all feeders or pulverizers stopped. Action Required (5) Master fuel trip shall be actuated. Statement of Problem and Substantiation for Public Comment It would not be sufficient to mention the "low drum water level" only as interlock condition for drum type boiler in consideration of the two types of Drum Boilers. One type is the natural circulation type and another is forced circulation type which is equipped with boiler circulation pumps (BCP). For the forced circulation type boiler, a low differential pressure of BCP is usually applied as interlock condition to initiate the master fuel trip relay instead of low drum water level condition. Submitter Full Name: masahiko mishiro Organization: Mitsubishi Heavy Industries,ltd. Submittal Date: Thu Nov 14 00:07:12 EST 2013 Copyright Assignment I, masahiko mishiro, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am masahiko mishiro, 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

7 of 109 11/18/2013 11:57 AM Public Comment No. 46-NFPA 85-2013 [ Section No. 6.4.1.2.6.4(B) ] (B) * A time delay before of not grester than 3 seconds before tripping of FD fan(s) shall be permitted where the duration is determined by a transient pressure analysis. Statement of Problem and Substantiation for Public Comment The furnace and downstream components on a balanced draft unit are not designed to withstand the pressure that the FD fans can provide. Submitter Full Name: Allan Zadiraka Organization: [ Not Specified ] Submittal Date: Mon Nov 11 15:19:05 EST 2013 Copyright Assignment I, Allan Zadiraka, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Allan Zadiraka, 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

8 of 109 11/18/2013 11:57 AM Public Comment No. 75-NFPA 85-2013 [ Section No. 6.4.1.2.7.6 ] 6.4.1.2.7.6 * Before main fuel firing and following a 5-minute period after a following a master fuel trip (furnace postpurge), FD fans shall be tripped if the furnace pressure exceeds the maximum pressure value recommended by the manufacturer. Statement of Problem and Substantiation for Public Comment 1. Comparing with 6.4.1.2.6.5 and 6.4.1.2.7.6, there is some possibility to invite misunderstanding, which is "post purge shall have more priority even in the condition that furnace pressure exceeds the maximum furnace design pressure". 2. ID fan and FD fan shall be tripped before the main fuel firing and following a master fuel trip, when the furnace pressure exceeds the maximum furnace design pressure. 3. Since a natural post purge (15min.) is required as mentioned in 6.4.1.2.4.3 (C) in case of all fans trip condition, therefore there is no necessary to mention that post purge has more priority. 4. What We have to mention in this code is " When the FD fan stopped in the period of post purge incompleted condition, it is important to avoid to supply air suddenly, positively by starting FD fan". Submitter Full Name: masahiko mishiro Organization: Mitsubishi Heavy Industries, ltd. Submittal Date: Fri Nov 15 00:28:32 EST 2013 Copyright Assignment I, masahiko mishiro, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am masahiko mishiro, 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

9 of 109 11/18/2013 11:57 AM Public Comment No. 52-NFPA 85-2013 [ Section No. 6.4.1.2.8 ] 6.4.1.2.8 Multiple and Variable-Speed Fan Interlocks. On start of the second fan and subsequent fan(s), whether the FD or ID type, the fan shall be capable of delivering airflow before airflow after opening its damper(s). Statement of Problem and Substantiation for Public Comment It is not possible to generate airflow through the fan with dampers closed. To generate airflow through the starting fan, its dampers need to be opened; and its fan speed develops sufficient head to overcome the discharge pressure of the parallel running fan. Submitter Full Name: SINMING KWONG Organization: EMERSON PROCESS MANAGEMENT PWS Submittal Date: Tue Nov 12 09:42:20 EST 2013 Copyright Assignment I, SINMING KWONG, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am SINMING KWONG, 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

0 of 109 11/18/2013 11:57 AM Public Comment No. 9-NFPA 85-2013 [ Section No. 6.4.2.1.27 ] 6.4.2.1.27 Axial Flow Fan Nearing Stall Line. This condition shall be sensed and alarmed in accordance with the manufactuer manufacturer 's recommendations. Statement of Problem and Substantiation for Public Comment The word was not spelled correctly. Submitter Full Name: Dale Evely Organization: Southern Company Services, Inc Submittal Date: Fri Sep 20 07:25:16 EDT 2013 Copyright Assignment I, Dale Evely, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Dale Evely, 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

1 of 109 11/18/2013 11:57 AM Public Comment No. 47-NFPA 85-2013 [ New Section after 6.5.2.1 ] 6.5.2.1.2 High positive furnace pressure trip interlock shall be selected based on the positive design pressure of the furnace. 6.5.2.1.3 High negative furnace pressure trip interlock shall be selected such that the trip value and the resulting negative furnace pressure transient does not exceed the furnace negative transient design pressure. Statement of Problem and Substantiation for Public Comment The addition of the high negative furnace pressure trip requirement to the code requires that additional guidance be provided on setting the high negative pressure trip set point. Submitter Full Name: Allan Zadiraka Organization: [ Not Specified ] Submittal Date: Mon Nov 11 15:39:03 EST 2013 Copyright Assignment I, Allan Zadiraka, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Allan Zadiraka, 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

2 of 109 11/18/2013 11:57 AM Public Comment No. 48-NFPA 85-2013 [ Section No. 6.5.2.1 ] 6.5.2.1 Functional Requirements. 6.5.2.1.1 The furnace pressure control system shall control the furnace pressure at the set point in the combustion chamber. Statement of Problem and Substantiation for Public Comment Revise numbering to match proposed addition. Submitter Full Name: Allan Zadiraka Organization: [ Not Specified ] Submittal Date: Mon Nov 11 15:54:36 EST 2013 Copyright Assignment I, Allan Zadiraka, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Allan Zadiraka, 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

3 of 109 11/18/2013 11:57 AM Public Comment No. 53-NFPA 85-2013 [ Section No. 6.5.2.3 ] 6.5.2.3 Component Requirements. The furnace pressure control element(s) [(H) in Figure 6.5.2.2.1] (fan inlet damper blade pitch control, speed control) shall meet the following criteria: (1) * The operating speed shall not exceed the control system's sensing and positioning capabilities. (2) The operating speed The response of the furnace pressure control equipment shall not be less than that of the airflow control equipment. Statement of Problem and Substantiation for Public Comment To avoid confusion, it is best to change "speed" to "response". Otherwise, Reader can mis-interpret the statement such that ID Fan motor speed must be equal or greater than FD Fan motor speed. Submitter Full Name: SINMING KWONG Organization: EMERSON PROCESS MANAGEMENT PWS Submittal Date: Tue Nov 12 10:16:49 EST 2013 Copyright Assignment I, SINMING KWONG, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am SINMING KWONG, 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

4 of 109 11/18/2013 11:57 AM Public Comment No. 81-NFPA 85-2013 [ New Section after 6.5.3.2.2 ] TITLE OF NEW CONTENT 6.5.3.2.3 Where the system design does not permit the use of fully open air paths, the minimum open area air paths shall be not less than that required for purge airflow requirements with fans in operation. Statement of Problem and Substantiation for Public Comment FR 162 asked for a new sectoni 6.5.3.2.2 which was inserted correctly. FR 162 stated that subsequent paragraphs should be renumbered. However, it appears that the old section 6.5.3.2.2 was deleted. Committee needs to confirm if the old section 6.5.3.2.2. is to be deleted or to be retained Submitter Full Name: Daniel Lee Organization: ABB Incorporated Submittal Date: Fri Nov 15 09:45:42 EST 2013 Copyright Assignment I, Daniel Lee, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Daniel Lee, 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

Public Comment No. 60-NFPA 85-2013 [ Section No. 6.6.3.1.11 ] 6.6.3.1.11 Valve Leak Testing. 6.6.3.1.11.1 Tightness tests of the main safety shutoff valves, individual burner safety shutoff valves, and associated vent valves shall be performed. 6.6.3.1.11.2 Permanent provisions shall be made in the fuel gas piping to allow for making leak tests and subsequent repairs. 6.6.3.1.11.3 Valves added in vent lines for leak testing shall be either continuously monitored and alarmed when in the incorrect position or locked in the open position except when leak testing is being performed. Statement of Problem and Substantiation for Public Comment CC NOTE: The following CC Note No. 26 appeared in the First Draft Report. The MBB committee should add a time frame to this requirement, such as "at least annually or in accordance with 4.4.1.1." Submitter Full Name: CC on BCS-AAC Organization: CC on Boiler Combustion System Hazards Submittal Date: Wed Nov 13 13:12:05 EST 2013 Copyright Assignment I, CC on BCS-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am CC on BCS-AAC, 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 5 of 109 11/18/2013 11:57 AM

6 of 109 11/18/2013 11:57 AM Public Comment No. 32-NFPA 85-2013 [ Section No. 6.6.3.1.11.1 ] 6.6.3.1.11.1 Tightness tests of the main safety shutoff valves, individual burner safety shutoff valves, and associated vent valves shall be performed at least annually or, for units firing a single fuel, at the first opportunity that the unit is down since the last tightness test. Statement of Problem and Substantiation for Public Comment "Shall be performed" it is not enforceable. The added text defines the minimum requirement. Submitter Full Name: Celso Schmidt Organization: UTC/Forney Corporation Submittal Date: Sun Nov 10 15:32:05 EST 2013 Copyright Assignment I, Celso Schmidt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Celso Schmidt, 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

7 of 109 11/18/2013 11:57 AM Public Comment No. 35-NFPA 85-2013 [ Section No. 6.6.5.1.3.2 ] 6.6.5.1.3.2 * Successful completion of the leak test shall be done before the main gas supply header is be conducted, at least annually, before the safety shutoff header valve is placed into operation. Additional Proposed Changes File Name Description Approved A.6.6.5.1.3.2.docx Annex material for 6.6.5.1.3.2 Statement of Problem and Substantiation for Public Comment 1- Unless when an automatic gas header leak test is provided, the NFPA 85 community does not follow the requirement to perform a gas header leak test every time the Main Gas Header Shutoff Valve is closed. An annual gas leak test should be a minimum requirement. 2- If automatic gas leak test is provided in the BMS logic, a Leak Test Credit of an 8-day period should be allowed to avoid the leak test to be repeated several times during a boiler start-up, wham multiple trips are expected. 3- Section 6.6.5.1.3 could be consolidated with section 6.6.3.1.11. 4-Revised Anex material was suggested for this section. Submitter Full Name: Celso Schmidt Organization: UTC/Forney Corporation Submittal Date: Sun Nov 10 16:25:51 EST 2013 Copyright Assignment I, Celso Schmidt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Celso Schmidt, 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

Proposed Annex material for Automatic Gas Header Leak Test Automatic Gas Header Leak Test NFPA85 Chapter 6 The objective of the leak test is to ensure that the main gas header safety shutoff valve is not leaking gas and that the individual burner safety shutoff valves are not leaking gas into the furnace. 1. The Logic proves the following conditions before setting the Gas Header Leak Test permissive: All individual gas burner safety shutoff valves closed Air flow at purge rate Gas Supply pressure adequate Gas Charging Valve closed (if existing) Gas Header Safety Shutoff Valve closed Gas Control Valve at Lightoff position 2. When the Main Gas Header Leak Test is commanded to start, the BMS logic opens momentary the Gas Charging Valve (or the Main Gas Safety Shutoff Valve if no charging valve is provided). 3. When the Main Gas Header reaches an adequate pressure for the Leak Test to be performed (usually a little above the maximum operating pressure) the Gas Charging Valve (or the Main Gas Safety Shutoff Valve) is commanded to close. 4. If the leak test adequate pressure is not established in a 15 seconds time interval, the test is interrupted and an alarm Main Gas Header Leak Test Pressurization Failure is issued. 5. When the main gas header reaches the adequate pressure for leak test (provided by a pressure transmitter installed at the gas header), this value is captured by the BMS logic. 6. During the next 180 seconds, this captured value is compared with the actual main gas header pressure: a) If the main gas header pressure drops 10% below the captured gas header leak test value, the header is leaking and an alarm Main Gas Header Safety Shutoff Valve Leak Test Failure is issued. b) If the main gas header pressure increases 10% above the captured gas header leak test value, the Main Gas Header Safety Shutoff Valve is leaking and an alarm Main Gas Header Safety Shutoff Valve Leak Failure is issued. c) If the main gas header pressure remains in limits of the captured gas header leak test value, the gas leak test is successful and an indication Main Gas Leak Test Successful is displayed. 7. To test the second burner gas block valves and the burner vent valves, the BMS logic shall be repeated with the first burner gas block valve maintained open and the burner vent valves maintained closed. 8. When the Main Gas Header Leak Test is Successful in both stages, this status remains set for 8 hours. The operator command to re-start the leak test resets the 8-hours leak test credit. These Notes Recorded and Presented by: Celso Schmidt November 18, 2013 Page 1 of 2

NFPA85 Chapter 6 Typical HMI graphic display (for oil fuel) These Notes Recorded and Presented by: Celso Schmidt November 18, 2013 Page 2 of 2

0 of 109 11/18/2013 11:57 AM Public Comment No. 37 The starting sequence shall be performed in the following order: (1) An open flow path from the inlets of the FD fans through the stack shall be verified. (2) An ID fan, if provided, shall be started; an FD fan then shall be started. Additional ID fans or FD fans shall be started in accordance with 6.5.3, as necessary, to achieve purge flow rate. (3) Dampers and burner registers shall be opened to the purge position in accordance with the open register purge method objectives outlined in 6.6.5.1.5.7. (4) The airflow shall be adjusted to purge airflow rate, and a unit purge shall be performed. Special provisions shall be utilized as necessary to prevent the hazardous accumulation of volatile vapors that are heavier than air or to detect and purge accumulations in the furnace bottom. (5) The main fuel control valve shall be closed and be positioned at lightoff firing rate (or closed if a bypass regulator is being provided) and the main safety shutoff valve(s) shall be opened, but only after the requirements of 6.6.5.1.3 for leak test requirements and 6.4.1.2.4 for permissive conditions in the unit purge system have been satisfied. (6) It shall be determined that the main fuel control valve is closed, and the following procedures shall be performed: (a) (b) (c) (d) The main fuel bypass control valve, if provided, shall be set to maintain the necessary burner header fuel pressure for light-off. The burner headers shall be vented in order to be filled with fuel gas and to provide a flow (if necessary) so that the main fuel and bypass fuel control valves function to regulate and maintain the correct pressure for burner light-off. The main fuel control valve shall be opened when necessary. The time needed to vent for control of header pressure after header charging shall be evaluated and minimized. (7) The igniter safety shutoff valve shall be opened, and the following shall be performed: (a) (b) (c) It shall be confirmed that the igniter fuel control valve is holding the manufacturer's recommended fuel pressure necessary for the igniter to operate at design capacity. The igniter headers shall be vented in order to be filled with fuel gas and to provide a flow (if necessary) so that the igniter fuel control valve functions to regulate and maintain the pressure within design limits specified by the manufacturer for lighting the igniters. The time needed to vent for control of header pressure after header charging shall be evaluated and minimized. (8) The air register or damper on the burner selected for light-off shall be adjusted to the position recommended by the manufacturer or the established operating procedure, in accordance with 6.6.5.1.5.7(C) through 6.6.5.1.5.7(F). (9) The spark or other source of ignition for the igniter(s) on the burner(s) to be lit shall be initiated, and the procedure shall continue as follows: (a) (b) (c) (d) The individual igniter safety shutoff valve(s) shall be opened, and all igniter system atmospheric vent valves shall be closed. If flame on the first igniter(s) is not established within 10 seconds, the individual igniter safety shutoff valve(s) shall be closed and the cause of failure to ignite shall be determined and corrected. With airflow maintained at purge rate, repurge shall not be required, but at least 1 minute shall elapse before a retrial of this or any other igniter is attempted. Repeated retrials of igniters without investigating and correcting the cause of the malfunction shall be prohibited. (10) Where Class 3 special electric igniters are used, the procedures described in 6.6.5.2.1.3(B) (1) through 6.6.5.2.1.3(B) (6), 6.6.5.2.1.3(B) (8), and 6.6.5.2.1.3(B) (11) through 6.6.5.2.1.3(B) (14) shall be used, consistent with the the requirements for individual main burner flame supervision. (11) After making certain that the igniter(s) is established and is providing the required level of ignition energy for the main burner(s), the following shall be performed:

1 of 109 11/18/2013 11:57 AM (a) (b) (c) (d) (e) The individual burner safety shutoff valve(s) shall be opened and the individual burner atmospheric vent valves shall be closed. Except where associated Class 1 igniters are in service, a master fuel trip shall be initiated when the flame detection system(s) indicates that ignition has not been obtained within 5 seconds of the time the main fuel actually begins to enter the furnace. Purging shall be repeated, and the conditions that caused the failure to ignite shall be corrected before another light-off attempt is made. For the following burner and all subsequent burners placed in operation, failure to ignite or loss of ignition for any reason on any burner(s) shall cause fuel flow to that burner(s) to stop. All conditions required by the manufacturer or by established operating procedures for light-off shall exist before restarting the burner(s). (12) After stable flame is established, the air register(s) or damper(s) shall be adjusted slowly to its operating position, making certain that ignition is not lost in the process. With automatic burner management systems, the air register shall be permitted to be opened simultaneously with the burner safety shutoff valve. (13) Class 3 igniters shall be shut off at the end of the time trial for proving the main flame, and the following shall be verified: (a) (b) The stable flame continues on the main burners after the igniters are shut off. The systems that allow the igniters to remain in service on either an intermittent or a continuous basis have been tested to meet all the requirements of Class 1 igniters or Class 2 igniters with associated interlocks in service. (14) After stable burner header pressure control has been established, the burner header atmospheric vent valve shall be closed. (15)* The sequence shall continue as follows: (16) The procedures in 6.6.5.2.1.3(B) (8) through 6.6.5.2.1.3(B) (13) shall be followed for placing additional burners with open registers in service, as necessary, to raise steam pressure or to carry additional load. (17) If used, automatic control of burner fuel flow and burner airflow during the lighting and start-up sequence shall be in accordance with the requirements of 6.6.5.2.1.3(B) (17). (18) The fuel flow to each burner (as measured by the burner fuel header pressure) shall be maintained at a controlled value that is compatible with the established airflow through the corresponding burner. (19) The established airflow through each open register shall be permitted to be maintained by controlling the windbox-to-furnace differential. (20) Total furnace airflow shall not be reduced below purge rate airflow and shall be at least that which is necessary for complete combustion in the furnace. (21) If it is necessary to vary fuel header pressure to eliminate a problem of having excessive lighting off and shutting down of burners, such variations shall be limited to a predetermined range. (22) This range shall be a function of the incremental fuel input that is added by the lighting of a single burner or gang of burners. (23) The maximum number of burners shall be placed in service consistent with the anticipated continuous load and the operating range of fuel header pressures. (24) The on-line metering combustion control (unless designed specifically for start-up procedures) shall not be placed into service until the following have occurred: (a) (b) (c) A predetermined minimum main fuel input has been attained. All registers on nonoperating burners are closed unless compensation is provided for by the control system. The burner fuel and airflow are adjusted as necessary.

2 of 109 11/18/2013 11:57 AM (d) Stable flame and specified furnace conditions have been established. (25) It shall be permitted to place a multiple number of igniters in service that are served simultaneously from a single igniter safety shutoff valve, provided that the igniters are reliably supervised, so that failure of one of the group to light causes the fuel to all igniters in the group to shut off. (26) It also shall be permitted to place in service simultaneously a multiple number of burners served by their corresponding multiple igniters from a single burner safety shutoff valve, provided that the burners are reliably supervised, so that failure of one of the group to light causes the fuel to all burners in the group to shut off. (27) On units with an overfire air system, the overfire air control damper positions shall be permitted to be changed only when repositioning of all burner air registers or burner air dampers is permitted. (28) On units with an overfire air system, the boiler shall be operating in a stable manner before the overfire air is introduced. The introduction of the overfire air shall not adversely affect boiler operation. (29) On units with an overfire air system and a reburn system, the overfire air shall be placed in operation before the reburn fuel sequence is started. (30) A reburn system shall be placed in service only after the following have occurred: (a) The boiler shall be operating at a load that ensures the introduction of the reburn fuel will not adversely affect continued boiler operation. (b) The temperature in the reburn zone shall be maintained in accordance with 6.6.3.5.2. (c) The boiler shall be operating in a stable manner before the reburn start-up sequence is initiated. Statement of Problem and Substantiation for Public Comment If a bypass regulator for burner lightoff is not provided, as usual, the valve needs to be proven at lightoff firing rate (minimum position). Submitter Full Name: Celso Schmidt Organization: UTC/Forney Corporation Submittal Date: Sun Nov 10 17:56:53 EST 2013 Copyright Assignment I, Celso Schmidt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Celso Schmidt, 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

3 of 109 11/18/2013 11:57 AM Public Comment No. 80-NFPA 85-2013 [ Section No. 6.6.5.2.3.10 ] 6.6.5.2.3.10 * After shutting down the forced and induced draft fans, dampers in the flue gas path shall and air path shall be permitted to be closed. Statement of Problem and Substantiation for Public Comment The original text stated that closing the burner air registers was allowed but the FR text only allows the closing of the boiler flue gas path. I understand that the first report was modified for two purposes 1) to address multiple boilers with a common flue gas path and to allow boiler bottle-up. The closing of the flue gas path is a requirement for multiple boilers but, closing the flue gas path is not necessary the only means to bottle up the boilers. I understand that some user bottle up the boiler with both the air gas path and flue gas path. The proposed comment is consistent with the original requirement and the current industry practice of bottling up the boiler. Submitter Full Name: Daniel Lee Organization: ABB Incorporated Submittal Date: Fri Nov 15 09:30:15 EST 2013 Copyright Assignment I, Daniel Lee, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Daniel Lee, 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

4 of 109 11/18/2013 11:57 AM Public Comment No. 14-NFPA 85-2013 [ Section No. 6.7.3.1.2.2 ] 6.7.3.1.2.2 * Relief valve discharge passages, vents, and telltales shall be provided with suitable piping to allow discharge of fuel oil, vapors, or toxic fumes in accordance with the requirements of 4.9.1. away from sources of ignition, combustion air intakes, building ventilation systems, or windows of a boiler or HSRG room or adjacent buildings and shall be designed for the expected range of external temperatures and protected against mechanical damage. Statement of Problem and Substantiation for Public Comment The First Draft text references section 4.9.1 which is for Gaseous Vents. The proposed text is similar to the First Draft wording added to for HRSG liquid fuels (8.4.3.2.3.5). Submitter Full Name: Steven Graf Organization: Emerson Process Management Submittal Date: Fri Oct 25 08:30:49 EDT 2013 Copyright Assignment I, Steven Graf, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Steven Graf, 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

5 of 109 11/18/2013 11:57 AM Public Comment No. 30-NFPA 85-2013 [ Section No. 6.7.3.1.11.1 ] 6.7.3.1.11.1 Tightness tests of the main safety shutoff valves and individual burner safety shutoff valves shall be performed at least annually or, for units firing a single fuel, at the first opportunity that the unit is down after one year since the last tightness test. Statement of Problem and Substantiation for Public Comment 'Shall be provided" it is not enforceable. The added text defines the minimum requirement. Submitter Full Name: Celso Schmidt Organization: UTC/Forney Corporation Submittal Date: Sun Nov 10 15:05:56 EST 2013 Copyright Assignment I, Celso Schmidt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Celso Schmidt, 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

6 of 109 11/18/2013 11:57 AM Public Comment No. 55-NFPA 85-2013 [ Section No. 6.7.5.1.2.1 ] 6.7.5.1.2.1 Cleaning devicesshall devices shall be operated only where heat input to the furnace is at a rate high enough to prevent a flameout during the sootblower operation cleaning device operation. Statement of Problem and Substantiation for Public Comment In the revised First Revision text, the term "sootblower" has been revised to a generic term of "cleaning devices". The change was made to the first reference to "sootblower" at the beginning of the section but also applies to the second reference to sootblower at the end of the section. This also provides consistency with the FR text in section 6.6.5.1.2.1. Submitter Full Name: John O'Rourke Organization: ALSTOM Power Inc. Submittal Date: Wed Nov 13 11:33:29 EST 2013 Copyright Assignment I, John O'Rourke, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am John O'Rourke, 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

7 of 109 11/18/2013 11:57 AM Public Comment No. 59-NFPA 85-2013 [ Section No. 6.7.5.1.2.3 ] 6.7.5.1.2.3 The use of waterwall cleaning devices and high temperature superheater and reheater sootblowers shall reheater cleaning devices shall be permitted for cleaning during periods of unit outage if a unit purge has been completed and purge rate airflow is maintained. Statement of Problem and Substantiation for Public Comment In the revised First Revision text, the term "sootblower" has been revised to a generic term of "cleaning devices". The change was made to the first reference to "sootblower" at the beginning of the section but also applies to the second reference to sootblower at the end of the section. The term superheater and reheater sootblowers" should be replaced with "superheater and reheater cleaning devices". The original text referenced wall sootblowers and superheater and reheater sootblowers. In the First Revision text, the term "wall sootblowers" was deleted and was replaced with "Cleaning Devices". The term wall should be added to the FR text. Assuming that the above comment is accepted, The revised would otherwise read, 6.7.5.1.2.3 The use of cleaning devices and high temperature superheater and reheater cleaning devices shall be permitted The above comments provide consistency with the FR text in section 6.6.5.1.2.3. Submitter Full Name: John O'Rourke Organization: ALSTOM Power Inc. Submittal Date: Wed Nov 13 13:09:34 EST 2013 Copyright Assignment I, John O'Rourke, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am John O'Rourke, 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

8 of 109 11/18/2013 11:57 AM Public Comment No. 36-NFPA 85-2013 [ Section No. 6.7.5.1.3 ] 6.7.5.1.3 * Operational Leak Test. An operational leak test shall be performed in accordance with established procedures while maintaining, at a minimum least annually, while maintaining purge rate airflow before, before the oil supply safety shutoff header is valve is placed in service operation. Additional Proposed Changes File Name Description Approved A.6.7.5.1.3.docx Annex material for 6.7.5.1.3 Statement of Problem and Substantiation for Public Comment 1- Unless when an automatic oil header leak test is provided, the NFPA 85 community does not follow the requirement to perform an oil header leak test every time the Main Oil Header Shutoff Valve is closed. An annual oil leak test should be a minimum requirement. 2- If automatic oil leak test is provided in the BMS logic, an Oil Leak Test Credit of an 8-day period should be allowed to avoid the leak test to be repeated several times during a boiler start-up, when multiple trips are expected. 3- Section 6.7.5.1.3 could be consolidated with section 6.7.3.1.11. 4-Revised Anex material was suggested for this section. Submitter Full Name: Celso Schmidt Organization: UTC/Forney Corporation Submittal Date: Sun Nov 10 17:28:51 EST 2013 Copyright Assignment I, Celso Schmidt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (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 Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Celso Schmidt, 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

Proposed Annex material for Automatic Oil Header Leak Test Automatic Main Oil Header Leak Test NFPA85 Chapter 6 The objective of the leak test is to ensure that the main oil header safety shutoff valve is not leaking oil and that the individual burner safety shutoff valves are not leaking oil into the furnace. 1. The Logic proves the following conditions before setting the Oil Header Leak Test permissive: All individual oil burner safety shutoff valves closed Air flow at purge rate Oil Supply pressure adequate Oil Temperature adequate Oil Recirculation Valve closed Oil Header Safety Shutoff Valve closed Oil Control Valve at Lightoff position 2. When the Main Oil Header Leak Test is commanded to start, the BMS logic opens momentary the Main Oil Safety Shutoff Valve. 3. When the Main Oil Header reaches an adequate pressure for the Leak Test to be performed (usually a little above the maximum operating pressure) the Main Oil Safety Shutoff Valve is commanded to close. 4. If the leak test adequate pressure is not established in a 5 seconds time interval, the test is interrupted and an alarm Main Oil Header Leak Test Pressurization Failure is issued. 5. When the main oil header reaches the adequate pressure for leak test (provided by a pressure transmitter installed at the oil header), this value is captured by the BMS logic. 6. During the next 60 seconds, this captured value is compared with the actual main oil header pressure: a) If the main oil header pressure drops 20% below the captured oil header leak test value, the header is leaking and an alarm Main Oil Header Safety Shutoff Leak Test Failure is issued. b) If the main oil header pressure increases 10% above the captured oil header leak test value, the Main Oil Header Safety Shutoff Valve is leaking and an alarm Main Oil Header Safety Shutoff Valve Leak Failure is issued. c) If the main oil header pressure remains in limits of the captured oil header leak test value, the oil leak test is successful and an indication Main Oil Leak Test Successful is displayed. 7. When the Main Oil Header Leak Test is Successful, this status remains set for 8 hours. The operator command to re-start the leak test resets the 8-hours leak test credit. These Notes Recorded and Presented by: Celso Schmidt November 18, 2013 Page 1 of 2

Typical HMI graphic display NFPA85 Chapter 6 These Notes Recorded and Presented by: Celso Schmidt November 18, 2013 Page 2 of 2