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Report on Comments F2006 -- Copyright, NFPA

Report of the Committee on Boiler Combustion System Hazards (BCS-AAC) Technical Correlating Committee Michael C. Polagye, Chair FM Global, MA [I] Bill Bass, Forney Corporation, TX [M] James R. Bostick, ABB Automation, OH [M] Dale E. Dressel, Solutia Incorporated, MO [U] David S. Eason, Detroit Edison Company, MI [U] Ronald E. Fringeli, Marsh USA Incorporated, OH [I] Gordon G. Gaetke, The Dow Chemical Company, TX [U] Masaaki Kinoshita, Mitsubishi Heavy Industries Limited, Japan [M] Robert Malanga, Fire and Risk Engineering, NJ [SE] Jerry J. Moskal, ALSTOM Power Incorporated, CT [M] Nancy C. Polosky, Babcock & Wilcox Company, OH [M] Peter J. Willse, GE Insurance Solutions, CT [I] Henry K. Wong, Washington Group International, NJ [SE] Alternates Ronald J. Fleming, ABB Incorporated, OH [M] (Alt. to James R. Bostick) Richard L. Haman, DTE Energy/Detroit Edison Company, MI [U] (Alt. to David S. Eason) Takayoshi (Ted) Isoda, Mitsubishi Power Systems, Incorporated, CA [M] (Alt. to Masaaki Kinoshita) Gerald E. McCullion, Honeywell, Incorporated, GA [M] (Voting Alt. to Honeywell Rep.) Michael R. Mulherin, The Dow Chemical Company, TX [U] (Alt. to Gordon G. Gaetke) John P. O'Rourke, ALSTOM Power Incorporated, CT [M] (Alt. to Jerry J. Moskal) Celso G. Schmidt, Forney Corporation, TX [M] (Alt. to Bill Bass) Nonvoting John C. deRuyter, The DuPont Company, Incorporated, DE [U] Rep. TC on Stoker Operations Michael B. Doherty, American Electric Power Service Corporation, OH [U] Rep. TC on Pulverized Fuel Systems John J. Eibl, The DuPont Company, TN [U] Rep. TC on Single Burner Boilers Dale P. Evely, Southern Company Services, Incorporated, AL [U] Rep. TC on Fundamentals of Combustion Systems Hazards Brian W. Moore, Hartford Steam Boiler Inspection & Insurance Company, CT [I] Rep. TC on Fluidized Bed Boilers John Van Name, Washington Group International, NY [SE] Rep. TC on Heat Recovery Steam Generators Harold R. Yates, HRY, Incorporated, MI [SE] Rep. TC on Multiple Burner Boilers Committee Scope: This Committee shall have primary responsibility for documents on the reduction of combustion system hazards in single- and multiple-burner boilers with a heat input rate of 2,500,000 Btu/hr and above. This includes all fuels. This Committee also is responsible for documents on the reduction of hazards in pulverized fuel systems, fluidized-bed boilers, heat recovery steam generators and other combustion turbine exhaust systems, and stoker-fired boilers, at any heat input rate. Report of the Committee on Fluidized Bed Boilers (BCS-FBB) Brian W. Moore, Chair Hartford Steam Boiler Inspection & Insurance Company, CT [I] P. K. Chelian, Foster Wheeler Power Group, Incorporated, NJ [M] Joseph N. Darguzas, EnviroPower, LLC, IL [IM] Shelton Ehrlich, Palo Alto, CA [SE] William Bradley George, Nova Scotia Power Incorporated, Canada [U] David Habenicht, Global Risk Consultants Corporation, IL [SE] Vic L. Jones, Merrick Industries Incorporated, FL [M] David L. Kraft, Babcock & Wilcox Company, OH [M] Donald L. Lueckenotte, Burns & McDonnell Engineering Company, MO [SE]

NFPA 85

Paul H. Miller, Southern Company Services, Incorporated, AL [U] Gary E. Norman, ALSTOM Power Incorporated, CT [M] Alternates Kevin M. Estes, Foster Wheeler Power Group, Incorporated, FL [M] (Alt. to P. K. Chelian) John P. O'Rourke, ALSTOM Power Incorporated, CT [M] (Alt. to Gary E. Norman) James M. Witt, Jr., Southern Company Services, Incorporated, AL [U] (Alt. to Paul H. Miller) Committee Scope: This Committee shall have primary responsibility for documents on the operation and reduction of combustion system hazards and the prevention of boiler furnace explosions of fluidized-bed boilers. This includes all fuels at any heat input rate. Report of the Committee on Fundamentals of Combustion Systems Hazards (BCS-FUN) Dale P. Evely, Chair Southern Company Services, Incorporated, AL [U] Kevin A. Alexeff, Stock Equipment Company, OH [M] Courtney D. Alvey, Baltimore, MD [SE] Carlton A. Bosfield, Grand Bahama Power Company, FL [U] David A. Cowdrick, Tampa Electric Company, FL [U] Richard A. Gallagher, Zurich Services Corporation, DE [I] Thomas B. George, Marsh USA Incorporated, MI [I] Ted Jablkowski, North American Manufacturing Company, CT [M] Randy J. Kleen, General Electric Company, TX [M] Richard T. Long, Jr., Exponent, Incorporated, MD [SE] Peter B. Matthews, Hartford Steam Boiler Inspection & Insurance Company, CT [I] Francisco A. Palacios, Babcock Power, Incorporated, MA [M] John R. Puskar, CEC Combustion Safety, Incorporated, OH [SE] Celso G. Schmidt, Forney Corporation, TX [M] Franklin R. Switzer, Jr., S-afe, Incorporated, IN [SE] Michael A. Walz, Burns & McDonnell Engineering Company, MO [SE] Harold R. Yates, HRY, Incorporated, MI [SE] Allan J. Zadiraka, The Babcock & Wilcox Company, OH [M] Alternates Bryan R. Baesel, CEC Combustion Safety, Incorporated, OH [SE] (Alt. to John R. Puskar) Barry J. Basile, Babcock Power, Incorporated, MA [M] (Alt. to Francisco A. Palacios) Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on fundamentals, maintenance, inspection, training, and safety for the reduction of combustion system hazards. Fundamentals shall specifically include definitions, furnace explosion/implosion prevention, manufacture, design and engineering, installation, coordination of design, construction and operation, basic operating objectives, equipment requirements, and commissioning. Report of the Committee on Heat Recovery Steam Generators (BCS-HRS) John Van Name, Chair Washington Group International, NY [SE] Harold Honath, Secretary Coen Company Incorporated, CA [M] Donald W. Bairley, ALSTOM Power Incorporated, CT [M] Robert R. Balsbaugh, Burns & McDonnell Engineering Company, MO [SE] Richard A. Brown, John Zink Company, LLC, OK [M] John H. Conroy, Forney Corporation, TX [M] Dale P. Evely, Southern Company Services, Incorporated, AL [U] Gordon G. Gaetke, The Dow Chemical Company, TX [U] George Y. Keller, Burns & Roe Enterprises, Incorporated, NJ [SE] Steven A. Lefton, Aptech Engineering Services, CA [SE] Brian W. Moore, Hartford Steam Boiler Inspection & Insurance Company, CT [I] Martin C. Nygard, Nooter/Eriksen, MO [M] Michael C. Polagye, FM Global, MA [I] Jimmie J. Schexnayder, Entergy Corporation, LA [U] Philip F. Souers, Siemens Power Corporation, FL [M] Joseph M. Vavrek, Sargent & Lundy, LLC, IL [SE] James P. Walawender, Black & Veatch Corporation, KS [SE]

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Report on Comments F2006 -- Copyright, NFPA

Alternates Alfred J. Beaty, Forney Corporation, TX [M] (Alt. to John H. Conroy) Sanda Brumaru, Burns and Roe Enterprises, NJ [SE] (Alt. to George Y. Keller) Rodney T. Crockett, John Zink Company, LLC, OK [M] (Alt. to Richard A. Brown) Rick Fiorenza, Coen Company Incorporated, CA [M] (Alt. to Harold Honath) Robert P. Kaltenbach, Burns & McDonnell Engineering Company, MO [SE] (Alt. to Robert R. Balsbaugh) Christopher J. Lech, ALSTOM Power Incorporated, CT [M] (Alt. to Donald W. Bairley) Michael R. Mulherin, The Dow Chemical Company, TX [U] (Alt. to Gordon G. Gaetke) George N. Pyros, Siemens Power Generation, FL [M] (Alt. to Philip F. Souers) Ronald Rispoli, Entergy Corporation, AR [U] (Alt. to Jimmie J. Schexnayder) Committee Scope: This Committee shall have primary responsibility for documents covering the operation of heat recovery steam generators and other combustion turbine exhaust systems, and the related reduction of combustion system hazards and prevention of explosions. This includes all fuels at any heat input rate. Report of the Committee on Multiple Burner Boilers (BCS-MBB) Harold R. Yates, Chair HRY, Incorporated, MI [SE] Bernard Hrul, Secretary Allen Bradley Company, MI [U] Courtney D. Alvey, Baltimore, MD [SE] Bill Bass, Forney Corporation, TX [M] Frank J. Bennett, Mirant Mid-Atlantic, MD [U] Dale E. Dressel, Solutia Incorporated, MO [U] John J. Eibl, The DuPont Company, TN [U] Dale P. Evely, Southern Company Services, Incorporated, AL [U] Kenneth Joe Frazier, Salt River Project, AZ [U] Gordon G. Gaetke, The Dow Chemical Company, TX [U] Kris A. Gamble, Black & Veatch Corporation, KS [SE] George Y. Keller, Burns & Roe Enterprises, Incorporated, NJ [SE] Richard Kimball, HF Controls Corporation, TX [M] Daniel J. Lee, ABB Incorporated, OH [M] W. Scott Matz, Invensys Process Systems, TX [M] Peter McKenna, Stone & Webster, Incorporated, MA [SE] Lalit M. Mehta, Coen Company, Incorporated, CA [M] Terry A. Nelson, Yokogawa Corporation of America, TX [M] John P. O'Rourke, ALSTOM Power Incorporated, CT [M] Francisco A. Palacios, Babcock Power, Incorporated, MA [M] Michael C. Polagye, FM Global, MA [I] Glenn A. Raney, Premier Consulting Services, TX [SE] Thomas D. Russell, Honeywell, Incorporated, TX [M] Jimmie J. Schexnayder, Entergy Corporation, LA [U] Franklin R. Switzer, Jr., S-afe, Incorporated, IN [SE] Joseph M. Vavrek, Sargent & Lundy, LLC, IL [SE] Michael A. Walz, Burns & McDonnell Engineering Company, MO [SE] Peter J. Willse, GE Insurance Solutions, CT [I] Henry K. Wong, Washington Group International, NJ [SE] Allan J. Zadiraka, The Babcock & Wilcox Company, OH [M] Alternates John E. Bollinger, The Babcock & Wilcox Company, OH [M] (Alt. to Allan J. Zadiraka) John C. deRuyter, The DuPont Company, Incorporated, DE [U] (Alt. to John J. Eibl) Ronald J. Fleming, ABB Incorporated, OH [M] (Alt. to Daniel J. Lee) Steven L. Hawkins, Black & Veatch Corporation, KS [SE] (Alt. to Kris A. Gamble) Kenneth Hurlburt, Babcock Power, Incorporated, MA [M] (Alt. to Francisco A. Palacios) Robert P. Kaltenbach, Burns & McDonnell Engineering Company, MO [SE] (Alt. to Michael A. Walz) Michael R. Mulherin, The Dow Chemical Company, TX [U] (Alt. to Gordon G. Gaetke)

NFPA 85

Gary E. Norman, ALSTOM Power Incorporated, CT [M] (Alt. to John P. O'Rourke) Mark A. Ratcliffe, Invensys Process Systems, TX [M] (Alt. to W. Scott Matz) Ronald Rispoli, Entergy Corporation, AR [U] (Alt. to Jimmie J. Schexnayder) Wesley J. Schulze, Coen Company, Incorporated, CA [M] (Alt. to Lalit M. Mehta) George P. Seroka, DTE Energy/Detroit Edison Company, MI [U] (Voting Alt. to DTE Energy Rep.) James M. Witt, Jr., Southern Company Services, Incorporated, AL [U] (Alt. to Dale P. Evely) Nonvoting S. Dharmalingam, Bharat Heavy Electricals Limited, India [M] Committee Scope: This Committee shall have primary responsibility for documents covering the reduction of combustion system hazards and the prevention of boiler furnace explosions and implosions in multiple burner boilers with a heat input rate of 2,500,000 Btu/hr and above. This includes all fuels. Report of the Committee on Pulverized Fuel Systems (BCS-PFS) Michael B. Doherty, Chair American Electric Power Service Corporation, OH [U] Courtney D. Alvey, Baltimore, MD [SE] David A. Cowdrick, Tampa Electric Company, FL [U] John C. deRuyter, The DuPont Company, Incorporated, DE [U] Rory G. Eastman, ALSTOM Power Incorporated, CT [M] Kenneth L. Gardner, Metso Industries, PA [M] Roderick J. Hossfeld, Jenike & Johanson, Incorporated, MA [SE] Walter E. Keiser, Georgia Power Company, GA [U] Kiran R. Patel, Babcock Power, Incorporated, MA [M] Jonathan R. Pranitis, Foster Wheeler Energy Corporation, NJ [M] Cleveland B. Skinker, Bechtel Power Corporation, MD [SE] William A. (Andy) Smith, Global Risk Consultants Corporation, GA [SE] Alternate Alan J. Seibert, ALSTOM Power Incorporated, CT [M] (Alt. to Rory G. Eastman) Committee Scope: This Committee shall have primary responsibility for documents on the operation and design requirements of pulverized fuel systems and reduction of hazards associated with those systems. This includes all carbonaceous solid fuels at any heat input rate. Report of the Committee on Single Burner Boilers (BCS-SBB) John J. Eibl, Chair The DuPont Company, TN [U] Courtney D. Alvey, Baltimore, MD [SE] Carlton A. Bosfield, Grand Bahama Power Company, FL [U] John T. Connor, Burns & McDonnell Engineering Company, MO [SE] Dale E. Dressel, Solutia Incorporated, MO [U] G. F. (Jerry) Gilman, SIS-Tech, OH [SE] Ted Jablkowski, North American Manufacturing Company, CT [M] Robert A. Koehler, Liberty Mutual Property, TX [I] Rep. Property Casualty Insurers Association of America Glenn A. Raney, Premier Consulting Services, TX [SE] Gary J. Shrider, Babcock & Wilcox Company, OH [M] Franklin R. Switzer, Jr., S-afe, Incorporated, IN [SE] Jacques Van Heijningen, Siemens Building Technologies, Incorporated, IL [M] J. A. "Red" Wagner, Fireye, NJ [M] Chris Wille, Coen Company, Incorporated, CA [M] Peter J. Willse, GE Insurance Solutions, CT [I] Committee Scope: This Committee shall have primary responsibility for documents on the reduction of combustion system hazards and the prevention of boiler furnace explosions in single burner boilers with a heat input rate of 2,500,000 Btu/hr and above. This includes all fuels.

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Report on Comments F2006 -- Copyright, NFPA

Report of the Committee on Stoker Operations (BCS-STO) John C. deRuyter, Chair The DuPont Company, Incorporated, DE [U] J. Mike Cantrell, The McBurney Corporation, GA [IM] Andrew K. Dant, Cogentrix Energy, Incorporated, NC [U] John Hoh, National Board of Boiler & Pressure Vessel Inspectors, OH [E] Staff Liaison: Amy B. Spencer Committee Scope: This Committee shall have primary responsibility for documents covering the operation of stokers and related fuel burning equipment. This includes all fuels at any heat input rate. These lists represent the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. The Report of the Technical Committee on Boiler Combustion System Hazards is presented for adoption. This Report on Comments was prepared by the individual Technical Committees and documents its action on the comments received on its Report on Proposals on NFPA 85, Boiler and Combustion Systems Hazards Code, 2004 edition, as published in the Report on Proposals for the 2006 November Meeting. The Reports were prepared by the: · Technical Correlating Committee on Boiler Combustion System Hazards (BCS-AAC) · Technical Committee on Fluidized Bed Boilers (BCS-FBB) · Technical Committee on Fundamentals of Combustion Systems Hazards (BCS-FUN) · Technical Committee on Heat Recovery Steam Generators (BCSHRS) · Technical Committee on Multiple Burner Boilers (BCS-MBB) · Technical Committee on Pulverized Fuel Systems (BCS-PFS) · Technical Committee on Single Burner Boilers (BCS-SBB) · Technical Committee on Stoker Operations (BCS-STO) This Report has been submitted to letter ballot of the individual Technical Committees. The results of the balloting, after circulation of any negative votes, can be found in the report. This Report has also been submitted to letter ballot of the Technical Correlating Committee on Boiler Combustion System Hazards, which consists of 4 voting members; of whom 2 voted affirmatively, negatively after circulation of negative ballots (Fringeli), and ballot was not returned (McCullion).

NFPA 85

Mr. Fringeli voted negatively stating: "There appears to be a direct conflict between the provisions of Comment 85-6a (Log #7) in the TCC ballot and ROC Comments 85-60 (Log #5), 85-66 (Log #54), 85-68 (Log #55), and 85-76 (log #5). · ROC Comment 85-6a states: Except as noted in 4.6.5.2.2 under no circumstances shall the airflow demand be less than the purge rate. · ROC Comments 85-60, 85-66, 85-68, and 85-76 set the mandatory master fuel trip at 5 percent below the minimum purge rate. Since the 960's the MFT had been set at 5 percent below the purge rate. Five percent below purge rate is consistent with the Fundamentals provision that airflow demand should not be less than purge rate (Comment 85-6a). Five percent below minimum purge can deviate significantly from this provision since the minimum purge rate can be well below the purge rate. This is a matter of correlation between Fundamentals and MBB. The above conflict also exists within MBB itself. Comments, 85-60, 85-66, and 85-68 conflict with subsections 6.6.5..5.7., 6.7.5..5.7, and 6.8.5..5.7 of ROP 85-8 (Log #70 BCS) respectively. This conflict, however, is not strictly a TCC issue. Although operating experience may support setting the MFT at 5 percent below the minimum purge rate, the proposed changes to NFPA 85 in this regard have introduced serious conflicts within the standard." This Report has also been submitted to a Supplemental letter ballot of the Technical Correlating Committee on Boiler Combustion System Hazards, which consists of 4 voting members; This Supplemental ballot consisted of Comment 85-56 (Log #57) of whom voted affirmatively, negatively after circulation of negative ballots (Willse), and ballots were not returned (Bostick, Malanga, and McCullion). Mr. Willse voted negatively stating: "The action taken the TCC on 85-56 is not in accordance with .4. of the Regulations Governing Committee Projects. A new set of criteria was added by the TCC which has not seen public review and is technical changes not resolving conflicts, or determining whether a committee (TC) has given due consideration to their actions." Mr.Dressel voted affirmative with the following comment: "I vote affirmative to the supplemental ballot. I concur that it was not the intent of the committee to make the requirements more stringent." Ms. Polosky voted affirmative with the following comment: "With the implementation of the supplemental ballot for new wording in 6.5... and leaving 6.5...2 as accepted in the ROP (85-8)."

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Report on Comments F2006 -- Copyright, NFPA

____________________________________________________________ 85- Log #6 BCS-FUN Final Action: Accept in Principle (3.3.3.5 Primary Air) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-7 Recommendation: The TCC wishes to make this a comment to the Fundamentals committee for their final approval since it is a definition. Substantiation: This is a direction from the Technical Correlating Committee on Boiler Combustion System Hazards in accordance with 4.2 and -4. of the Regulations Governing Committee Projects. Committee Meeting Action: Accept in Principle Revise text as follows:. ...5. Primary Air (for the purposes of equipment within the scope of Chapter 8 in an HRSG or other combustion turbine exhaust system) ..." ..57 "...can result in unburned fuels entering the HRSG enclosure or other combustion turbine exhaust systems. ..02 "...stack; in an HRSG or other combustion turbine exhaust system, a continuous path for movement of an airstream through the HRSG system or other combustion turbine exhaust systems. ..5. "...the appropriate portion of the HRSG enclosure or other combustion turbine exhaust systems for a number..." ..8. Emergency Shutdown (HRSG or other combustion turbine exhaust systems). ..6 "...for HRSGs...to the stack; for other combustion turbine exhaust systems, the combined spaces of the combustion turbine, and the associated ducts that convey the air and combustion gases from the air intake to the stack. Committee Statement: The committee agrees with the actions from ROP 85-7. However, ...5. was slightly modified because the parenthetical was closely related to the definition and could be confusing. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R.

NFPA 85

____________________________________________________________ 85-5 Log #2 BCS-FUN Final Action: Accept in Principle (3.3.46 Design Full Load Mass Airflow (New) ) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-22 Recommendation: The following shall be a public comment to be submitted to the Fundamentals, Multiple Burner Boiler and Fluidized Bed Boiler Committees. Insert the following new definition in ..., renumbering subsequent sections with a cross reference in ..46 as follows: "... Design Full Load Mass Airflow. The air flow required to achieve full load. For the purposes of Chapter 6, Multiple Burner Boilers it is the flow required to achieve full load based on the original design fuel as defined by the boiler equipment manufacturer." Substantiation: The TCC believes adding of the definition has merit, and it is placed as a subsection to "air" because it is the most likely location for users to look. Further consideration should be given to the comments expressed in voting, as the proposed solution appears to resolve the original concerns of the Fundamentals Committee regarding correlation. Committee Meeting Action: Accept in Principle Insert the following new definition in ..., renumbering subsequent sections with a cross reference in ..46 as follows: "... Design Full Load Mass Airflow. The air flow required to achieve nameplate full load. For the purposes of Chapter 6, Multiple Burner Boilers it is the flow required to achieve nameplate full load based on the original design fuel as defined by the boiler equipment manufacturer." Committee Statement: The word "nameplate" was added for clarification because boiler and HRSG ratings can be changed by design. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 ____________________________________________________________ Ballot Not Returned: 2 Cowdrick, D., Kleen, R. 85-2 Log #CC BCS-FUN Final Action: Accept ____________________________________________________________ (3.3.27 Bypass Stack) Final Action: Accept in Principle ____________________________________________________________ 85-6 Log # BCS-MBB (3.3.46 Design Full Load Mass Airflow (New) ) Submitter: Technical Committee on Fundamentals of Combustion ____________________________________________________________ Systems Hazards Submitter: Technical Correlating Committee on Boiler Combustion Comment on Proposal No: N/A System Hazards Recommendation: In the definition of Bypass Stack insert a space Comment on Proposal No: 85-22 between the "A" and "s" in the first word, "Astack". Change to read: A Recommendation: The following shall be a public comment to be stack submitted to the Fundamentals, Multiple Burner Boiler and Fluidized Bed Substantiation: Correction of a typo. Boiler Committees. Committee Meeting Action: Accept Insert the following new definition in ..., renumbering subsequent Number Eligible to Vote: 18 sections with a cross reference in ..46 as follows: Ballot Results: Affirmative: 6 "... Design Full Load Mass Airflow. The air flow required to Ballot Not Returned: 2 Cowdrick, D., Kleen, R. achieve full load. For the purposes of Chapter 6, Multiple Burner Boilers ____________________________________________________________ it is the flow required to achieve full load based on the original design fuel as defined by the boiler equipment manufacturer." 85- Log #8 BCS-FUN Final Action: Accept in Principle Substantiation: The TCC believes adding of the definition has merit, and (3.3.38 Combustion Turbine Exhaust Systems) ____________________________________________________________ it is placed as a subsection to "air" because it is the most likely location for users to look. Further consideration should be given to the comments Submitter: Technical Correlating Committee on Boiler Combustion expressed in voting, as the proposed solution appears to resolve the System Hazards original concerns of the Fundamentals Committee regarding correlation. Comment on Proposal No: 85-9 Committee Meeting Action: Accept in Principle Recommendation: The TCC voted to "Accept in Principle" on this. See committee action and statement in Comment 85-5 (Log #2). Substantiation: Use the language found in Proposal 85-2 (Log #CP600) Committee Statement: The Committee agrees with Fundamental's instead of the language in this Proposal 85-9 (Log #55). proposed definition in Comment 85-5 (Log #2). The Committee Committee Meeting Action: Accept in Principle highlights this for TCC discussion to ensure BCS-FBB agrees as well. See committee action on Comment 85-4 (Log #7). Number Eligible to Vote: 31 Committee Statement: See committee action on Comment 85-4 (Log Ballot Results: Affirmative: 0 #7). Ballot Not Returned: Seroka, G. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 ____________________________________________________________ Ballot Not Returned: 2 Cowdrick, D., Kleen, R. 85-7 Log #4 BCS-FBB Final Action: Accept in Principle ____________________________________________________________ (3.3.46 Design Full Load Mass Airflow (New) ) ____________________________________________________________ 85-4 Log #7 BCS-FUN Final Action: Accept Submitter: Technical Correlating Committee on Boiler Combustion (3.3.38 Combustion Turbine Exhaust Systems) ____________________________________________________________ System Hazards Comment on Proposal No: 85-22 Submitter: Michael C. Polagye, FM Global Recommendation: The following shall be a public comment to be Comment on Proposal No: 85-9 submitted to the Fundamentals, Multiple Burner Boiler and Fluidized Bed Recommendation: Revise the definition to read: Boiler Committees. 3.3.38 Combustion Turbine Exhaust Systems. All ductwork from the Insert the following new definition in ..., renumbering subsequent combustion turbine exhaust to the stack including any emission control sections with a cross reference in ..46 as follows: catalyst systems contained within the exhaust flow path. "... Design Full Load Mass Airflow. The air flow required to Substantiation: Per the proposal Substantiation, the word "catalyst" is not achieve full load. For the purposes of Chapter 6, Multiple Burner Boilers to be included in the definition. it is the flow required to achieve full load based on the original design fuel Committee Meeting Action: Accept as defined by the boiler equipment manufacturer." Number Eligible to Vote: 18

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Report on Comments F2006 -- Copyright, NFPA

Substantiation: The TCC believes adding of the definition has merit, and it is placed as a subsection to "air" because it is the most likely location for users to look. Further consideration should be given to the comments expressed in voting, as the proposed solution appears to resolve the original concerns of the Fundamentals Committee regarding correlation. Committee Meeting Action: Accept in Principle The TCCs intent was met. See committee action on Comment 85-5 (Log #2) and 85-6 (Log #). Committee Statement: The Committee agrees with Fundamental's proposed definition in Comment 85-5 (Log #2). The Committee highlights this for TCC discussion, noting this also agrees with BCSMBB's Comment 85-6 (Log #). Number Eligible to Vote: 11 Ballot Results: Affirmative: 9 Ballot Not Returned: 2 Chelian, P., Lueckenotte, D.

NFPA 85

Proof of Closure Switch. A device that provides feedback that a piece of equipment is in the closed position. For Chapter 5, Single Burner Boilers, when referring to safety shutoff valves, it is a non-field adjustable switch installed in a safety shutoff valve by its the valve manufacturer and that activates only after the valve is fully closed. Committee Statement: Editorial changes for clarity and to allow the generic proof of closure switch to apply to things other than safety shutoff valves in BCS-SBB applications. Although the committee accepted this comment in principle, they wished the TCC, BCS-SBB and BCSMBB to highlight a few issues for future consideration [see Comment 85-5 (Log #9).] For example, the term "non-field adjustable" might not be enforceable. It should be noted that a possible solution is two definitions (proof of closure switch general and one for BCS-SBB) to allow consistency with NFPA 86 (which is the same as BCS-SBB's submission). It was also questioned if a "requirement" was creeping into the definition. The BCS-SBB TC should review and make a comment for ____________________________________________________________ TCC consideration and resolution. 85-8 Log #8 BCS-FUN Final Action: Accept in Principle Number Eligible to Vote: 18 (3.3.46 Design Full Load Mass Airflow (New) ) Ballot Results: Affirmative: 6 ____________________________________________________________ Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Submitter: Michael C. Polagye, FM Global Comment on Proposal No: 85-22 ____________________________________________________________ Recommendation: Insert the following definition and renumber the 85- Log #6 BCS-FUN Final Action: Accept in Principle following sections, as required: (3.3.156 Proof of Closure Switch (New) ) 3.3.46 Design Full Load Mass Airflow. For Chapter 6, Multiple Burner ____________________________________________________________ Boilers: the flow required to achieve full load on the original design fuel Submitter: Technical Correlating Committee on Boiler Combustion as defined by the boiler original equipment manufacturer. System Hazards Substantiation: The term is used in Chapter 6 and the definition is needed Comment on Proposal No: 85-26 because as fuels change and design upgrades occur during the operating Recommendation: Submit a comment to BCS-MBB, BCS-FUN and life of the unit the quantity of air required at full load will change. This BCS-SBB to add a new definition as follows: definition establishes that as used in Chapter 6, the "design full load mass Proof of Closure Switch. A device that provides feedback that a piece of air flow" of interest is that which pertains to the original design fuel. equipment is in the closed position. For Chapter 5, Single Burner Boilers, Committee Meeting Action: Accept in Principle it is a non-field adjustable switch installed in a safety shutoff valve by its See committee action and statement on Comment on 85-5 (Log #2). manufacturer and that activates only after the valve is fully closed. Committee Statement: See committee action and statement on Comment Substantiation: The TCC action merges BCS-MBB Proposal 85-26 on 85-5 (Log #2). (Log #CP700) and BCS-SBB Proposal 85-20 (Log #CP40) that created Number Eligible to Vote: 18 different definitions for proof of closure switch. Ballot Results: Affirmative: 6 Committee Meeting Action: Accept in Principle Ballot Not Returned: 2 Cowdrick, D., Kleen, R. See committee action and statement on Comment 85-0 (Log #9). Committee Statement: See committee action and statement on Comment ____________________________________________________________ 85-0 (Log #9). 85-9 Log #5 BCS-FUN Final Action: Accept Number Eligible to Vote: 18 (3.3.69 Fresh Air Mode) Ballot Results: Affirmative: 6 ____________________________________________________________ Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Submitter: Technical Correlating Committee on Boiler Combustion System Hazards ____________________________________________________________ Comment on Proposal No: 85-24 85-2 Log #0 BCS-MBB Final Action: Accept in Principle Recommendation: The TCC notes that Proposal 85-25 (Log #CP20) (3.3.156 Proof of Closure Switch (New) ) was forwarded to BCS-HRS from the Fundamentals TC, and the BCS____________________________________________________________ HRS TC's final action is shown in this log. This proposal shall also be a Submitter: Technical Correlating Committee on Boiler Combustion comment from the TCC to the Fundamentals Committee for their final System Hazards approval since it is a definition. Comment on Proposal No: 85-20 Substantiation: This is a direction from the Technical Correlating Recommendation: Submit a comment to BCS-MBB, BCS-FUN and Committee on Boiler Combustion System Hazards in accordance with BCS-SBB to add a new definition as follows: 4.2 and -4. of the Regulations Governing Committee Projects. Proof of Closure Switch. A device that provides feedback that a piece of Committee Meeting Action: Accept equipment is in the closed position. For Chapter 5, Single Burner Boilers, Modify ..69 as follows: it is a non-field adjustable switch installed in a safety shutoff valve by its ..69 Fresh Air Firing. The operation of an HRSG with air instead of manufacturer and that activates only after the valve is fully closed. combustion turbine exhaust. Substantiation: The TCC action merges BCS-MBB Proposal 85-26 Committee Statement: The committee agreed with HRSG's proposed (Log #CP700) and BCS-SBB Proposal 85-20 (Log #CP40) that created Proposal 85-24 (Log #CP60). different definitions for proof of closure switch. Number Eligible to Vote: 18 Committee Meeting Action: Accept in Principle Ballot Results: Affirmative: 6 See committee action and statement on Comment 85-0 (Log #9). Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Committee Statement: The Committee agrees with Fundamental's proposed definition in Comment 85-0 (Log #9). The Committee ____________________________________________________________ highlights this for TCC discussion. 85-0 Log #9 BCS-FUN Final Action: Accept in Principle Number Eligible to Vote: 31 (3.3.156 Proof of Closure Switch (New) ) Ballot Results: Affirmative: 28 Negative: 2 ____________________________________________________________ Ballot Not Returned: Seroka, G. Submitter: Technical Correlating Committee on Boiler Combustion Explanation of Negative: System Hazards BASS, B.: This appears to be an issue for the BCS-SBB committee and Comment on Proposal No: 85-20 the Technical Correlating Committee. However, I must vote negative with Recommendation: Submit a comment to BCS-MBB, BCS-FUN and regard to this BCS-MBB comment. A valve with a non-field adjustable BCS-SBB to add a new definition as follows: proof of closure limit switch has never been an NFPA 85 (or any of its Proof of Closure Switch. A device that provides feedback that a piece of predecessors) requirement that I can determine. I have not seen nor heard equipment is in the closed position. For Chapter 5, Single Burner Boilers, any technical reason for such a requirement. Also, I do not believe there it is a non-field adjustable switch installed in a safety shutoff valve by its would be any technical reason for such a requirement on single burner manufacturer and that activates only after the valve is fully closed. boilers that would not apply to any other type boiler. The substantiation Substantiation: The TCC action merges BCS-MBB Proposal 85-26 stated in 85-20 (Log #CP40) that it is an NFPA 86, Standard for Ovens (Log #CP700) and BCS-SBB Proposal 85-20 (Log #CP40) that created and Furnaces definition is not a valid reason to suddenly include it as different definitions for proof of closure switch. a requirement in NFPA 85. It severely limits the sources of valves and Committee Meeting Action: Accept in Principle borders on requiring specific manufacturers. Modify the proposed language, number it as ..56.5, renumbering MATZ, W.: . I feel that this requirement in BCS-SBB is too restrictive. subsequent definitions as follows: It limits the choice of valve manufacturers.

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2. If BCS-SBB is going to put this tight of a restriction on suppliers of valves for single burner boilers, I feel the least they can do is to provide a list of acceptable valve manufacturers which could be taken as NFPA endorsement of a selected group manufacturer. . This type of restriction, to the best of my knowledge has never been used in NFPA 85.

NFPA 85

____________________________________________________________ 85-6 Log #CC2 BCS-FUN Final Action: Accept (3.3.156.2 Normal Shutdown, High Steam Temperature Switch) ____________________________________________________________ Submitter: Technical Committee on Fundamentals of Combustion Systems Hazards Comment on Proposal No: N/A ____________________________________________________________ Recommendation: Modify existing ..56.2 as follows: 85- Log # BCS-SBB Final Action: Accept in Principle ..56.2 Normal Shutdown, High Steam Water Temperature Switch. (3.3.156 Proof of Closure Switch (New) ) A temperature-actuated device that is arranged to effect a normal burner ____________________________________________________________ shutdown when the water temperature exceeds a preset temperature. Submitter: Technical Correlating Committee on Boiler Combustion Substantiation: Correction of a typo. System Hazards Committee Meeting Action: Accept Comment on Proposal No: 85-20 Number Eligible to Vote: 18 Recommendation: Submit a comment to BCS-MBB, BCS-FUN and Ballot Results: Affirmative: 6 BCS-SBB to add a new definition as follows: Proof of Closure Switch. A Ballot Not Returned: 2 Cowdrick, D., Kleen, R. device that provides feedback that a piece of equipment is in the closed position. For Chapter 5, Single Burner Boilers, it is a non-field adjustable ____________________________________________________________ switch installed in a safety shutoff valve by its manufacturer and that 85-7 Log #9 BCS-FUN Final Action: Accept in Principle activates only after the valve is fully closed. (4.2) Substantiation: The TCC action merges BCS-MBB Proposal 85-26 ____________________________________________________________ (Log #CP700) and BCS-SBB Proposal 85-20 (Log #CP40) that created Submitter: Technical Correlating Committee on Boiler Combustion different definitions for proof of closure switch. System Hazards Committee Meeting Action: Accept in Principle Comment on Proposal No: 85-0 See committee action and statement on Comment 85-0 (Log #9). Recommendation: Submit a comment to Fundamentals as follows: Committee Statement: The Committee agrees with Fundamental's The TCC agrees with the action to delete Section 4.2, and suggests proposed definition in Comment 85-0 (Log #9). The Committee noted Fundamentals takes the material from the existing Section 4.7, and that there is a request for clarification on this definition to the NFPA 86 inserts it into a new Section 4.2 and renames the section "Installation and TC, which could further modify this definition. The Committee highlights Commissioning". this for TCC discussion. Substantiation: From an "ease of cross reference" perspective, this Number Eligible to Vote: 15 organization of sections is preferred. Additionally the TCC believes that Ballot Results: Affirmative: 5 having a section title is important to this chapter. Committee Meeting Action: Accept in Principle ____________________________________________________________ See committee action on Comment 85-8 (Log #44). 85-4 Log #8 BCS-SBB Final Action: Accept in Principle Committee Statement: See committee action on Comment 85-8 (Log (3.3.156 Proof of Closure Switch (New) ) #44). ____________________________________________________________ Number Eligible to Vote: 18 Submitter: Technical Correlating Committee on Boiler Combustion Ballot Results: Affirmative: 6 System Hazards Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Comment on Proposal No: 85-26 Recommendation: Submit a comment to BCS-MBB, BCS-FUN and ____________________________________________________________ BCS-SBB to add a new definition as follows: 85-8 Log # BCS-FUN Final Action: Accept in Principle Proof of Closure Switch. A device that provides feedback that a piece of (4.4.1.3) equipment is in the closed position. For Chapter 5, Single Burner Boilers, ____________________________________________________________ it is a non-field adjustable switch installed in a safety shutoff valve by its TCC Action: Change the word "specific" to "specified" to correct a manufacturer and that activates only after the valve is fully closed. typo. "Specified" is the term used in the 2004 edition and no proposal Substantiation: The TCC action merges BCS-MBB Proposal 85-26 or comment was made to change it. (Log #CP700) and BCS-SBB Proposal 85-20 (Log #CP40) that created Submitter: Ted Jablkowski, North American Mfg. Co., Ltd. different definitions for proof of closure switch. Comment on Proposal No: 85-58 Committee Meeting Action: Accept in Principle Recommendation: Revise text to read: See committee action and statement on Comment 85- (Log #) and 4.4.. Operation, set points, and adjustments shall be verified by testing 85-0 (Log #9) at specific intervals, and the results shall be documented. When a system Committee Statement: See committee action and statement on BCS-SBB includes a "built in" test mechanism that bypasses any safety device, it Comment 85- (Log #), where the Fundamentals proposed definition shall be interlocked to prevent operation of the system while the device is in BCS-FUN Comment 85-0 (Log #9) was accepted. in the test mode, unless listed for that purpose. Number Eligible to Vote: 15 Substantiation: The substantiation for the committee's action to Reject Ballot Results: Affirmative: 5 Proposal 85-58 (Log #80) BCS-SBB regarding 5..6. indicated that "5..6 does not pertain to the periodic testing of safety interlocks". ____________________________________________________________ This substantiation, therefore, supports the relocation of the previously 85-5 Log #9 BCS-FUN Final Action: Accept in Principle proposed requirement to the section of NFPA 85 that covers periodic (3.3.156 Proof of Closure Switch (New) ) testing. ____________________________________________________________ Committee Meeting Action: Accept in Principle Submitter: Michael C. Polagye, FM Global Insert a new A.4.4.. as follows: Comment on Proposal No: 85-20 4.4..* Operation, set points, and adjustments shall be verified by Recommendation: Revise ..56 from Proposal 85-20 as follows and testing at specific intervals, and the results shall be documented. renumber subsequent sections accordingly: A.4.4.. When a system includes a "built in" test mechanism that 3.3.156.5 Proof of Closure Switch. Non-field adjustable A switch bypasses any safety device, it should be interlocked to prevent operation installed in a safety shutoff valve by its manufacturer that activates only of the system while the device is in the test mode, unless operation after the valve is fully closed. procedures specifically address this device or they are listed for that Substantiation: The term "non-field adjustable" is appropriate for NFPA purpose. 86, but not NFPA 85, which encompasses boilers that use larger SSOVs Committee Statement: The material was moved to be advisory because than those used in ovens and furnaces. Also editorially, a paragraph there were no data presented to necessitate the mandatory requirement, number has been added to the definition. (The paragraph number, which could be costly. It was modified editorially for clarity. ...5.6, as shown in the ROP for Proposal 85-20 Log #CP40 is Number Eligible to Vote: 18 incorrect.) Ballot Results: Affirmative: 6 Committee Meeting Action: Accept in Principle Ballot Not Returned: 2 Cowdrick, D., Kleen, R. See committee action and statement on Comment 85-0 (Log #9). Committee Statement: See committee action and statement on Comment 85-0 (Log #9). Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R.

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____________________________________________________________ 85-9 Log #40 BCS-FUN Final Action: Accept in Principle (4.4.1.6) ____________________________________________________________ TCC Action: The word "original" was deleted from the BCS-FUN Comment because it could create confusion. It could be misinterpreted to mean the original design criteria instead of subsequent design upgrades. Modify 4.4.1.6 from the 2004 edition as follows: 4.4.1.6 System operation shall be tested and verified for compliance with this code the design criteria whenever a controller is replaced, repaired, reprogrammed or updated before returning it to service. Submitter: Michael C. Polagye, FM Global Comment on Proposal No: 85- Recommendation: Revise text to read: 4.4.1.6 Whenever a controller is replaced, repaired, or updated, intended system operation shall be verified by test before returning it to service. for compliance with this code whenever a controller is replaced, repaired, or updated. Substantiation: While Sections . and .4 of NFPA 85 address the broad subjects of application and retroactivity of the Code, the submitter of the proposal has made a valid observation about the existing text in 4.4.6 implying retroactive compliance is required as a result of maintenance or repair. The revised text submitted in this comment addresses this concern while maintaining the intent of the paragraph. Committee Meeting Action: Accept in Principle Revise text to read: 4.4.1.6 System operation shall be tested and verified for compliance with the original design criteria whenever a controller is replaced, repaired, reprogrammed or updated before returning it to service. Committee Statement: The intent of the submitter was met. Language from NFPA 86, Section 7... was used as a model for the new text. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. ____________________________________________________________ 85-20 Log #68 BCS-FUN Final Action: Accept in Principle (4.4.1.6.1 and 4.4.1.6.2 (New) ) ____________________________________________________________ Submitter: Harold R. Yates, HRY, Inc. Comment on Proposal No: 85- Recommendation: Revise text to read: 4.4..6. System operation shall be verified for compliance with this code whenever a controller is reprogrammed, replaced, repaired or updated. 4.4..6.2 A commissioning test (see Section 4.7) verifying system operation shall be required whenever a controller is replaced reprogrammed, repaired, or updated. Substantiation: This proposal was rejected by Committee as "The concern being addressed is already covered by Section . and .4 of the current code." These sections refer to "...new installations and major alterations...", and "...judgment of AHJ...". Replacement of a controller may not be considered a major alteration, not be under scrutiny of the AHJ. Further consideration should be given to accepting this proposal. Committee Meeting Action: Accept in Principle See committee statement on Comment 85-9 (Log #40). Committee Statement: See committee statement on Comment 85-9 (Log #40). Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R.

NFPA 85

requirement. This comment deletes the use of these two terms and restores the use of "minimize" as it appears in the 2004 edition of this Code. Other "editorial" changes are made to enhance readability. Committee Meeting Action: Accept Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. ____________________________________________________________ 85-22 Log #4 BCS-FUN Final Action: Accept (Table 4.6.2.4.2) ____________________________________________________________ Submitter: Henry K. Wong, Washington Group International Comment on Proposal No: 85-6 Recommendation: For further clarification the following revised Table 4.6.2.4.2 is recommended: Table 4.6.2.4.2 Minimum Vent Line Size NPS (in.) DN (mm) ¾ 20 25 ¼ 2 ½ 40 2 50 2½ 65 80 ½ 90 Vent internal cross-sectional area 5 percent of the fuel line internal crosssectional area

Fuel Line Size NPS (in.) DN (mm) ½ 40 2 50 65 to 80 2 ½ to 90 ½ 4 to 5 00 to 25 6 50 7 75 8 200 >8 >200

Substantiation: Table is easier to read with English and Metric values separated. Provided more clarification for the vent sizing of fuel piping greater than 8 in. Committee Meeting Action: Accept Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R.

____________________________________________________________ 85-2 Log #6 BCS-FUN Final Action: Accept in Principle (4.6.3.2.4 and 4.6.3.2.9) ____________________________________________________________ Submitter: Thomas B. George, Marsh USA Inc. Comment on Proposal No: 85-49 Recommendation: Revise text to read as follows: 4.6..2.4* Design. The design of the logic system for burner management shall include and accommodate the following requirements: () Diagnostics shall be included in the design to monitor processor logic function. (2) Logic system failure shall not preclude proper operator intervention. () Logic shall be protected from unauthorized changes. (4) Logic shall not be changed while the associated equipment is in operation. (5) System response time (throughout) shall be short to prevent negative effects on the application. ____________________________________________________________ (6) Protection from the effects of noise shall prevent false operation. 85-2 Log #4 BCS-FUN Final Action: Accept (7) No single component failure within the logic system shall prevent a (4.6.2.3.2.2(B)) mandatory master fuel trip. ____________________________________________________________ (8) The operator shall be provided with a dedicated manual switch(es) Submitter: Michael C. Polagye, FM Global that shall actuate the master fuel trip relay independently and directly. Comment on Proposal No: 85-4 (9) At least one manual switch referenced in 4.6..2.4(8) shall be Recommendation: Revise text to read: identified and located remotely where it can be reached in case of (B)* The arrangement of air inlets, ductwork, and air preheaters shall be emergency. designed to minimize prevent hazardous contamination of the air supply (0)* The logic system shall be monitored for failure. by such materials as flue gas, water, fuels(s), and other materials feed () Failure of the logic system shall require a fuel trip for all equipment stocks from as a result of either intentional or accidental discharges. supervised by the failed logic system. Substantiation: The submitter of the proposal makes reference to the 4.6..2.9 Programmable Logic Controllers. Skikda explosion in the substantiation, implying the boiler air inlets, 4.6..2.9. Programmable logic controllers, if used, shall be monitored ductwork, and air preheaters could have been designed in a way that by external watch dog timers. would have prevented the explosion. This is an implication that cannot 4.6..2.9.2 If a watch dog timer trips, a master fuel trip for boilers or a be proved at that facility nor any other where combustible materials, duct burner trip for HRSGs shall then occur. including fuels, are handled. The requirement to "prevent" contamination A.4.6..2.4 Logic systems include Programmable Logic Controllers is not practically achievable or enforceable when broadened to include (PLCs), Digital Processing Units (DPUs), Distributed Control Systems accidental discharges from ruptures and leaks. Also, the word "hazardous" (DCSs), etc. has many connotations and does not add to the understanding of the A.4.6..2.4(0) External watchdog timers are a means to implement monitoring of the logic system for failure.

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Substantiation: The Fundamentals of Combustion System Hazards Technical Committee formed a task group to address two proposals to revise 4.6..2.9. Upon review of the paragraphs, it became clear that the existing language focused on providing external watchdog timers for PLC's. This approach does not provide guidance for other types of logic systems including logic solvers, logic controllers, etc. There are also other technologies available for logic systems that can provide equivalent or better protection than that afforded by external watchdog timers. Accordingly, revised functional criteria for paragraph 4.6..2.4 and the elimination of 4.6..2.9 are proposed in this comment. This comment substantiation should be referred to for both BSC-FUN Proposal 85-49 (Log #) and BCS-FUN Proposal 85-50 (Log #48). Committee Meeting Action: Accept in Principle Complete the proposed changes and modify the proposed as follows: A.4.6..2.4(0) External Watch-dog timers, as defined in ..65 are one of the possible means to implement monitoring of the logic system for failure. Committee Statement: The annex material was changed to make reference to the defined term. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. ____________________________________________________________ 85-24 Log #CC2 BCS-MBB Final Action: Reject (4.6.3.2.4(10)) ____________________________________________________________ TCC Action: The use of watchdog timers is addressed adequately in the Annex. There is nothing in the body of the code prohibiting the use of external watchdog timers. The action in BCS-FUN Comment 85-23 (Log #36) will stand. Submitter: Technical Committee on Multiple Burner Boilers Comment on Proposal No: 85-49 Recommendation: Modify Proposed 4.6..2.4(0) [in BCS-FUN Comment 85-2 (Log #6)] to complete all the BCS-FUN Committee Meeting actions in 85-2 (Log #6), with the following modification: (0)* The logic system shall be monitored for failure. A watchdog timer shall be permitted to be used as one means of monitoring for this failure. Substantiation: To this point, a watchdog timer is the most common way to monitor logic system failure in BCS-MBBs. This is highlighted for TCC correlation with BCS-FUN Comment 85-2 (Log #6). Committee Meeting Action: Accept Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. ____________________________________________________________ 85-25 Log #CC4 BCS-FBB Final Action: Reject (4.6.3.2.4(10)) ____________________________________________________________ TCC Action: The use of watchdog timers is addressed adequately in the Annex. There is nothing in the body of the code prohibiting the use of external watchdog timers. The action in BCS-FUN Comment 85-23 (Log #36) will stand. Submitter: Technical Committee on Fluidized Bed Boilers Comment on Proposal No: 85-49 Recommendation: Modify Proposed 4.6..2.4(0) [in BCS-FUN Comment 85-2 (Log #6)] to complete all the BCS-FUN Committee Meeting actions in 85-2 (Log #6), with the following modification, agreeing with BCS-MBB Committee Comment 85-24 (Log #CC2): (0)* The logic system shall be monitored for failure. A watchdog timer shall be permitted to be used as one means of monitoring for this failure. Substantiation: To this point, a watchdog timer is the most common way to monitor logic system failures. This is highlighted for TCC correlation with BCS-FUN Comment 85-2 (Log #6) (with comments from HRSG and BCS-SBB agreeing with BCS-FUN actions) and BCS-MBB Committee Comment 85-24 (Log #CC2). Committee Meeting Action: Accept Number Eligible to Vote: 11 Ballot Results: Affirmative: 9 Ballot Not Returned: 2 Chelian, P., Lueckenotte, D. ____________________________________________________________ 85-26 Log #5 BCS-FUN Final Action: Hold (4.6.3.2.5) ____________________________________________________________ TCC Action: See Technical Correlating Committee action on Comment 85-27a (Log #70). Except for the material modified in Technical Correlating Committee Comment 85-27a (Log #70), the material provided in Comment 85-26 (Log #35) is potentially controversial, and has not had the benefit of public review. This comment is therefore held for further study. Submitter: Thomas B. George, Marsh USA Inc. Comment on Proposal No: 85-8 Recommendation: Revise text to read as follows: 4.6..2.5 Requirement for Independence. (A) The burner management system shall be provided with independent logic, independent input/output systems, and independent power supplies

NFPA 85

and shall be a functionally and physically separate device from other logic systems, such as the boiler or HRSG control system. The Burner Management System shall meet the requirements of Failure Effects (4.6..2.) and Design (4.6..2.4). (B) For single burner boilers, boiler control systems shall be permitted to be combined with the burner management system only if the fuel/air ratio is controlled externally from the boiler control system (e.g., locked fuel/air ratio with mechanical positioning type system). An individual Master Fuel Trip shall be provided for each boiler or HRSG. (C) The burner management safety functions shall include, but shall not be limited to, purge interlocks and timing, mandatory safety shutdowns, trial timing for ignition, and flame monitoring. All mandatory fuel trip signals shall be hardwired so as to not rely on digital communication paths. (D) The logic system shall be limited to one steam generator. Burner Management input/output system for individual boiler or HRSG shall be partitioned in separate input/output cards from any other logic system. (E) The same hardware type used for burner management systems shall be permitted to be used for other logic systems. If the Burner Management System for an individual boiler or HRSG is integrated with other control systems for the same boiler or HRSG the following requirements shall be satisfied: . Requirements of 4.6..2.5(a) through (d) shall be satisfied. 2. Requirements for operability (i.e., control, status, and alarms) shall not interfere with or compromise the Burner Management System. . Requirement for communication with other control system and operator interface shall not interfere with or compromise the Burner Management System. 4. Failure of signal communications shall be detectable and logic shall be made fail-safe. 5. Requirement for integrated system power shall be permitted provided that the Burner Management System is designed for fail-safe shutdown on loss of power without operator intervention. 6. Requirement for common configurations tool shall be permitted provided that security access is provided to the Burner Management System and that requirements of 4.6..2.4() and 4.6..2.4(4) are satisfied. (F) Data highway communications between the burner management system and other systems shall be permitted. If the Burner Management System is combined with other boiler or HRSG control systems or other Burner Management System in the same logic system device the following requirements shall be satisfied: . Requirements of 4.6..2.5(a) through (e) shall be satisfied. 2. Requirement for functional separation of the Burner Management System from the other control system or other Burner Management System to the extent that the functional integrity of the Burner Management System is not compromised. (G) Signals that initiate mandatory master fuel trips shall be hard wired. For single burner boilers, boiler control systems shall be permitted to be combined with the burner management system under one of the following conditions: .* If the fuel/air ratio is controlled externally from the boiler control system. 2. If the combined boiler control system and burner management system is specifically listed or labeled for the application. A.4.6..2.5(G) An independent fuel/air ratio control can consist of a mechanical positioning-type, pressure balance ratio control or similar system. The above legislative text addresses the following proposals: Proposal Log Chapter ROP Task Group Committee Action Recommended Action 85-8 #2 BCS-FUN Accept in Principle Reject 85-9 #60 BCS-FUN Reject Accept in Principle 85-40 #9a BCS-FUN Reject Accept in Principle 85-4 #a BCS-FUN Reject Accept in Principle 85-42 #b BCS-FUN Reject Accept in Principle 85-4 #9b BCS-SBB Reject Accept in Principle 85-44 #6a BCS-FUN Reject Accept in Principle 85-45 #6b BCS-SBB Reject Accept in Principle 85-47 #4 BCS-FUN Reject Accept in Principle 85-48 #8 BCS-FUN Reject Accept in Principle 85-5 #2 BCS-FUN Accept Reject Proposal 85-46 is to alter the label "steam generator" to "boiler or HRSG" and does not address the issue of independency. The legislative language below has been altered to incorporate the change proposed and accepted in the ROP stage by the BCS-FUN. 85-46 #CP20 BCS-FUN Accept Accept Substantiation: The Fundamentals of Combustion System Hazards Technical Committee formed a task group to address a number of proposals to revise 4.6..2.5, all of which addressed the issue of Burner Management System independence. The existing language for 4.6..2.5 used the methodology of independence to provide reliability. This approach, however, does not guarantee that the designed system is reliable, nor does it allow for new technologies and design approaches. The proposed language in this comment provides criteria for the competent designer to provide systems meeting the functional requirements of the code.

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This comment and substantiation should be referred to for all of the following proposals: Proposal Log Chapter ROP Task Group Committee Action Recommended Action 85-8 #2 BCS-FUN Accept in Principle Reject 85-9 #60 BCS-FUN Reject Accept in Principle 85-40 #9a BCS-FUN Reject Accept in Principle 85-4 #a BCS-FUN Reject Accept in Principle 85-42 #b BCS-FUN Reject Accept in Principle 85-4 #9b BCS-SBB Reject Accept in Principle 85-44 #6a BCS-FUN Reject Accept in Principle 85-45 #6b BCS-SBB Reject Accept in Principle 85-47 #4 BCS-FUN Reject Accept in Principle 85-48 #8 BCS-FUN Reject Accept in Principle 85-5 #2 BCS-FUN Accept Reject Committee Meeting Action: Accept in Principle Make the changes in the comment with changes as follows in (C) and (E): (C)* The burner management safety functions shall include, but shall not be limited to, purge interlocks and timing, mandatory safety shutdowns, trial timing for ignition, and flame monitoring. All mandatory fuel trip signals shall be hardwired so as to not rely on non-deterministic digital communication paths. (E) The same hardware type used for burner management systems shall be permitted to be used for other logic systems. If the Burner Management System for an individual boiler or HRSG is integrated with other control systems for the same boiler or HRSG the following requirements shall be satisfied: . Requirements of 4.6..2.5(a) through (d) shall be satisfied. 2. Requirements for operability Functions of other control systems (i.e., control, status, and alarms) shall not interfere with or compromise the Burner Management System. . Requirement for Communication with other control systems and operator interface shall not interfere with or compromise the Burner Management System. 4. Failure of signal communications shall be detectable and logic shall be made fail-safe. 5. Requirement for Integrated system power shall be permitted provided that the Burner Management System is designed for fail-safe shutdown on loss of power without operator intervention. 6. Requirement for Common configurations tool shall be permitted provided that security access is provided to the Burner Management System and that requirements of 4.6..2.4() and 4.6..2.4(4) are satisfied. (F) Data highway communications between the burner management system and other systems shall be permitted. If the Burner Management System is combined with other boiler or HRSG Burner Management Systems or other control systems in the same logic system device, the following requirements shall be satisfied: . Requirements of 4.6..2.5(a) through (e) shall be satisfied. 2. Requirement for Functional separation of the individual Burner Management Systems from the other Burner Management Systems or other control systems or is required to the extent that the functional integrity of each the Burner Management System is not compromised. Additionally, add new Annex material to (C) as follows: A.4.6..2.5(C) This section does not require direct wiring of inputs to Master Fuel Trip Relays or other devices directly initiating a Master Fuel Trip. Committee Statement: "Non-deterministic" was added to (C) due to a concern that digital paths would also include I/O communication with the logic solver and this was not intended by the task group. The word "digital" was removed to allow multiple communication types. The term "requirements for..." was deleted to clarify that it was not referring to requirements elsewhere in NFPA 85. Other editorial changes for clarity and advisory material for user-friendliness. Number Eligible to Vote: 18 Ballot Results: Affirmative: 5 Negative: Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Explanation of Negative: PALACIOS, F.: I have voted negative both on the ballot as well as during the Committee meeting basically because I do not believe that removing the requirement for independence of the BMS from other controls results in an overall improvement in safety and is not granted for the sake of decreasing cost only. Each of the individual controls, BMS and boiler control could benefit from selective state of the art increase in reliability and self monitoring but there will always be an inherent higher level in overall safety by independent controls checking each other at all times. Comment on Affirmative: EVELY, D.: At the end of the BCS-FUN Technical Committee ROC meeting in March of 2006 I was satisfied with the action of that committee on this ROC item. After participating in the BCS-MBB and BCS-HRS Technical Committee discussions later in the month, however, I became concerned that this material might be too controversial to implement as is

NFPA 85

in the next edition without having the benefit of suitable public comment. I am therefore recommending to the Technical Correlating Committee that they consider holding this material over for the next revision cycle. ____________________________________________________________ 85-27 Log #CC BCS-HRS Final Action: Accept in Principle (4.6.3.2.5) ____________________________________________________________ TCC Action: See Technical Correlating Committee action on Comment 85-27a (Log #70) which meets the intent of this comment. BCS-FUN Comment 85-26 (Log #35) was held by the TCC for further revision. Submitter: Technical Committee on Heat Recovery Steam Generators, Comment on Proposal No: 85-8 Recommendation: Revise text to read as follows: 4.6..2.5 Requirement for Independence. (A) The burner management system shall be provided with independent logic, independent input/output systems, and independent power supplies and shall be a functionally and physically separate device from other logic systems, such as the boiler or HRSG control system. The Burner Management System shall meet the requirements of Failure Effects (4.6..2.) and Design (4.6..2.4). (B) An individual Master Fuel Trip shall be provided for each boiler or HRSG. (C)* All mandatory fuel trip signals shall be hardwired so as to not rely on non-deterministic communication paths. (D) The logic system shall be limited to one steam generator boiler or HRSG. (E) The same hardware type used for burner management systems shall be permitted to be used for other logic systems. (F) Data highway communications between the burner management system and other systems shall be permitted. (G) For single burner boilers, boiler control systems shall be permitted to be combined with the burner management system under one of the following conditions: .* If the fuel/air ratio is controlled externally from the boiler control system. 2. If the combined boiler control system and burner management system is specifically listed or labeled for the application. A.4.6..2.5(C)* This section does not require direct wiring of inputs to Master Fuel Trip Relays or other devices directly initiating a Master Fuel Trip. A.4.6..2.5(G) An independent fuel/air ratio control can consist of a mechanical positioning-type, pressure balance ratio control or similar system. Substantiation: This comment, BCS-MBB Comment 85-29 (Log #CC0), BCS-SBB Comment 85-28 (Log #CC20) and BCS-FUN Comment 85-26 (Log #5) should be highlighted for TCC discussion and correlation. The HRSG TC prefers to retain the original 2004 edition wording in 4.6..2.5(A) because independence ensures that the safety system is not compromised and is a very small economic impact for requiring the independence, in addition to the BCS-FUN modification for (A). Sections (B), (C) and (G) will be as endorsed or modified by BCS-FUN. In (D), the suggested changes have been negated by the return of the original 2004 text for (A). It was suggested to return (D) to the 2004 language, with one modification, changing "steam generators" to "boilers and HRSG" to be consistent with the rest of the document. The 2004 edition of Sections (E) and (F) will be maintained as is, and (G) will be as BCS-FUN endorsed. Definitions of hardwired and nondeterministic are needed, which would then render the proposed BCS-FUN A.4.6..2.5(C) unnecessary. Although changes have been suggested, the committee doesn't believe that this material has had adequate public review and should be held for the next revision or could be material for a future TIA. Committee Meeting Action: Accept Number Eligible to Vote: 17 Ballot Results: Affirmative: 6 Ballot Not Returned: Lefton, S. ____________________________________________________________ 85-27a Log #70 BCS-AAC Final Action: Accept (4.6.3.2.5) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-8 Recommendation: Revise text to read: 4.6..2.5 Requirement for Independence. (A) The burner management system shall be provided with independent logic, independent logic solving hardware, independent input/output systems, and independent power supplies and shall be a functionally and physically separate device from other logic systems, such as the boiler or HRSG control system.

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(B) For single burner boilers, boiler control systems shall be permitted to be combined with the burner management system only if the fuel/air ratio is controlled externally from the boiler control system (e.g., locked fuel/air ratio with mechanical positioning-type system). For single burner boilers, boiler control systems shall be permitted to be combined with the burner management system under one of the following conditions: .* If the fuel/air ratio is controlled externally from the boiler control system. 2. If the combined boiler control system and burner management system is specifically listed or labeled for the application. A.4.6..2.5(B) An independent fuel/air ratio control can consist of a mechanical positioning-type, pressure balance ratio control or similar system. (C) The burner management safety functions shall include, but shall not be limited to, purge interlocks and timing, mandatory safety shutdowns, trial timing for ignition, and flame monitoring. (D) The logic system shall be limited to one steam generator boiler or HRSG. (E) The same hardware type used for burner management systems shall be permitted to be used for other logic systems. (F) Data highway communications between the burner management system and other systems shall be permitted. (G) Signals that initiate mandatory master fuel trips shall be hard wired. Substantiation: In view of Comment 85-26 (Log #5), there were items that had not had the benefit of public review, and were therefore held for further revision. The changes to (B) reflect the relatively noncontroversial changes from Comment 85-26 (Log #5). The remaining changes in this TCC comment reflect the ROP actions to ROP 85-8 (Log #2), ROP 855 (Log #2) and ROP 85-46 (Log #CP20). Committee Meeting Action: Accept [The TCC ballot results were 14 voting members; of whom 13 voted affirmatively and 1 ballot was not returned (McCullion).]

NFPA 85

. Modify BCS-FUN Comment 85-26 (Log #5) to modify 4.6..2.5(E) to insert a "7." as follows: 7. For Multiple Burner Boilers the logic solvers for the Burner Management System shall be independent from other logic solvers. Substantiation: This comment, BCS-SBB Comment 85-28 (Log #CC20) and BCS-FUN Comment 85-26 (Log #5) should be highlighted for TCC discussion and correlation. The addition of "E7" was to ensure that the common functions are allowed to be integrated but not the logic solvers. BCS-MBB is unique because the units are more complex and have more potential for unsafe operation (with additional blocks). Committee Meeting Action: Accept Number Eligible to Vote: 31 Ballot Results: Affirmative: 29 Negative: Ballot Not Returned: Seroka, G. Explanation of Negative: RUSSELL, T.: I voted negative on this issue based on the requirement of having independent logic solvers for the BMS on MBB. I believe that as digital processors gain in capability that there is no reason not to fully utilize that capability. I do believe there should be some constraints on how the logic is implemented.

____________________________________________________________ 85-0 Log #CC BCS-FBB Final Action: Accept in Principle (4.6.3.2.5(E)7) ____________________________________________________________ TCC Action: See Technical Correlating Committee action on Comment 85-27a (Log #70) which meets the intent of this comment. BCS-FUN Comment 85-26 (Log #35) was held by the TCC for further revision. Submitter: Technical Committee on Fluidized Bed Boilers Comment on Proposal No: 85-8 Recommendation: Modify BCS-FUN Comment 85-26 (Log #5) committee meeting action to make the suggested changes, but with the following modifications. ____________________________________________________________ . Modify BCS-FUN Comment 85-26 (Log #5) to modify 4.6..2.5(E) 85-28 Log #CC20 BCS-SBB Final Action: Accept in Principle to insert a "7." as follows: (4.6.3.2.5(C)) 7. For multiple burner boilers and Fluidized Bed Boilers the logic ____________________________________________________________ solvers for the Burner Management System shall be independent from TCC Action: See Technical Correlating Committee action on other logic solvers. Comment 85-27a (Log #70) which meets the intent of this comment. Substantiation: This comment, BCS-MBB Committee Comment 85-29 BCS-FUN Comment 85-26 (Log #35) was held by the TCC for further (Log #CC0), BCS-SBB Committee Comment 85-28 (Log #CC20) and revision. BCS-FUN Comment 85-26 (Log #5) should be highlighted for TCC Submitter: Technical Committee on Single Burner Boilers, discussion and correlation. The addition of "E7" was to ensure that the Comment on Proposal No: 85-8 common functions are allowed to be integrated but not the logic solvers. Recommendation: . Modify BCS-FUN Comment 85-26 (Log #5) BCS-MBB and BCS-FBB are unique because the units are more complex committee meeting action to make the suggested changes, but with the and have more potential for unsafe operation (with additional blocks). following modifications. Modify BCS-FUN Comment 85-26 (Log #5) to Committee Meeting Action: Accept modify 4.6..2.5(C) and delete A.4.6..2.5(C) as follows: Number Eligible to Vote: 11 (C) All mandatory fuel trip signals shall be hardwired so as to not rely Ballot Results: Affirmative: 9 on non-deterministic -digital communication paths. Ballot Not Returned: 2 Chelian, P., Lueckenotte, D. A.4.6..2.5(C) This section does not require direct wiring of inputs to Master Fuel Trip Relays or other devices directly initiating a Master Fuel ____________________________________________________________ Trip. 85- Log #20 BCS-FUN Final Action: Accept in Principle 2. If the above comment is not accepted, an alternate suggestion is to (4.6.3.2.9, 4.6.3.2.9.1, and 4.6.3.2.9.2) add a new (G) as follows: ____________________________________________________________ (G). All mandatory fuel trip signals shall be hardwired. Submitter: Technical Correlating Committee on Boiler Combustion Substantiation: The last part of the sentence is a clarification and System Hazards is not necessary. Additionally, there is confusion about what is "non Comment on Proposal No: 85-49 deterministic" and the Annex conflicts with the body as it does not require Recommendation: Submit a comment to Fundamentals as follows: direct wiring of inputs to the master fuel trip and conflicts with ..92, the Consider changing "controllers" to "systems" throughout the modified definition of a Hard Wired System. It is this TCs understanding that the section, as noted in TCC action for Proposal 85-50 (Log #48). purpose of the hard wired interlock is to allow the operation of the MFT Substantiation: This is a direction from the Technical Correlating should there be a failure of the logic system. Additionally, the deleted Committee on Boiler Combustion System Hazards in accordance with material contained an oversight; analog system were not addressed and the 4.2 and -4. of the Regulations Governing Committee Projects. modified section addresses analog systems. This comment and BCS-FUN Committee Meeting Action: Accept in Principle Comment 85-26 (Log #5) should be highlighted for TCC discussion. See committee action and statement on Comment 85-2 (Log #6) Committee Meeting Action: Accept where the section was deleted. Number Eligible to Vote: 15 Committee Statement: See committee action and statement on Comment Ballot Results: Affirmative: 5 85-2 (Log #6) where the section was deleted. Number Eligible to Vote: 18 ____________________________________________________________ Ballot Results: Affirmative: 6 85-29 Log #CC0 BCS-MBB Final Action: Accept in Principle Ballot Not Returned: 2 Cowdrick, D., Kleen, R. (4.6.3.2.5(E)7) ____________________________________________________________ ____________________________________________________________ TCC Action: See Technical Correlating Committee action on 85-2 Log #42 BCS-FUN Final Action: Accept in Principle Comment 85-27a (Log #70) which meets the intent of this comment. (4.6.3.2.9, 4.6.3.2.9.1, and 4.6.3.2.9.2) BCS-FUN Comment 85-26 (Log #35) was held by the TCC for further ____________________________________________________________ revision. Submitter: Michael C. Polagye, FM Global Submitter: Technical Committee on Multiple Burner Boilers Comment on Proposal No: 85-49 Comment on Proposal No: 85-8 Recommendation: Replace "controller" and "controllers" with "system" Recommendation: Modify BCS-FUN Comment 85-26 (Log #5) and "systems," respectively as follows: committee meeting action to make the suggested changes, but with the 4.6.3.2.9 Logic Systems Controllers. following modifications. 4.6.3.2.9.1 Logic systems controllers, if used, shall be monitored for failure.

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4.6.3.2.9.2 If the logic system controller is not redundant, failure of the logic system controller shall require a fuel trip for the burners managed by the failed logic system controller. Also delete Annex paragraph A.4.6..2.9 as follows: A.4.6..2.9 Logic controllers include PLCs, Digital Processing Units (DPUs), Distributed Control Systems (DCSs), etc. Substantiation: As stated in the TCC comment on Proposals 85-49 and 85-50 and by the submitter of Proposal 85-50, "logic system" is a defined term while "logic controller" is not. The Annex is not needed with "logic system" being a defined term. Committee Meeting Action: Accept in Principle See committee action and statement on Comment 85-2 (Log #6) where the section was deleted. Committee Statement: See committee action and statement on Comment 85-2 (Log #6) where the section was deleted. Number Eligible to Vote: 18 Ballot Results: Affirmative: 6 Ballot Not Returned: 2 Cowdrick, D., Kleen, R.

NFPA 85

____________________________________________________________ 85-5 Log #2 BCS-MBB Final Action: Accept in Principle (4.6.5.1.3.2) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-5 Recommendation: Submit a comment to BCS-SBB and BCS-MBB as follows: Consider if additional action needs to be taken as a result of this proposal, and further consideration be given to the comments expressed in voting on the BCS-FUN ballot. Substantiation: This is a direction from the Technical Correlating Committee on Boiler Combustion System Hazards in accordance with 4.2 and -4. of the Regulations Governing Committee Projects. Committee Meeting Action: Accept in Principle See committee action and statement on Comment 85-6 (Log #4). Committee Statement: The BCS-MBB Committee highlights this for TCC discussion [BCS-FUN 85-6 (Log #4) and BCS-SBB action to add ____________________________________________________________ new 4.6.5... and associated annex]. The Committee does not agree 85- Log #2 BCS-FUN Final Action: Accept in Principle that it is needed for BCS-MBB. The topic is covered for BCS-MBBs (4.6.3.2.9 and 4.6.3.2.9.1) in 4.6.5.. in the 2004 edition in a performance-based manner without ____________________________________________________________ requiring specific equipment. As written, BCS-FUN Comment 85-6 (Log Submitter: Technical Correlating Committee on Boiler Combustion #4) would require it for all chapters, and BCS-MBB is opposed to this System Hazards because it doesn't add significantly to the safe operation of BCS-MBBs. Comment on Proposal No: 85-50 Recommendation: Submit a comment to the Fundamentals Committee as Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 follows: Ballot Not Returned: Seroka, G. It is suggested that the committee consider changing the action to "Accept in Principle", still maintaining the other changes from Proposal ____________________________________________________________ 85-49 (Log #). 85-6 Log #4 BCS-FUN Final Action: Hold Substantiation: The submitter's substantiation is correct that the "logic controller" is NOT a defined term in NFPA 85, whereas "logic system" IS (4.6.5.1.5 (New) ) ____________________________________________________________ a defined term. See Proposal BCS-FUN 85-49 (Log #). Committee Meeting Action: Accept in Principle TCC Action: This material has not had the benefit of public See committee action and statement on Comment 85-2 (Log #6) review, and shall be submitted to HRSG, BCS-FBB and BCS-SBB where the section was deleted. for consideration to add in their chapters. This material is not Committee Statement: See committee action and statement on Comment appropriate for inclusion in the BCS-FUN chapters because BCS85-2 (Log #6) where the section was deleted. MBB declined to add the material in their chapter in Comment 85-35 Number Eligible to Vote: 18 (Log #23). Ballot Results: Affirmative: 6 Submitter: Michael C. Polagye, FM Global Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Comment on Proposal No: 85-5 Recommendation: Insert a new 4.6.5..5 as follows: ____________________________________________________________ 4.6.5..5 Valves and dampers used to maintain air/fuel ratio shall have 85-4 Log #22 BCS-SBB Final Action: Hold local external visual indication of position. (4.6.5.1.3.2) Substantiation: As noted in the Committee's Substantiation, the ____________________________________________________________ submitter's reason for creating the proposal addresses a valid safety issue TCC Action: See TCC action on 85-36 (Log #43). that applies to both control valves and dampers and should not be limited Submitter: Technical Correlating Committee on Boiler Combustion to multiple-burner boilers. The new paragraph number for the text in this System Hazards comment addresses these concerns. Committee Meeting Action: Accept Comment on Proposal No: 85-5 Number Eligible to Vote: 18 Recommendation: Submit a comment to BCS-SBB and BCS-MBB as Ballot Results: Affirmative: 6 follows: Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Consider if additional action needs to be taken as a result of this proposal, and further consideration be given to the comments expressed in ____________________________________________________________ voting on the BCS-FUN ballot. 85-6a Log #7 BCS-AAC Final Action: Accept Substantiation: This is a direction from the Technical Correlating (4.6.5.2.1) Committee on Boiler Combustion System Hazards in accordance with ____________________________________________________________ 4.2 and -4. of the Regulations Governing Committee Projects. Submitter: Technical Correlating Committee on Boiler Combustion Committee Meeting Action: Accept in Principle System Hazards Insert a new 4.6.5... and annex material as follows: 4.6.5...2 4.6.5...* Flow control valves on single burner boilers used Comment on Proposal No: 85-8 Recommendation: Modify Section 4.6.5.2. as follows: to maintain air/fuel ratio shall have visual indication of position. 4.6.5.2. Except as noted in 4.6.5.2.2, under no circumstances shall the A.4.6.5...2 A.4.6.5... During setup, commissioning and operation it airflow demand be less than the purge rate. is necessary for operators to verify that valves are in the correct position. Substantiation: In the 200 edition, Section 4.6.5.2. was a requirement Off ratio operation can rapidly result in hazardous conditions. and 4.6.5.2.2 was an exception to the requirement. In the 2004 edition, the Committee Statement: The Committee highlights this for TCC exception was changed to be a requirement, which is an error as the two discussion. The Committee agrees in principle with the original Proposal sections now conflict since both cannot be satisfied. 85-5. The BCS-SBB TC believes that the material is applicable to TCs Committee Meeting Action: Accept beyond BCS-MBB and BCS-SBB and believes each committee should [The TCC ballot results were 14 voting members; of whom 12 review this to see if it shall apply to their respective chapters, and if voted affirmatively, 1 negatively, and 1 ballot was not returned (McCullion).] so, modify this section accordingly. The Committee agrees with the submitter's substantiation, but expanded the text to include all combustion Mr. Fringeli voted negatively stating: control valves: "Combustion control systems with fuel control valves "There appears to be a direct conflict between the provisions of without exterior indication having been observed. In some cases, the same Comment 85-6a (Log #7) in the TCC ballot and ROC Comments 85-60 manufacturers valve can indicate full open/or full closed position with (Log #5), 85-66 (Log #54), 85-68 (Log #55), and 85-76 (log #5). the exterior drive device in the same position, resulting in unsafe start-up · ROC Comment 85-6a states: Except as noted in 4.6.5.2.2 under no during setup." circumstances shall the airflow demand be less than the purge rate. Number Eligible to Vote: 15 · ROC Comments 85-60, 85-66, 85-68, and 85-76 set the mandatory Ballot Results: Affirmative: 4 Negative: master fuel trip at 5 percent below the minimum purge rate. Explanation of Negative: Since the 960's the MFT had been set at 5 percent below the purge DRESSEL, D.: The visual indication on flow control valves got a lot of rate. Five percent below purge rate is consistent with the Fundamentals discussion and was not without dissent. As a minimum standard, I think provision that airflow demand should not be less than purge rate if we have been able to get by without this requirement for 40+ years we still can. There is existing equipment that does not have this indication and (Comment 85-6a). Five percent below minimum purge can deviate significantly from this provision since the minimum purge rate can be well I expect that will continue.

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below the purge rate. This is a matter of correlation between Fundamentals and MBB. The above conflict also exists within MBB itself. Comments, 85-60, 85-66, and 85-68 conflict with subsections 6.6.5..5.7., 6.7.5..5.7, and 6.8.5..5.7 of ROP 85-8 (Log #70 BCS) respectively. This conflict, however, is not strictly a TCC issue. Although operating experience may support setting the MFT at 5 percent below the minimum purge rate, the proposed changes to NFPA 85 in this regard have introduced serious conflicts within the standard."

NFPA 85

____________________________________________________________ 85-9 Log #2 BCS-SBB Final Action: Accept (5.3.6.2) ____________________________________________________________ Submitter: Ted Jablkowski, North American Mfg. Co., Ltd. Comment on Proposal No: 85-58 Recommendation: Revise text to read: 5..6.2 Each interlock shall be provided with a method of establishing the set point. that shall be repeatable within prescribed limits. Substantiation: The substantiation for the committee's action to Reject ____________________________________________________________ Proposal 85-58 (Log #80) BCS-SBB regarding 5..6. indicated that 85-7 Log #7 BCS-FUN Final Action: Accept "5..6 does not pertain to the periodic testing of safety interlocks". This (4.6.8.1 and 4.7.1) substantiation, therefore, supports the removable of the requirement ____________________________________________________________ shown stricken above, which could arguably only be determined by a Submitter: Technical Correlating Committee on Boiler Combustion suitable test, periodic or otherwise. In addition, the stricken requirement is System Hazards unenforceable as it does not provide any definition of "prescribed limits". Comment on Proposal No: 85-8 Committee Meeting Action: Accept Recommendation: Modify Section 4.6.8. and 4.7. as follows: Number Eligible to Vote: 15 4.6.8. Where selective catalytic reduction (SCR) systems are selected Ballot Results: Affirmative: 5 for NOx emission control, they shall be integrated into the design of the ____________________________________________________________ boiler system, HRSG, or combustion turbine exhaust system to operate in 85-40 Log #24 BCS-MBB Final Action: Accept in Principle the flue gas temperature range required. (Figure 6.4.2.3.1) 4.7. The boiler, HRSG, combustion turbine exhaust system, or ____________________________________________________________ pulverized fuel system shall not be released for operation before the Submitter: Technical Correlating Committee on Boiler Combustion installation and checkout of the required safeguards and instrumentation System Hazards system have been successfully completed. Comment on Proposal No: 85-65 Substantiation: As a result of the expansion of the HRSG scope, the Recommendation: The TCC will submit a comment to the BCS-MBB TC changes in Chapter 4 are for consistency. as follows: Committee Meeting Action: Accept TCC recommends adding cross-reference to Section 4.6.9 Flue Gas Path Number Eligible to Vote: 18 Auxiliary Systems-Fuels and Feedstock Piping. Ballot Results: Affirmative: 6 Substantiation: See Committee Action and Statement on Proposal 85-7 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. (Log #). Committee Meeting Action: Accept in Principle ____________________________________________________________ See committee action and statement on Comment 85-4 (Log #46). 85-8 Log #44 BCS-FUN Final Action: Accept in Principle Committee Statement: See committee action and statement on Comment (4.7) 85-4 (Log #46). ____________________________________________________________ Number Eligible to Vote: 31 TCC Action: The TCC wished to incorporate the change accepted in Ballot Results: Affirmative: 0 85-37 (Log #7) to incorporate the phrase "combustion turbine exhaust Ballot Not Returned: Seroka, G. system". Modify the BCS-FUN comment to proposed Section 4.2.1 to read as ____________________________________________________________ follows: 85-4 Log #46 BCS-MBB Final Action: Accept in Principle 4.2.1 The boiler, HRSG, combustion turbine exhaust system, or (Figure 6.4.2.3.1) pulverized fuel system shall not be released for operation before ____________________________________________________________ the installation and checkout of the required safeguards and Submitter: Michael C. Polagye, FM Global instrumentation system have been successfully completed. Comment on Proposal No: 85-65 Submitter: Michael C. Polagye, FM Global Recommendation: Revise text of new block as follows: Comment on Proposal No: 85-0 Trip all flue gas path auxiliary systems that introduce hazards through Recommendation: Change Section 4.7 and its sub-paragraphs to Section addition of fuel, oxidizing agents, or ignition sources. See 4.6.9, Flue Gas 4.2 and re-title section to Installation and Commissioning as follows: Path Auxiliary Systems - Fuel and Feedstock Piping. 4.27 Installation and Commissioning. Substantiation: 4.6.9 is a new section in Chapter 4 that provides valve 4.27.1 The boiler, HRSG, or pulverized fuel system shall not be requirements for fuel and feedstock piping supplying flue gas path released for operation before the installation and checkout of the required auxiliary systems. safeguards and instrumentation system have been successfully completed. Committee Meeting Action: Accept in Principle 4.27.2 The party responsible for the erection and installation of the Revise text of new block as follows: equipment shall ensure that all pertinent apparatus is installed and Trip all flue gas path auxiliary systems that introduce hazards through connected in accordance with the system design. addition of fuel, oxidizing agents, or ignition sources. See 4.6.9. Flue Gas 4.27.3 The owner or owner's representative, the engineering consultant, Path Auxiliary Systems - Fuel and Feedstock Piping. the equipment manufacturer, and the operating company shall prohibit Committee Statement: The box isn't big enough to contain all the text operation until the safeguards have been tested for correct operation as a and already contains enough text. The submitter's intent was met. system. Number Eligible to Vote: 31 4.27.3.1 If temporary interlocks and instrumentation are necessary to Ballot Results: Affirmative: 0 meet these requirements, any such temporary system shall be reviewed by Ballot Not Returned: Seroka, G. the purchaser, the engineering consultant, the equipment manufacturer, and the operating company, and agreement shall be reached on the system's ____________________________________________________________ ability to protect equipment and personnel in advance of start-up. 85-42 Log #59 BCS-MBB Final Action: Reject 4.27.3.2 All temporary modifications shall be documented, and (Table 6.4.2.3.1(a) Blocks 3 through 12) permanent resolutions shall be accomplished prior to commercial ____________________________________________________________ operation. Submitter: Charles Moore, Hull, MA 4.27.4 The safety interlock system and protective devices shall be tested Comment on Proposal No: 85-8 jointly by the organization responsible for the system design and those Recommendation: Blocks through 2, 6.6.5.2.54, 6.7.5.2.5.4, 6.4.2.. who operate and maintain such a system and devices. et al: 4.27.5 After installation but before initial operation, coordinated tests of The paragraphs referenced above require tripping the precipitator on a all systems shall be accomplished. MFT. 4.27.6 Documentation of the plant equipment, the system, and Substantiation: This is the safe thing to do but is not being implemented maintenance activities shall be updated to reflect changes in the status of at many plants due to E.P.A. Requirements. EPA Requirements have force equipment and operating procedures. of law, NFPA 85 does not. Suggest NFPA discuss with EPA a 0 minute Substantiation: Proposal 85-0 (Log #7) deleted the existing Section after emergency trip where opacity limits are waived. Such relief would 4.2, Installation, as all requirements in that section were also contained ease the plants reluctance to trip the ESP. in Section 4.7, Commissioning. However, Section 4.2 is the more logical place in the chapter for this material, which addresses both installation and Committee Meeting Action: Reject Committee Statement: There is no recommended action. The implied commissioning. Committee Meeting Action: Accept action of leaving the precipitator in service on an MFT has been Number Eligible to Vote: 18 determined to be unsafe, as acknowledged by the submitter. Ballot Results: Affirmative: 6 Number Eligible to Vote: 31 Ballot Not Returned: 2 Cowdrick, D., Kleen, R. Ballot Results: Affirmative: 0

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Ballot Not Returned: Seroka, G. Comment on Affirmative: GAMBLE, K.: Revise "capacity" to "opacity".

NFPA 85

____________________________________________________________ 85-46 Log #2 BCS-MBB Final Action: Accept in Principle (Table 6.4.2.3.1(c)(2)) ____________________________________________________________ ____________________________________________________________ Submitter: Bill Bass, Forney Corp. 85-4 Log #66 BCS-MBB Final Action: Reject Comment on Proposal No: 85-7 (Table 6.4.2.3.1(a) Blocks 3 through 12) Recommendation: Revise text to read as follows: ____________________________________________________________ (2) Any igniters proven on, all main fuel remains off all burner Submitter: Charles Moore, Hull, MA valves remain closed, all pulverizers remain stopped, all igniter valves Comment on Proposal No: 85-8 subsequently closed. Recommendation: Blocks through 2: Substantiation: New wording removes any question as to whether it These blocks represent conditions that initiate the tripping of all main applies to coal fired units, gas fired units, oil fired units, or multiple fuel and ignition fuel supplies through master fuel trip relay contact(s) or fired units. specific fuel trip relays contact(s)....Whenever the master fuel trip relay(s) Committee Meeting Action: Accept in Principle is operated it shall trip all fuel header, burner, and ignitor safety shutoff Revise text to read as follows: valves and de-energize all sparks, and all ignition devices within the unit (2) Any igniters proven on, all other fuel sources off all burner and flue gas path through master fuel trip relay contact(s) or specific fuel valves remain closed, all pulverizers remain stopped, all igniter valves trip relays contact(s). subsequently closed. Committee Statement: The committee agrees with the submitter's intent The master fuel trip relay contact(s) or specific fuel trip relays contact(s) to reword in an attempt to avoid the misconception that if there is no shall also trip the fuel oil circulating and recirculating valves.... pulverizer, the requirement doesn't apply. This also avoids ambiguity The master fuel trip relay contact(s) or specific fuel trip relays contact(s) between main fuel and auxiliary or warm up fuels. shall also trip primary air fans or exhausters, coal feeders and coal burner Number Eligible to Vote: 31 line shutoff valves or take equivalent functional action to stop coal Ballot Results: Affirmative: 0 delivery to burners. Ballot Not Returned: Seroka, G. Substantiation: The revision incorporated here [through Proposal 8568 (Log #69)] will require a hardwired relay tripping system that is ____________________________________________________________ very complex and will require a relay larger than is currently made. The 85-47 Log #45 BCS-MBB Final Action: Reject alternative is multiple MFT relays which worse. (6.4.2.3.4) The past practice of breaking the trips up into fuel based trip relays, ____________________________________________________________ Oil Fuel Trip (OFT) relay, Gas Fuel Trip (GFT) relay, and Ignitor Fuel Submitter: Michael C. Polagye, FM Global Trip (IFT) relay has worked reliably over the years. The MFT relay is Comment on Proposal No: 85-75 reduced in size and complexity as it trips the specific fuel relays which Recommendation: Revise text to read as follows: provide adequate contacts to the operating equipment. Relays are currently 6.4.2.3.4 Boiler Enclosure Purge. available of the size required for this cascade system. 6.4.2.3.4.1 A Boiler Enclosure Purge in accordance with the Purge Committee Meeting Action: Reject Requirements in Section 6.4.4 shall be performed prior to the resetting Committee Statement: The change is not needed because the "(s)" at the of the master fuel trip relay and introduction of an ignition source or fuel end of "relay", indicates it can be multiple, including individual fuel trip to the boiler enclosure, after the occurrence of a shutdown or master fuel relays. It is the intent of the TC that multiple relays are allowed. trip, and after any purge permissive is lost prior to introducing an ignition Number Eligible to Vote: 31 source or fuel into the boiler enclosure. Ballot Results: Affirmative: 0 6.4.2.3.4.7.12* Completion of the Boiler Enclosure Purge shall require Ballot Not Returned: Seroka, G. a minimum of five minutes and at least five volume changes of the boiler enclosure while all of the purge permissives are maintained. ____________________________________________________________ 6.4.2.3.4.7.23 Accumulation of purge time and volume changes shall be 85-44 Log #25 BCS-MBB Final Action: Accept in Principle permitted as soon as all of the purge permissives are satisfied. (Table 6.4.2.3.1(b)) 6.4.2.3.4.54* Boiler Enclosure Purge Permissives. Boiler enclosure ____________________________________________________________ purge permissives shall, at a minimum, include: Submitter: Technical Correlating Committee on Boiler Combustion (A) All igniter header and individual igniter shutoff valves proven closed System Hazards by valve position. Comment on Proposal No: 85-70 Exception: Where the igniter capacity is 1.5 MWt (5 million Btu/hr) or Recommendation: TCC submits a comment to the BCS-MBB TC as less, proof of closure of individual igniter safety shutoff valves by means follows: Consider adding a comma after the word "stopped" in the proposed text. other than valve position shall be permitted. (B) If coal is fired on the unit, all pulverizers are stopped and all coal Substantiation: Editorial clarity. flow to the furnace stopped. Committee Meeting Action: Accept in Principle (C) If fuel gas is fired on the unit, all main fuel gas header and See committee action on Comment 85-45 (Log #). individual fuel gas burner shutoff valves are proven closed by valve Committee Statement: The word "stopped" is no longer there per position. committee action on 85-45 (Log #). Number Eligible to Vote: 31 (D) If fuel oil is fired on the unit, all main fuel oil header and individual Ballot Results: Affirmative: 0 fuel oil burner shutoff valves are proven closed by valve position. Ballot Not Returned: Seroka, G. (E) Any other sources of combustibles that could enter the boiler enclosure proven closed by valve position or other positive means. ____________________________________________________________ Exception: Where the capacity of the combustible source is 1.5 MWtt (5 85-45 Log # BCS-MBB Final Action: Accept in Principle million Btu/hr) or less, proof of closure of shutoff valves by means other (Table 6.4.2.3.1(b)(2)) than valve position shall be permitted. ____________________________________________________________ (F) All required burner air registers are in purge position. Submitter: Bill Bass, Forney Corp. (G) At least one FD fan and, if so equipped, one ID fan in service. Comment on Proposal No: 85-70 (H) Flue gas recirculation fans shall be operated as recommended by the Recommendation: Revise text to read as follows: boiler manufacturer. (2) Any igniters proven on, all main fuel remains off all burner (I) Total boiler air flow is at purge rate air flow. valves remain closed, all pulverizers remain stopped, all igniter valves 6.4.2.3.4.7.35 Loss of any of the purge permissives during a boiler subsequently closed. enclosure purge shall cancel any purge time and volume changes that have Substantiation: New wording removes any question as to whether it accumulated. applies to coal fired units, gas fired units, oil fired units, or multiple fuel 6.4.2.3.4.7.46 Completion of boiler enclosure purge shall be indicated. fired units. 6.4.2.3.4.7.57 After the boiler enclosure purge is complete, the master Committee Meeting Action: Accept in Principle fuel trip relay(s) shall be permitted to be reset. Revise text to read as follows: 6.4.2.3.4.85* Component Purge. (2) Any igniters proven on, all other fuel sources off all burner 6.4.2.3.4.8.15.1 Prior to being placed in operation, all flue gas path valves remain closed, all pulverizers remain stopped, all igniter valves subsequently closed. components from the boiler enclosure to the stack inlet (e.g., precipitators, Committee Statement: The committee agrees with the submitter's intent fired reheaters) containing sources of ignition energy shall be purged to reword in an attempt to avoid the misconception that if there is no for a minimum of five minutes and at least five volume changes of the pulverizer, the requirement doesn't apply. This also avoids ambiguity component while all of the component purge permissives are maintained. between main fuel and auxiliary or warm up fuels. 6.4.2.3.4.8.25.2 Components shall be purged with air or, after the unit is Number Eligible to Vote: 31 in service, with flue gas or inert gas that will not support combustion. Ballot Results: Affirmative: 0 6.4.2.3.4.8.35.3* Purging of these components shall be permitted to be Ballot Not Returned: Seroka, G. performed concurrently with the Boiler Enclosure Purge.

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6.4.2.3.4.8.45.4 Accumulation of purge time and volume changes shall be permitted as soon as all of the component purge permissives are satisfied. 6.4.2.3.4.65.5* Component Purge Permissives. Component purge permissives shall, at a minimum, include: (A) All sources of fuel and other combustibles into the component proven closed by valve position or other positive means. (B) All sources of ignition energy proven off. (C) Component purge flow rate at or above boiler enclosure purge rate air flow. 6.4.2.3.4.8.55.6 Loss of any of the component purge permissives during a component purge shall cancel any purge time and volume changes that have accumulated. When conducted concurrently with the Boiler Enclosure Purge, loss of any purge permissives during a component purge shall cancel any purge time and volume changes that have accumulated. 6.4.2.3.4.8.65.7 After the component purge is complete, the component shall be permitted to be reset. 6.4.2.3.4 Purge Requirements. {And renumber subsequent sections accordingly} 6.4.2.3.4.1 A Boiler Enclosure Purge shall be performed as part of the open register, continuous purge light off procedures specified in 6.6.5..7, 6.7.5..7, and 6.8.5..7. 6.4.2.3.4.2 A Boiler Enclosure Purge shall be completed before resetting of the master fuel trip relay shall be permitted. 6.4.2.3.4.3 A Boiler Enclosure Purge shall be required after the occurrence of a master fuel trip or if any purge permissive is lost prior to introducing any fuel or ignition source to the boiler enclosure. 6.4.2.3.4.3.1 On a normal shutdown, after all fuel has been removed from service, Boiler Enclosure Purge conditions, including purge rate air flow, shall be established and a Boiler Enclosure Purge completed. 6.4.2.3.4.3.2* On an emergency shutdown where FD & ID fans remain in service, boiler enclosure purge conditions shall be established and a Boiler Enclosure Purge completed. Purge rate air flow shall be established in accordance with the following procedure; (A) All fans in the combustion air and flue gas streams that are in service at the time of the trip shall be left in service. This shall not include primary air fans or pulverizer exhausters used to convey coal into the furnace. (B) The airflow shall not be changed by deliberate manual or automatic control action except as permitted in (C) and (D). (C) If the airflow is greater than the purge rate, it shall be permitted to be decreased gradually to the purge rate for a Boiler Enclosure Purge. (D) If the airflow is less than the purge rate at the time of the trip, it shall be continued at the existing rate for 5 minutes and then increased gradually to the purge rate airflow and held at that value for a Boiler Enclosure Purge. If increasing airflow to purge rate requires starting fans, they shall be started in accordance with Section 6.5. (E) During a master fuel trip event, the overfire air system shall remain at the same setting as when the event occurred for such time as the main combustion airflow is held. (F) Following the hold period, the overfire air shall be permitted to be gradually adjusted to overfire air purge settings or cooling flows either manually or automatically. 6.4.2.3.4.3.3 On an emergency shutdown where no fans remain in service, boiler enclosure purge conditions shall be established and a Boiler Enclosure Purge completed. Purge rate air flow shall be established in accordance with the following procedure: (A) All dampers in the air and flue gas passages of the unit shall be opened slowly to the fully open position to create as much natural draft as possible to ventilate the unit. (B) Opening of fan dampers shall be timed or controlled to ensure that positive or negative furnace pressure transients beyond design limits do not occur during fan coast down. (C) This condition shall be maintained for at least 5 minutes. (D) At the end of this period, the fan(s) shall be started in accordance with Section 6.5. (E) The airflow shall be increased gradually to the purge rate, and a Boiler Enclosure Purge shall be completed. 6.4.2.3.4.3.4 After completion of the Boiler Enclosure Purge, the unit shall be permitted to either: () Shutdown, closing the burner air registers and shutting down the forced draft fans and induced draft fans; however, maintaining airflow through the unit to prevent accumulation of combustible gases is a prudent procedural step due to the potential of fuel leak-by. (2) Relight in accordance with the applicable paragraphs of 6.6.5, 6.7.5, or 6.8.5, depending on the fuels being fired. 6.4.2.3.4.4 Purge Rate Air Flow. 6.4.2.3.4.4.1* Purge rate air flow shall not be less than 25 percent of design full load mass air flow. 6.4.2.3.4.4.2* Purge rate air flow shall not be greater than 40 percent of design full load mass air flow for coal-fired units. 6.4.2.3.4.4.3 Purge rate air flow shall be a predefined rate defined by the designer. 6.4.2.3.4.4.4 Purge rate air flow shall be maintained from the forced draft (FD) fan inlet through the stack.

NFPA 85

6.4.2.3.4.4.5 Purge rate air flow shall be maintained from purge completion through light off and initial loading as described in Subparagraphs 6.6.5..5, 6.7.5..5, and 6.8.5..5. Substantiation: As accepted by the committee, Proposal 85-8 (Log #CP70), the section and paragraph numbering in some areas exceed the maximum number of levels allowed by the NFPA Manual of Style. The proposed reorganization addresses this and additionally separates purge interlocks from purge requirements by retaining the Boiler Enclosure Purge and Component Purge interlocks under the major heading of 6.4.2, Interlock System and creates a new section 6.4.4, Purge Requirements. Committee Meeting Action: Reject Committee Statement: The submitter is commended for the work. However, due to the complexity of the cross-referencing, the committee is reluctant to implement the change. See Committee Comment 85-54 (Log #CC). Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. Comment on Affirmative: GAMBLE, K.: In exception following 6.4.2..4(E) change MWtt to MWt. ____________________________________________________________ 85-48 Log #69 BCS-MBB Final Action: Accept (6.4.2.3.4) ____________________________________________________________ Submitter: Bill Bass, Forney Corp. Comment on Proposal No: 85-8 Recommendation: Revise text to read: 6.4.2..4 Purge Requirements. 6.4.2..4. A Boiler Enclosure Purge shall be performed as part of the open register, continuous purge light off procedures specified in 6.6.5..7, 6.7.5..7, and 6.8.5..7. 6.4.2..4.2 A Boiler Enclosure Purge shall be completed before resetting of the master fuel trip relay shall be permitted. 6.4.2..4. A Boiler Enclosure Purge shall be required after the occurrence of a master fuel trip or if any purge permissive is lost prior to introducing any fuel or ignition source to the boiler enclosure. 6.4.2..4.. (A) On a normal shutdown, after all fuel has been removed from service, Boiler Enclosure Purge conditions, including purge rate air flow, shall be established and a Boiler Enclosure Purge completed. 6.4.2..4..2 (B)* On an emergency shutdown where FD and ID fans remain in service, boiler enclosure purge conditions shall be established and a Boiler Enclosure Purge completed. Purge rate air flow shall be established in accordance with the following procedure; (A) () All fans in the combustion air and flue gas streams that are in service at the time of the trip shall be left in service. This shall not include primary air fans or pulverizer exhausters used to convey coal into the furnace. (B) (2) The airflow shall not be changed by deliberate manual or automatic control action except as permitted in (C) () and (D) (4). (C) () If the airflow is greater than the purge rate, it shall be permitted to be decreased gradually to the purge rate for a Boiler Enclosure Purge. (D) (4) If the airflow is less than the purge rate at the time of the trip, it shall be continued at the existing rate for 5 minutes and then increased gradually to the purge rate airflow and held at that value for a Boiler Enclosure Purge. If increasing airflow to purge rate requires starting fans, they shall be started in accordance with Section 6.5. (E) (5) During a master fuel trip event, the overfire air system shall remain at the same setting as when the event occurred for such time as the main combustion airflow is held. (F) (6) Following the hold period, the overfire air shall be permitted to be gradually adjusted to overfire air purge settings or cooling flows either manually or automatically. 6.4.2..4.. (C) On an emergency shutdown where no fans remain in service, boiler enclosure purge conditions shall be established and a Boiler Enclosure Purge completed. Purge rate air flow shall be established in accordance with the following procedure: (A) () All dampers in the air and flue gas passages of the unit shall be opened slowly to the fully open position to create as much natural draft as possible to ventilate the unit. (B) (2) Opening of fan dampers shall be timed or controlled to ensure that positive or negative furnace pressure transients beyond design limits do not occur during fan coast down. (C) () This condition shall be maintained for at least 5 minutes. (D) (4) At the end of this period, the fan(s) shall be started in accordance with Section 6.5. (E) (5) The airflow shall be increased gradually to the purge rate, and a Boiler Enclosure Purge shall be completed. 6.4.2..4..4 (D) After completion of the Boiler Enclosure Purge, the unit shall be permitted to either: () Shutdown, closing the burner air registers and shutting down the forced draft fans and induced draft fans; however, maintaining airflow through the unit to prevent accumulation of combustible gases is a prudent procedural step due to the potential of fuel leak-by.

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(2) Relight in accordance with the applicable paragraphs of 6.6.5, 6.7.5, or 6.8.5, depending on the fuels being fired. 6.4.2..4.4 Purge Rate Air Flow. 6.4.2..4.4. (A)* Purge rate air flow shall not be less than 25 percent of design full load mass air flow. 6.4.2..4.4.2 (B)* Purge rate air flow shall not be greater than 40 percent of design full load mass air flow for coal-fired units. 6.4.2..4.4. (C) Purge rate air flow shall be a predefined rate defined by the designer. 6.4.2..4.4.4 (D) Purge rate air flow shall be maintained from the forced draft (FD) fan inlet through the stack. 6.4.2..4.4.5 (E) Purge rate air flow shall be maintained from purge completion through light off and initial loading as described in Subparagraphs 6.6.5..5, 6.7.5..5, and 6.8.5..5. 6.4.2..4.5* Boiler Enclosure Purge Permissives. Boiler enclosure purge permissives shall, at a minimum, include: (A) () All igniter header and individual igniter shutoff valves proven closed by valve position. Exception: Where the igniter capacity is .5 MWt (5 million Btu/hr) or less, proof of closure of individual igniter safety shutoff valves by means other than valve position shall be permitted. (B) (2) If coal is fired on the unit, all pulverizers are stopped and all coal flow to the furnace stopped. (C) () If fuel gas is fired on the unit, all main fuel gas header and individual fuel gas burner shutoff valves are proven closed by valve position. (D) (4) If fuel oil is fired on the unit, all main fuel oil header and individual fuel oil burner shutoff valves are proven closed by valve position. (E) (5) Any other sources of combustibles that could enter the boiler enclosure proven closed by valve position or other positive means. Exception: Where the capacity of the combustible source is .5 MWtt (5 million Btu/hr) or less, proof of closure of shutoff valves by means other than valve position shall be permitted. (F) (6) All required burner air registers are in purge position. (G) (7) At least one FD fan and, if so equipped, one ID fan in service. (H) (8) Flue gas recirculation fans shall be operated as recommended by the boiler manufacturer. (I) (9) Total boiler air flow is at purge rate air flow. 6.4.2..4.6* Component Purge Permissives. Component purge permissives shall, at a minimum, include: (A) () All sources of fuel and other combustibles into the component proven closed by valve position or other positive means. (B) (2) All sources of ignition energy proven off. (C) () Component purge flow rate at or above boiler enclosure purge rate air flow. 6.4.2..4.7* Boiler Enclosure Purge. 6.4.2..4.7. (A)* Completion of the Boiler Enclosure Purge shall require a minimum of five minutes and at least five volume changes of the boiler enclosure while all of the purge permissives are maintained. 6.4.2..4.7.2 (B) Accumulation of purge time and volume changes shall be permitted as soon as all of the purge permissives are satisfied. 6.4.2..4.7. (C) Loss of any of the purge permissives during a boiler enclosure purge shall cancel any purge time and volume changes that have accumulated. 6.4.2..4.7.4 (D) Completion of boiler enclosure purge shall be indicated. 6.4.2..4.7.5 (E) After the boiler enclosure purge is complete, the master fuel trip relay(s) shall be permitted to be reset. 6.4.2..4.8* Component Purge. 6.4.2..4.8. (A) Prior to being placed in operation, all flue gas path components from the boiler enclosure to the stack inlet (e.g., precipitators, fired reheaters) containing sources of ignition energy shall be purged for a minimum of five minutes and at least five volume changes of the component while all of the component purge permissives are maintained. 6.4.2..4.8.2 (B) Components shall be purged with air or, after the unit is in service, with flue gas or inert gas that will not support combustion. 6.4.2..4.8. (C)* Purging of these components shall be permitted to be performed concurrently with the Boiler Enclosure Purge. 6.4.2..4.8.4 (D) Accumulation of purge time and volume changes shall be permitted as soon as all of the component purge permissives are satisfied. 6.4.2..4.8.5 (E) Loss of any of the purge permissives during a component purge shall cancel any purge time and volume changes that have accumulated. 6.4.2..4.8.6 (F) After the component purge is complete, the component shall be permitted to be reset. Substantiation: NFPA editorial staff noted that in this newly rewritten purge section, there were paragraphs with seven place numbers. That is not permitted by the manual of style. In addition, the paragraphs with parenthetical capital letters represent lists and should be parenthetical numbered paragraphs. The proposed modification renumbers these paragraphs to meet the manual of style. All parenthetical capital lettered paragraphs were changed to parenthetical numbered paragraphs. All seven place numbered paragraphs were changed to parenthetical capital lettered

NFPA 85

paragraphs. I believe this meets the manual of style requirements and is consistent with the current NFPA 85 format. Committee Meeting Action: Accept Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. ____________________________________________________________ 85-49 Log #26 BCS-MBB Final Action: Accept in Principle (6.4.2.3.4.x) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-76 Recommendation: The TCC will submit a comment to BCS-MBB TC as follows: Verify the issues raised by the submitter in this log have indeed been addressed in Proposal 85-75 (Log #96). Substantiation: In the TCC review of Proposal 85-75 (Log #96), it was not apparent that the submitter's intent was addressed. Committee Meeting Action: Accept in Principle Modify ROP draft 6.4.2..4.5(E) and (F) as follows: (E) Any other sources of combustibles that could enter the boiler enclosure or flue gas path proven closed by valve position or other positive means. (F) All; required burner air registers are in purge position. Committee Statement: This change meets the original intent of the submitter. The changes in (F) are editorial. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. ____________________________________________________________ 85-50 Log #49 BCS-MBB Final Action: Accept (6.4.2.3.4.3) ____________________________________________________________ Submitter: John P. O'Rourke, ALSTOM Power Inc. Comment on Proposal No: 85-75 Recommendation: Revise to read: ...or if any purge permissive, as defined in 6.4.2..4.5, is lost prior to... Substantiation: It is quite common that non-firing related conditions are included in Unit Purge Permit criteria, i.e., "Drum Level within limits", etc. In these instances, a condition such as drum level being outside of established limits should not require a repurge of the boiler. The revised wording clarifies the requirements. Note: This requirement, taken literally, will cause confusion as opening of the fuel header safety shutoff valves will cause the purge complete condition to reset before fuel is actually introduced into the boiler. Committee Meeting Action: Accept Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. ____________________________________________________________ 85-5 Log #50 BCS-MBB Final Action: Accept in Principle (6.4.2.3.4.4.3) ____________________________________________________________ Submitter: John P. O'Rourke, ALSTOM Power Inc. Comment on Proposal No: 85-75 Recommendation: Revise to read: The boiler designer shall establish a minimum purge rate airflow at which the unit is may be purged. This purge rate airflow shall be in accordance with 6.4.2..4.4. and 6.4.2..4.4.2. Substantiation: Revised wording will provide clarity that there is a "minimum" purge rate airflow that can be used to purge and "operate" the unit and it is established by the boiler designer. The rate of airflow that is used to generate a Master Fuel Trip should be 5 percent below this "design" value. It is not practical to have the airflow trip setpoint track the rate at which the unit was purged. Suggest to renumber this paragraph to 6.4.2..4.4. and renumber subsequent paragraphs. Committee Meeting Action: Accept in Principle Replace and modify existing 6.4.2..4.4. to be the new 6.4.2..4.4., renumbering subsequent sections accordingly to read: 6.4.2..4.4. The boiler designer shall establish a minimum purge rate airflow. at which the unit is may be purged. This purge rate airflow shall be in accordance with 6.4.2..4.4. 6.4.2..4.4.2 and 6.4.2..4.4.2 6.4.2..4.4.. Committee Statement: Slight editorial changes for clarity. The referenced sections were modified to reflect the insertion. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. Comment on Affirmative: RUSSELL, T.: I believe there is an editorial error in the first sentence of the revised text. It should read: The boiler designer shall establish a minimum purge rate airflow at which the unit may be purged.

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____________________________________________________________ 85-52 Log #60 BCS-MBB Final Action: Reject (6.4.2.3.4.4.5) ____________________________________________________________ Submitter: Charles Moore, Hull, MA Comment on Proposal No: 85-8 Recommendation: Revise text: 6.4.2..4.4.5 Twenty-five percent MCR airflow shall be maintained from purge completion through light off and initial loading as described in 6.6.5..5, 6.7.5..5, and 6.8.5..5. Substantiation: On larger units, elevated air flows are used for purge (5 percent ±) to keep purge time to 5 minutes. It is not possible to light the ignitors at this air flow and it has to be reduced to 25 percent. Need to remove this requirement. Committee Meeting Action: Reject Committee Statement: The intent of the committee is to specifically prohibit this action because it is dangerous. Individual ignitor airflows can be reduced as long as the total airflow is maintained at or above minimum purge rate. Design purge airflow may be reduced to no less than that determined by the designer in 6.4.2..4.4. [Comment 85-5 (Log #50)] if it is recognized that the purge time needs to be increased. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

NFPA 85

Committee Statement: The meeting action is to clarify the intent. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

____________________________________________________________ 85-56 Log #57 BCS-MBB Final Action: Accept in Principle (6.5.1.1.1, 6.5.1.1.2, 6.5.1.3.1.1 and 6.5.1.3.1.2 (New) ) ____________________________________________________________ TCC Action: Modify 6.5.1.1.1 as follows, leaving 6.5.1.1.2 as accepted in the ROP as follows: 6.5.1.1.1 The furnace structural design shall be such that it is capable of withstanding a transient design pressure without permanent deformation due to yield or buckling of any support member. 6.5.1.1.2 This transient design pressure need not be considered as acting simultaneously with other transient loads such as wind load or seismic load. Substantiation: Section 6.5.1.1.1, as proposed in the ROP was more conservative than the requirement in Section 4.6.1 as it appears in the ROP and Section 7.5.1 as it appears in the 2004 edition (which was not changed). It was not the intent of Proposal ROP 85-81 (Log #CP705) to change the transient pressure design requirements and the new text provides language consistent with the 2004 edition. Submitter: John P. O'Rourke, Alstom Power Inc. ____________________________________________________________ Comment on Proposal No: 85-8 85-5 Log #27 BCS-MBB Final Action: Accept Recommendation: Delete 6.5... and 6.5...2 and add new subsections (6.4.2.3.5) 6.5.... and 6.5....2 as follows: ____________________________________________________________ 6.5.... For structural design purposes, the calculated stress Submitter: Technical Correlating Committee on Boiler Combustion resulting from "transient" design pressure, either acting alone, or acting System Hazards in combination with other loads such as dead load shall be permitted a Comment on Proposal No: 85-77 Recommendation: The TCC will submit a comment to BCS-MBB TC as one-third allowable stress increase over that used for continuous design pressure. follows: 6.5....2 This transient design pressure need not be considered as Verify the issues raised by the submitter in this log have indeed been acting simultaneously with other loads such as wind load or seismic load. addressed in Proposal 85-75 (Log #96). Substantiation: The sections referenced above relate to 6.5..2() from Substantiation: In the TCC review of Proposal 85-75 (Log #96), it was the 2004 code which referenced the requirements of ASCE 7. This not apparent that the submitter's intent was addressed. Committee Meeting Action: Accept referenced code applies to only one of the two permitted options that are Committee Statement: The submitter's intent was met in BCS-MBB allowed in 6.5..2 but did not apply to 6.5..2(2) which requires a furnace Proposal 85-75 (Log #96). pressure control system in accordance with 6.5.2 and a furnace design Number Eligible to Vote: 31 in accordance with 4.6.. Paragraph 4.6. states that the furnace shall be Ballot Results: Affirmative: 0 capable of withstanding a "transient" design pressure without permanent Ballot Not Returned: Seroka, G. deformation due to yield or bucking of any support member. In this case, the one-third allowable does not apply. ____________________________________________________________ Committee Meeting Action: Reject 85-54 Log #CC BCS-MBB Final Action: Accept Committee Statement: ROP Section 6.5... does not address any (6.4.2.3.9.2) ____________________________________________________________ transient design pressure requirements so relocating these requirements into this section is incorrect. Submitter: Technical Committee on Multiple Burner Boilers Number Eligible to Vote: 31 Comment on Proposal No: 85-79 Ballot Results: Affirmative: 29 Negative: Recommendation: Modify 6.4.2..9.2 as follows: Ballot Not Returned: Seroka, G. 6.4.2..9.2 Mandatory Pulverizer Subsystem Trips -- Not Necessarily Explanation of Negative: Automatically Initiated. A direct-fired pulverized coal system trip shall O'ROURKE, J.: It is the writer's opinion that the technical committee result from be interlocked so that trips are initiated not necessarily automatic, in accordance with any of the following conditions: has improperly applied the one third allowable stress increase over the Substantiation: The proposed text in Proposal 85-79 using "interlock" continuous design pressure to the furnace enclosure and now conflicts implies an automatic trip, whereas the location is under the heading "...Not with section 4.6. which states that..." the furnace shall be capable of Necessarily Automatically Initiated". withstanding a transient design pressures and normal operating pressures Committee Meeting Action: Accept without permanent deformation due to yield or buckling of any support Number Eligible to Vote: 31 member. This reference to yield or buckling includes a two-thirds Ballot Results: Affirmative: 0 allowable stress increase above the continuous design pressure. Ballot Not Returned: Seroka, G. ____________________________________________________________ ____________________________________________________________ 85-57 Log #56 BCS-MBB Final Action: Accept in Principle 85-55 Log #47 BCS-MBB Final Action: Accept (6.5.1.2.1) (6.5.1.1) ____________________________________________________________ ____________________________________________________________ Submitter: John P. O'Rourke, Alstom Power Inc. Submitter: Michael C. Polagye, FM Global Comment on Proposal No: 85-8 Comment on Proposal No: 85-82 Recommendation: Revise text to read: Recommendation: Delete the text shown in the Committee Meeting 6.5..2....does not exceed the transient design pressure of furnace... Action as follows: 6.5.. The requirements of Section 6.5 shall apply to any boiler where Substantiation: The revised text in the ROP changes the requirements a fan is located in a flue gas stream downstream of the boiler enclosure to for the positive furnace design pressure from transient design pressure to minimize the risks of negative furnace draft in excess of furnace structural a continuous design pressure. Further, the revised text does not limit the capability. design pressure, (transient or continuous) to a maximum value as is done Substantiation: The action taken by the technical committee on this log with balanced draft units where the transient design pressure is limited to conflicts with the action taken in Proposal 85-8 (Log #CP705). The +5 in. w.c. correct action is to keep the text as written in 85-8. The action taken Committee Meeting Action: Accept in Principle on this Proposal 85-82 should remain as Accept in Principle. But the Delete ROP text of 6.5..2. as shown in Proposal 85-8 (Log #CP705). Committee Statement should be revised to: "Refer to action taken in Committee Statement: The submitter's intent was met by deleting the Proposal 85-8 (Log #CP705). This meets the intent of the submitter." section instead of modifying it. It eliminated the confusion between the Committee Meeting Action: Accept application of transient and continuous pressure. In the ROP draft, we are deleting the second paragraph of 6.5., Number Eligible to Vote: 31 retaining the first paragraph as follows: Ballot Results: Affirmative: 0 The requirements of Section 6.5 shall apply to any boiler where a fan Ballot Not Returned: Seroka, G. is located in a flue gas stream downstream of the boiler enclosure to minimize the risks of negative furnace draft in excess of furnace structural capability.

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____________________________________________________________ 85-58 Log #52 BCS-MBB Final Action: Accept in Principle (6.5.1.2.2) ____________________________________________________________ Submitter: John P. O'Rourke, ALSTOM Power Inc. Comment on Proposal No: 85-8 Recommendation: Revise text to read: 6.5..2.2 Implosion protection requirements shall not apply to pressurized fired units. Substantiation: See comment to 6.5..2. regarding transient design pressure. Committee Meeting Action: Accept in Principle Modify ROP text in 6.5..2.2 as shown in Proposal 85-8(Log #CP705) as follows: 6.5..2.2 6.5..2 Pressure Fired Units. Transient design pressure and Implosion protection requirements shall not apply to units without a fan located in the flue gas path downstream of the boiler enclosure pressure fired units. Committee Statement: Note than 6.5..2. was deleted per Comment 8557 (Log #56), so this section becomes 6.5..2. The submitter's intent was met. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

NFPA 85

____________________________________________________________ 85-62 Log #62 BCS-MBB Final Action: Accept in Principle (6.7.3.1.13) ____________________________________________________________ Submitter: Charles Moore, Hull, MA Comment on Proposal No: 85-8 Recommendation: Revise text to read: 6.7... Positive means shall be provided to prevent fuel from entering the burner header system through recirculating valves, particularly from the fuel supply system of another boiler. This does not prohibit fuel recirculation systems designed as required in this code. Substantiation: This paragraph as a stand alone prohibits fuel recirculating systems which are permitted in later sections of this code. General Comment: The fuel oil system requirements for a fuel oil warm up recirculation system design seems to conflict with each other and are confusing. In addition, they do not address the mechanically atomized delta P style of burner fuel oil supply system design where there is a continuous return flow. This return flow can be regulated, feed into a pump, etc., but generally goes to some sort of a header where an elevated pressure is present. The requirements in some of the paragraphs cannot be met with the requirements of this type of system. Committee Meeting Action: Accept in Principle Insert 2004 language from 6.7...5(A) and (B) and 6.7...6(A) and (B) to be inserted into the ROP draft, renumbering subsequent sections as follows: ____________________________________________________________ 6.7...5 6.7...2 Recirculation. 85-59 Log #58 BCS-MBB Final Action: Accept (A) Recirculation provisions shall be incorporated for controlling the (6.5.1.3.1) viscosity of the oil to the burners for initial light-off and for subsequent ____________________________________________________________ operation. Submitter: John P. O'Rourke, Alstom Power Inc. (B) These systems shall be designed and operated to prevent excessively Comment on Proposal No: 85-8 hot oil from entering fuel oil pumps, which could cause them to vaporRecommendation: Revise text to read: bind, with subsequent interruption to the fuel oil supply. shall be designed so that the maximum... 6.7...6 6.7... Positive means shall be provided to prevent fuel Substantiation: Editorial: removes "so that" which is repeated in the text. oil from entering the burner header system through recirculating valves, Committee Meeting Action: Accept particularly from the fuel supply system of another boiler. Number Eligible to Vote: 31 (A) These means shall utilize the requirements of Table 6.4.2..(a), Ballot Results: Affirmative: 0 blocks through 2. Ballot Not Returned: Seroka, G. (B) Check valves have not proven dependable in heavy oil service and shall not be used for this function. ____________________________________________________________ Committee Statement: In reviewing Proposal 85-8 (Log #CP70), it 85-60 Log #5 BCS-MBB Final Action: Accept in Principle was determined that there were four paragraphs that were inadvertently (6.6.5.2.5.2(B)2) deleted. These were reinstated, thereby meeting the intent of the submitter. ____________________________________________________________ Number Eligible to Vote: 31 Submitter: John P. O'Rourke, ALSTOM Power Inc. Ballot Results: Affirmative: 0 Comment on Proposal No: 85-75 Ballot Not Returned: Seroka, G. Recommendation: Revise 6.6.5.2.5.2(B)2 to read: Total airflow decreases 5 percent full load airflow below the minimum ____________________________________________________________ purge rate airflow as established by the boiler designer and in accordance 85-6 Log #6 BCS-MBB Final Action: Hold with 6.4.2..4.4.. (6.7.5.2.1.1(8) Exception (New) ) Substantiation: The revised text clarifies that the requirement of the ____________________________________________________________ Mandatory Airflow trip should be based on the minimum design airflow Submitter: Charles Moore, Hull, MA and not related to the airflow rate at which the unit was purged. Comment on Proposal No: 85-8 Committee Meeting Action: Accept in Principle Recommendation: Add an Exception to read: Revise ROP text in 6.6.5.2.5.2(B)2 as shown in Proposal 85-75 (Log 6.7.5.2..(8) All safety shutoff valves are closed and all sparked de#96) to read: energized. Total airflow decreases below the minimum purge rate airflow as Exception: If the design of the fuel oil system requires the safety shutoff required in 6.4.2..4.4. by 5% design full load airflow. be open for fuel oil recirculation, the safety shutoff valves may be open if Committee Statement: The section reference was changed as a result of all burner valves are proven closed. Comment 85-5 (Log #50). Editorial changes were made for clarity. The Substantiation: The added exception will permit the continued submitter's intent was met. recirculation of the fuel oil for system warm up during the start up Number Eligible to Vote: 31 procedure. If not, it appears that the recirculation system would be Ballot Results: Affirmative: 0 required to be shut down. In the common system design, this presents a Ballot Not Returned: Seroka, G. conflict with 6.7.5.2..(0). General Comment: The fuel oil system requirements for a fuel oil warm ____________________________________________________________ up recirculation system design seems to conflict with each other and are 85-6 Log #28 BCS-MBB Final Action: Accept confusing. In addition, they do not address the mechanically atomized (6.6.5.4.9) delta P style of burner fuel oil supply system design where there is a ____________________________________________________________ continuous return flow. This return flow can be regulated, feed into a Submitter: Technical Correlating Committee on Boiler Combustion pump, etc., but generally goes to some sort of a header where an elevated System Hazards pressure is present. The requirements in some of the paragraphs cannot be Comment on Proposal No: 85-94 met with the requirements of this type of system. Recommendation: The TCC agrees with the committee action to delete Committee Meeting Action: Hold this section, but disagrees with the committee substantiation. Committee Statement: This is a significant change that has not had the Replace substantiation with "This requirement is addressed in 6.6.2(7)." benefit of public review. The committee agrees that there is potentially Substantiation: This is a direction from the Technical Correlating merit to the suggestion, and a Task Group has been formed to study the Committee on Boiler Combustion System Hazards in accordance with issue for the next revision. In the past, the committee considered the 4.2 and -4. of the Regulations Governing Committee Projects. submitter's concern as addressed in 6.7.5.2..(0) and Comment 85-62 Committee Meeting Action: Accept (Log #62). Section 6.7.5.2..(0) and the text added in Comment 85-62 Number Eligible to Vote: 31 (Log #62) allow circulation by opening the header safety shut-off valve. It Ballot Results: Affirmative: 0 will be reconsidered. Ballot Not Returned: Seroka, G. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

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____________________________________________________________ 85-64 Log #64 BCS-MBB Final Action: Hold (6.7.5.2.1.3(6)) ____________________________________________________________ Submitter: Charles Moore, Hull, MA Comment on Proposal No: 85-8 Recommendation: Revise text to read: 6.7.5.2..(6) The main fuel control valve shall be closed open and the main safety shutoff valve(s) shall be open, but only after the requirements of 6.7.5.2.9 for leak test requirements and 6.4.2..4 for permissive conditions in the unit purge system have been satisfied. Substantiation: In the design of most fuel oil systems if you close either of the valves, you will not get any warm up oil flow. This is unless a special circulation valve has been provided. There are many stations where this circulation valve is not provided as it is viewed and a path around the trip valve. The code should not rule out the simpler and safer design. General Comment: The fuel oil system requirements for a fuel oil warm up recirculation system design seems to conflict with each other and are confusing. In addition, they do not address the mechanically atomized delta P style of burner fuel oil supply system design where there is a continuous return flow. This return flow can be regulated, feed into a pump, etc., but generally goes to some sort of a header where an elevated pressure is present. The requirements in some of the paragraphs cannot be met with the requirements of this type of system. Committee Meeting Action: Hold Committee Statement: This is a significant change that has not had the benefit of public review. The committee agrees that there is potentially merit to the suggestion, and a Task Group has been formed to study the issue for the next revision. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

NFPA 85

____________________________________________________________ 85-67 Log #6 BCS-MBB Final Action: Accept in Principle (6.7.5.2.5.4 through 6.7.5.2.5.8) ____________________________________________________________ Submitter: Charles Moore, Hull, MA Comment on Proposal No: 85-8 Recommendation: The paragraph numbering jumps from 6.7.5.2.5.4 through 6.7.5.2.5.8. Substantiation: What happened to 6.7.5.2.5.5, 6.7.5.2.5.6, and 6.7.5.2.5.7? Add paragraphs back or renumber. Committee Meeting Action: Accept in Principle . Insert a new 6.7.5.2.5.5 and renumber ROP text of 6.7.5.2.5.8 to be 6.7.5.2.5.6, modified as follows: 6.7.5.2.5.5 Following a master fuel trip (MFT), the unit shall be purged in accordance with 6.4.2..4. 6.7.5.2.5.8 6.7.5.2.5.6 Following the completion of a unit purge, one burner (or group of burners) at a time shall be permitted to be placed in service in a manner specified in 6.7.5.2... (A) Fuel oil passages then shall be permitted to be cleared into the furnace from each burner when the igniter has been established for that burner. (B) After each burner is cleared, its igniter shall be permitted to be shut down. 2. Add a new 6.6.5.2.5.5 to read as follows: 6.6.5.2.5.5 Following an MFT, the unit shall be purged in accordance with 6.4.2..4. . Insert a new 6.8.5.2.5.5, renumbering subsequent sections as follows: 6.8.5.2.5.5 Following an MFT, the unit shall be purged in accordance with 6.4.2..4. Committee Statement: The submitter is correct, and the numbering ____________________________________________________________ was corrected. A new section was added to complete the sequence of operations following a master fuel trip. The same requirements were added 85-65 Log #65 BCS-MBB Final Action: Hold for oil, gas and coal. (6.7.5.2.1.3(7)) ____________________________________________________________ Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Submitter: Charles Moore, Hull, MA Ballot Not Returned: Seroka, G. Comment on Proposal No: 85- Recommendation: Revise text to read: ____________________________________________________________ 6.7.5.2..(7) It shall be determined that the main fuel control valve is 85-68 Log #55 BCS-MBB Final Action: Accept in Principle closed (unless opening is required for the fuel warm up system) and the (6.8.5.2.5.2(B)1) following procedures performed: ____________________________________________________________ Substantiation: This permits the main fuel oil valve to be open for Submitter: John P. O'Rourke, ALSTOM Power Inc. recirculation. General Comment: The fuel oil system requirements for a fuel oil warm Comment on Proposal No: 85-75 Recommendation: Revise 6.8.5.2.5.2(B) to read: up recirculation system design seems to conflict with each other and are Total airflow decreases 5 percent full load airflow below the minimum confusing. In addition, they do not address the mechanically atomized purge rate airflow as established by the boiler designer and in accordance delta P style of burner fuel oil supply system design where there is a with 6.4.2..4.4.. continuous return flow. This return flow can be regulated, feed into a pump, etc., but generally goes to some sort of a header where an elevated Substantiation: The revised text clarifies that the requirement of the pressure is present. The requirements in some of the paragraphs cannot be Mandatory Airflow trip should be based on the minimum design airflow and not related to the airflow rate at which the unit was purged. met with the requirements of this type of system. Committee Meeting Action: Accept in Principle Committee Meeting Action: Hold Revise ROP text of 6.8.5.2.5.2(B) as shown in Proposal 85-75 (Log Committee Statement: This is a significant change that has not had the #96) to read: benefit of public review. The committee agrees that there is potentially Total airflow decreases below the minimum purge rate airflow as merit to the suggestion, and a Task Group has been formed to study the required in 6.4.2..4.4. by 5% design full load airflow. issue for the next revision. Committee Statement: The section reference was changed as a result of Number Eligible to Vote: 31 Comment 85-5 (Log #50). Editorial changes were made for clarity. The Ballot Results: Affirmative: 0 submitter's intent was met. Ballot Not Returned: Seroka, G. Number Eligible to Vote: 31 ____________________________________________________________ Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G. 85-66 Log #54 BCS-MBB Final Action: Accept in Principle (6.7.5.2.5.2(B)2) ____________________________________________________________ ____________________________________________________________ 85-69 Log #CC0 BCS-FBB Final Action: Hold Submitter: John P. O'Rourke, ALSTOM Power Inc. (7.4.1.1.2) Comment on Proposal No: 85-75 ____________________________________________________________ Recommendation: Revise 6.7.5.2.5.2(B)2 to read: Submitter: Technical Committee on Fluidized Bed Boilers Total airflow decreases 5 percent full load airflow below the minimum Comment on Proposal No: 85- purge rate airflow as established by the boiler designer and in accordance Recommendation: Revise as follows: with 6.4.2..4.4.. 7.4...2 The minimum transient design pressure (see 7.5.) shall meet Substantiation: The revised text clarifies that the requirement of the both of the following: Mandatory Airflow trip should be based on the minimum design airflow () Whichever is greater, .67 times the predicted operating pressure of and not related to the airflow rate at which the unit was purged. the component or + 8.7 kPa (+ 5 in. w.g., but shall not be in excess of the Committee Meeting Action: Accept in Principle maximum head capability of the air supply fan at ambient temperature. Revise ROP text in 6.7.5.2.5.2(B)2 as shown in Proposal 85-75 (Log (2)* The maximum head capability of the induced draft fan at ambient #96) to read: temperature , but not more negative than ­ 8.7 kPa (-5 in. w.g.). Total airflow decreases below the minimum purge rate airflow as Substantiation: Adding arbitrary caps or limits on what should be worst required in 6.4.2..4.4. by 5% design full load airflow. case conditions should not be done. Also, this wording is consistent with Committee Statement: The section reference was changed as a result of 4.6.. Comment 85-5 (Log #50). Editorial changes were made for clarity. The Committee Meeting Action: Hold submitter's intent was met. Committee Statement: This material has not had the benefit of public Number Eligible to Vote: 31 review, therefore is being held for further revision.

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Number Eligible to Vote: 11 Ballot Results: Affirmative: 9 Ballot Not Returned: 2 Chelian, P., Lueckenotte, D.

NFPA 85

____________________________________________________________ 85-7 Log #0 BCS-HRS Final Action: Accept in Principle (8.10.1.4, 8.10.1.5, and A.8.10.1.4 (New) ) ____________________________________________________________ ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion 85-70 Log #CC BCS-FBB Final Action: Hold System Hazards (7.4.1.1.2) Comment on Proposal No: 85-27 ____________________________________________________________ Recommendation: The TCC directs that the following be a comment to Submitter: Technical Committee on Fluidized Bed Boilers the BCS-HRS Committee: Consider adding explanatory annex material to Comment on Proposal No: 85- 8.0..5 to explain why it is generally acceptable for control of fuel input Recommendation: Revise as follows: to be automatic without automatic control of fuel/air ratio. 7.4...2 The minimum transient design pressure (see 7.5.) shall meet Substantiation: Fuel/air ratio is normally a critical safeguard to prevent both of the following: explosions and an explanation as to why this is not critical for fresh air Substantiation: The pressures described in 7.4...2 are short duration firing of an HRSG is warranted. events and as such are applied as transients, which follow different Committee Meeting Action: Accept in Principle allowable stresses and applied margins than continuous pressures. Also, See committee action and statement on Comment 85-79 (Log #48). this wording is consistent with 4.6.. Committee Statement: See committee action and statement on Comment Committee Meeting Action: Hold 85-79 (Log #48). Committee Statement: This material has not had the benefit of public Number Eligible to Vote: 17 review, therefore is being held for further revision. Ballot Results: Affirmative: 6 Number Eligible to Vote: 11 Ballot Not Returned: Lefton, S. Ballot Results: Affirmative: 9 Ballot Not Returned: 2 Chelian, P., Lueckenotte, D. ____________________________________________________________ 85-74 Log #5 BCS-FUN Final Action: Accept in Principle ____________________________________________________________ (A.4.5.5) 85-7 Log #29 BCS-FBB Final Action: Accept ____________________________________________________________ (7.4.3.2.11) Submitter: Michael A. Walz, Burns & McDonnell ____________________________________________________________ Comment on Proposal No: 85-75 TCC Action: The TCC wished to clarify that the submitter's original Recommendation: Relocate and renumber A.4.5.5 to become proposal will be now accepted as originally submitted in Proposal 85- A.6.4.2..4.4 and reword as follows: 115 (Log #70). A.4.5.5 A.6.4.2..4.4 The minimum purge rate air flow and minimum Submitter: Technical Correlating Committee on Boiler Combustion operating air flow value (25 percent for most boilers) is based on historical System Hazards experience in reducing the occurrence of explosions. This value is Comment on Proposal No: 85-5 based on safety considerations and could be in conflict with economic Recommendation: The TCC submits the following comment to BCSconsiderations or emission limits. Factors considered in establishing the FBB: minimum airflow include the following: Consideration should be given to reconsidering their action on this () Removal of combustibles and products of combustion proposal. (2) Cooling requirements for burners that are out of service Substantiation: The TCC notes that Proposal 85-5 (Log #67), which was () Accuracy of total burner airflow, individual burner airflow, and other submitted including similar material for Chapter 4, was rejected by the airflow measurements Fundamentals TC, and similar material submitted as Proposal 85-99 (Log (4) Accuracy of burner air and main burner fuel distribution #68) for BCS-MBB was accepted in principle in part in Chapter 6. (5) Effect of thermal and pressure transients within the combustion Committee Meeting Action: Accept chamber on the air and main burner fuel flows Complete the action in Proposal 85-5 (Log #70). (6) Impact of air leakage Committee Statement: The committee believes it should be consistent for (7) Wear and deterioration of the unit and equipment the requirements with gas. (8) Operational and control margins Number Eligible to Vote: 11 The asterisk indicating annex material should be added to the paragraph Ballot Results: Affirmative: 9 number of 6.4.2..4.4. Ballot Not Returned: 2 Chelian, P., Lueckenotte, D. In addition, the Technical Correlating Committee is requested to consider adding a reference to paragraph 7.6.2.2.6(A) saying "(See Annex ____________________________________________________________ for paragraph 6.4.2..4.4.)" 85-72 Log #CC2 BCS-FBB Final Action: Hold Substantiation: The information contained in this annex is not directly (7.5.1(A)) related to the paragraph to which the annex is attached. A more logical ____________________________________________________________ association is with 6.4.2..4.4 which is titled Purge Rate Air Flow. This is Submitter: Technical Committee on Fluidized Bed Boilers a clarification only, not a change in content. Comment on Proposal No: 85- Committee Meeting Action: Accept in Principle Recommendation: Modify 7.5.(A) as follows: The annex item will be added with one modification and will be (A) The boiler enclosure, the air system and the flue gas removal system assigned to 4.6.5.2. as follows: shall be designed so that the maximum head capability of the forced draft A.6.4.2..4.4 A.4.6.5.2. The minimum purge rate air flow and fans and induced draft fans within these systems, with ambient air, does minimum operating air flow value (25 percent for most boilers) is based not exceed the continuous design pressure of these systems. The design on historical... shall include the following: Committee Statement: The location is more suited to the Fundamentals () This design pressure is defined the same as, and shall be in chapter instead of just the MBB chapter since it is applicable to more than accordance with, the wind and seismic stresses of ASCE 7, Minimum just BCS-MBB. The "(25 percent for most boilers)" was deleted because Design Loads for Buildings and Other Structures. those percentages are covered in the respective chapters. It is suggested (2) The appropriate design or the steel members shall be in accordance that the BCS-MBB TC may wish to refer to this annex. with ASIC ASD,...., or AISC LRFD.........Buildings. Number Eligible to Vote: 18 Substantiation: The intent of 7.5. is to assure the fan pressure is treated Ballot Results: Affirmative: 6 as a continuous load (not as a transient load) versus 7.5. (B) forces the Ballot Not Returned: 2 Cowdrick, D., Kleen, R. transient pressure by a controls tripping function. The reference to wind and seismic stresses of ASCE 7 is not applicable to continuous loads. ____________________________________________________________ AISC does not contain rules for elevated temperature designs. Therefore, 85-75 Log # BCS-MBB Final Action: Reject the "appropriate design of attachment (warm or hot) steel members" can (A.6.4.2.3.4.4.2) not be designed according to AISC. ____________________________________________________________ Committee Meeting Action: Hold TCC Action: The TCC notes that the submitter's concern is addressed Committee Statement: This material has not had the benefit of public in Comment 85-76 (Log #51). review and is held for consideration during the next cycle. Submitter: Bill Bass, Forney Corp. Number Eligible to Vote: 11 Comment on Proposal No: 85-8 Ballot Results: Affirmative: 9 Recommendation: Delete this entire paragraph. Ballot Not Returned: 2 Chelian, P., Lueckenotte, D. Substantiation: I feel that few, if any, burner management systems are designed to generate a master fuel trip at 5 percent below whatever airflow rate the boiler is purged at during any given boiler purge. This would require the BMS to enforce an exact fixed purge rate, or to calculate a new trip setpoint and new low air flow limit for a variable purge rate. Systems are designed to ensure the purge is above a certain minimum

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and, in the case of coal, below 40 percent. If the minimum is 25 percent, there is nothing to prevent an operator from purging at greater than 25 percent if he chooses. There is an existing requirement that lighting the first burner must be done at the current purge rate. I have no problem with that. But the trip setpoint should not have to change accordingly. Rather it should remain at 5 percent below the minimum purge rate. While there is certainly nothing unsafe about this statement, I think it adds information that goes against long established safe operating history. If it is safe to fire at 0 percent after purging at 0 percent, it should be safe to fire the same boiler at 0 percent after purging at 5 percent. This paragraph should be removed until a task group has thoroughly addressed this issue for the next edition. Committee Meeting Action: Reject Committee Statement: See committee action and statement on Comment on 85-76 (Log #5). Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

NFPA 85

Committee Statement: It is noted that the new number would be A.6.2.2..4.4. and other modified text [per Comment 85-5 (Log #50)]. The submitter's intent was met. The caution for the operator was added. Number Eligible to Vote: 31 Ballot Results: Affirmative: 0 Ballot Not Returned: Seroka, G.

____________________________________________________________ 85-77 Log #4 BCS-MBB Final Action: Accept (A.6.5.1.3.2.2) ____________________________________________________________ Submitter: Bill Bass, Forney Corp. Comment on Proposal No: 85-8 Recommendation: Add a - sign (negative sign) in front of all numbers in this paragraph for clarity. Substantiation: Words such as "more negative than" may imply a negative number, but there should be a negative sign on the number to leave no doubt. And all numbers in the corresponding 6.5...2.2 have negative signs in front of the numbers. ____________________________________________________________ Committee Meeting Action: Accept 85-76 Log #5 BCS-MBB Final Action: Accept in Principle Number Eligible to Vote: 31 (A.6.4.2.3.4.4.2) Ballot Results: Affirmative: 0 ____________________________________________________________ Ballot Not Returned: Seroka, G. Submitter: John P. O'Rourke, ALSTOM Power Inc. Comment on Proposal No: 85-75 ____________________________________________________________ Recommendation: Delete the following text: 85-78 Log #67 BCS-MBB Final Action: Hold ...The designer is cautioned, however,....required at 0 percent airflow. (Figure A.6.7.5.1.4(c) and A.6.7.5.1.4(d)) Substantiation: The deleted text adds confusion as to the requirement ____________________________________________________________ of the Mandatory Airflow trip that shall occur when unit airflow falls 5 Submitter: Charles Moore, Hull, MA percent below the "minimum" purge rate airflow. The deleted text implies Comment on Proposal No: 85-8 that the trip is based on the rate of airflow of which the unit was last Recommendation: Revise Figure A.6.7.5..4(c) and A.6.7.5..4(d) as purged. This interpretation that the trip tracks the rate at which the unit follows: was last purged is not consistent with industry practice. Substantiation: Safety shutoff valves should be shown in the return line Committee Meeting Action: Accept in Principle to positively prevent fuel flow to the burner header. In many designs Modify ROP text in 6.4.2..4.4.2 as shown in Proposal 85-75 (Log #96) this line connects to the fuel oil system that is or could be at a positive as follows: pressure. A.6.4.2..4.4.2 Fuel gas and fuel oil fired units are permitted to have Committee Meeting Action: Hold purge rate air flows above 40 percent. The designer is cautioned, however, Committee Statement: This is a significant change that has not had the that a mandatory automatic master fuel trip is required by subparagraphs benefit of public review. The committee agrees that there is potentially 6.6.5.2.5.2, 6.7.5.6.2, 6.7.5.2.5.2 and 6.8.5.2.5.2 at any airflow five merit to the suggestion, and a Task Group has been formed to study the percent or more less below minimum purge rate air flow for any fuel. For issue for the next revision. example, if minimum purge rate air flow is established by the designer at Number Eligible to Vote: 31 5 percent, the furnace will not be permitted to be operated with airflow Ballot Results: Affirmative: 0 below 5 percent, and a mandatory automatic master fuel trip is required Ballot Not Returned: Seroka, G. at 0 percent air flow. The operator is cautioned that purging at higher airflow rates than minimum purge airflow requires the higher airflow be maintained for light-off.

FIGURE A.6.7.5.1.4(c) Typical mechanical atomizing main oil burner system.

85-20

Report on Comments F2006 -- Copyright, NFPA

NFPA 85

FIGURE A.6.7.5.1.4(d) Typical stream or air atomizing main oil burner system.

____________________________________________________________ 85-79 Log #48 BCS-HRS Final Action: Accept in Principle (A.8.10.1.5 (New) ) ____________________________________________________________ Submitter: Michael C. Polagye, FM Global Comment on Proposal No: 85-27 Recommendation: Add Annex material to 8.0.5 as follows: A.8.10.15 The low fuel flow compared to the high air flow required to prevent tube and tube fin overheating when operating in a fresh air firing mode precludes the development of an explosive mixture in the HRSG and automatic fuel air ratio control is not required even with fuel flow in automatic. Substantiation: This addition provides explanatory material as to why automatic fuel air ratio control is not critical to safe operation of an HRSG operated in a fresh air firing mode, even with fuel flow in automatic. This comment addresses the concern raised by the TCC regarding 8.0..5. Committee Meeting Action: Accept in Principle Add new Annex material to ROP Section 8.0..5 as follows: A.8.10.1.5 High air flow is required to ensure proper air flow distribution through the HRSG and low fuel flow compared to the high air flow is required to prevent tube and tube fin overheating when operating in a fresh air firing mode. This precludes the development of an explosive mixture in the HRSG and automatic fuel air ratio control is not required even with fuel flow in automatic. Committee Statement: Changes were made for editorial clarity and to provide additional information as to why proportionally higher air flow is required as compared to a conventional boiler. Number Eligible to Vote: 17 Ballot Results: Affirmative: 6 Ballot Not Returned: Lefton, S.

____________________________________________________________ 85-80 Log # BCS-STO Final Action: Accept (Annex F) ____________________________________________________________ Submitter: Technical Correlating Committee on Boiler Combustion System Hazards Comment on Proposal No: 85-5 Recommendation: Create a committee comment as follows: Consider changing the title of Annex F from the proposed "Fuels for Stokers and Other Boilers" to "Solid Fuel Firing in Stokers". Substantiation: Although these fuels are used in other boilers, this annex specifically addresses solid fuel combustion in stokers, and should be reflected in the title. Committee Meeting Action: Accept Number Eligible to Vote: 4 Ballot Results: Affirmative: Ballot Not Returned: Cantrell, J.

85-2

FORM FOR FILING NOTICE OF INTENT TO MAKE A MOTION (NITMAM) AT AN ASSOCIATION TECHNICAL MEETING 2006 FALL REVISION CYCLE FINAL DATE FOR RECEIPT OF NITMAM: 5:00 pm EST, October 20, 2006

If you have questions about filling out or filing the NITMAM, please contact the Codes and Standards Administration at 617-984-7249 For further information on the Codes- and Standards-Making Process, see the NFPA website (www.nfpa.org) Date________________Name________________________________________________Tel. No. Company or Affiliation __________________________________________________Email Address Street Address_________________________________City________________________State______Zip Log #: Date Rec'd:

FOR OFFICE USE ONLY

_________________

1. (a) NFPA Document (include Number and Title)_______________________________________________________________ (b) Proposal or Comment Number____________________ (c) Section/Paragraph _____________________________________ 2. Motion to be made. Please check one: (See also 4-6 of the Regulations Governing Committee Projects)

(a) Proposal _(1) Accept. __ (3) Accept as modified by the TC.

(2) Accept an Identifiable Part.* (4) Accept an Identifiable Part as modified by TC.*

(b) Comment (1) Accept. (4) Accept an Identifiable Part as modified by TC.*

(2) Accept an Identifiable Part.* __ (5) Reject

(3) Accept as modified by the TC. (6) Reject an Identifiable Part.*

(c) Return Technical Committee Report for Further Study (2) Return a portion of a Report in the form of a proposal and related comment(s). _____ (1) Return entire Report. _____ (3) Return a portion of a Report in the form of identifiable part(s) of a proposal and related comments (s). (Identify the specific portion of the proposal and the related comments below)* * Clearly identify the Identifiable Part(s) indicated above (use separate sheet if required). ___________________________________________________________________________________________________________ ___________________________________________________________________________________________________________ __________________________ 3. I am entitled to make this motion in accordance with 4.6.8 of the Regulations Governing Committee Projects, as follows: (check (a), (b), or (c). (a)____ This motion may be made by the original submitter or their designated representative, and I am the (if you check (a) indicate one of the following): ___I am the Original submitter, or ___I am the submitter's designated representative (attach written authorization signed by the original submitter), or ___ I am an Organizational Member delegate permitted to represent the submitter on behalf of the Organization Member in accordance with 4-6.5 (c). (b)____This motion may be made by a Technical Committee Member and I am a Member of the responsible Technical Committee. (c)____This motion may be made by anyone.

(Form continued on next page)

NITMAM form (continued) 4. Comments or Clarification (optional): This NITMAM will be reviewed by a Motions Committee. In addition to determining whether your Amending Motion is proper, the Committee may take other actions as described in 2.3 of the Technical Meeting Convention Rules as follows: Restating and Grouping of Motions. Upon request or on its own initiative, and in consultation with the mover(s), the Motions Committee may: (a) restate an Amending Motion to facilitate the making of a proper motion or to clarify the intent of the mover; and (b) group Amending Motions that are dependent on one another into a single Amending Motion. Dependent motions are motions that the mover(s) wish to be considered by the assembly and voted on as single up or down package. In addition to the foregoing, the Motions Committee may take such other actions or make such other recommendations as will facilitate the fair and efficient consideration of amending. The NFPA Staff may contact you to clarify your motion or to consult on the permitted actions in 2.3. If you have any comments, suggestions, or requests of the Motions Committee as it reviews your NITMAM and considers actions permitted in 2.3, please provide them below. (Use additional sheet if necessary):

__________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ _________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________ __________________________________________________________________________________________________________________________

Name (please print):_____________________________________________________________________

Signature (Required)_____________________________________________________________________

(Note: This NITMAM will be reviewed, and if proper, your Amending Motion will be certified in accordance with the Technical Meeting Convention Rules and posted on the NFPA website by November 17, 2006. Documents that have Certified Amending Motions will be considered at the June 2007 Annual Meeting Technical Committee Report. In order to have your Certified Amending Motion considered at that meeting, you must appear, sign in, and make the motion as prescribed in the Convention Rules).

PLEASE USE A SEPARATE NITMAM FORM FOR EACH AMENDING MOTION YOU WISH TO MAKE, Mail to: Secretary, Standards Council, National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471 NFPA Fax: (617) 770-3500

Sequence of Events Leading to Issuance of an NFPA Committee Document

Step 1 Call for Proposals Proposed new Document or new edition of an existing Document is entered into one of two yearly revision cycles, and a Call for Proposals is published. Step 2 Report on Proposals (ROP) Committee meets to act on Proposals, to develop its own Proposals, and to prepare its Report.

Committee votes by written ballot on Proposals. If two-thirds approve, Report goes forward. Lacking two-thirds approval, Report returns to Committee. Step 3 Report on Proposals (ROP) is published for public review and comment. Report on Comments (ROC) Committee meets to act on Public Comments to develop its own Comments, and to prepare its report.

Committee votes by written ballot on Comments. If two-thirds approve, Reports goes forward. Lacking two-thirds approval, Report returns to Committee. Step 4 Report on Comments (ROC) is published for public review. Technical Report Session

"Notices of intent to make a motion" are filed, are reviewed, and valid motions are certified for presentation at the Technical Report Session. ("Consent Documents" that have no certified motions bypass the Technical Report Session and proceed to the Standards Council for issuance.) NFPA membership meets each June at the Annual Meeting Technical Report Session and acts on Technical Committee Reports (ROP and ROC) for Documents with "certified amending motions." Step 5 Committee(s) vote on any amendments to Report approved at NFPA Annual Membership Meeting. Standards Council Issuance

Notification of intent to file an appeal to the Standards Council on Association action must be filed within 20 days of the NFPA Annual Membership Meeting. Standards Council decides, based on all evidence, whether or not to issue Document or to take other action, including hearing any appeals.

I

The Technical Report Session of the NFPA Annual Meeting

The process of public input and review does not end with the publication of the ROP and ROC. Following the completion of the Proposal and Comment periods, there is yet a further opportunity for debate and discussion through the Technical Report Sessions that take place at the NFPA Annual Meeting. The Technical Report Session provides an opportunity for the final Technical Committee Report (i.e., the ROP and ROC) on each proposed new or revised code or standard to be presented to the NFPA membership for the debate and consideration of motions to amend the Report. The specific rules for the types of motions that can be made and who can make them are set forth in NFPA's rules which should always be consulted by those wishing to bring an issue before the membership at a Technical Report Session. The following presents some of the main features of how a Report is handled. What Amending Motions are Allowed. The Technical Committee Reports contain many Proposals and Comments that the Technical Committee has rejected or revised in whole or in part. Actions of the Technical Committee published in the ROP may also eventually be rejected or revised by the Technical Committee during the development of its ROC. The motions allowed by NFPA rules provide the opportunity to propose amendments to the text of a proposed code or standard based on these published Proposals, Comments and Committee actions. Thus, the list of allowable motions include motions to accept Proposals and Comments in whole or in part as submitted or as modified by a Technical Committee action. Motions are also available to reject an accepted Comment in whole or part. In addition, Motions can be made to return an entire Technical Committee Report or a portion of the Report to the Technical Committee for further study. The NFPA Annual Meeting, also known as the World SafetyConference and Exposition®, takes place in June of each year. A second Fall membership meeting was discontinued in 2004, so the NFPA Technical Report Session now runs once each yearat the Annual Meeting in June. Who Can Make Amending Motions. Those authorized to make these motions is also regulated by NFPA rules. In many cases, the maker of the motion is limited by NFPA rules to the original submitter of the Proposal or Comment or his or her duly authorized representative. In other cases, such as a Motion to Reject an accepted Comment, or to Return a Technical Committee Report or a portion of a Technical Committee Report for Further Study, anyone can make these motions. For a complete explanation, NFPA rules should be consulted. The filing of a Notice of Intent to Make a Motion. Before making an allowable motion at a Technical Report Session, the intended maker of the motion must file, in advance of the session, and within the published deadline, a Notice of Intent to Make a Motion. A Motions Committee appointed by the Standards Council then reviews all notices and certifies all amending motions that are proper. The Motions Committee can also, in consultation with the makers of the motions, clarify the intent of the motions and, in certain circumstances, combine motions that are dependent on each other together so that they can be made in one single motion. A Motions Committee report is then made available in advance of the meeting listing all certified motions. Only these Certified Amending Motions, together with certain allowable Follow-Up Motions (that is, motions that have become necessary as a result of previous successful amending motions) will be allowed at the Technical Report Session. Consent Documents. Often there are codes and standards up for consideration by the membership that will be non-controversial and no proper Notices of Intent to Make a Motion will be filed. These "Consent Documents" will bypass the Technical Report Session and head straight to the Standards Council for issuance. The remaining Documents are then forwarded to the Technical Report Session for consideration of the NFPA membership. Important Note: The filing of a Notice of Intent to Make a Motion is a new requirement that takes effect beginning with those Documents scheduled for the Fall 2005 revision cycle that reports to the June 2006 Annual Meeting Technical Report Session. The filing of a Notice of Intent to Make a Motion will not, therefore, be required in order to make a motion at the June 2005 Annual Meeting Technical Report Session. For updates on the transition to the new Notice requirement and related new rules effective for the Fall 2005 revision cycle and the June 2006 Annual Meeting, check the NFPA website.

II

Action on Motions at the Technical Report Session. In order to actually make a Certified Amending Motion at the Technical Report Session, the maker of the motion must sign in at least an hour before the session begins. In this way a final list of motions can be set in advance of the session. At the session, each proposed Document up for consideration is presented by a motion to adopt the Technical Committee Report on the Document. Following each such motion, the presiding officer in charge of the session opens the floor to motions on the Document from the final list of Certified Amending Motions followed by any permissible Follow-Up Motions. Debate and voting on each motion proceeds in accordance with NFPA rules. NFPA membership is not required in order to make or speak to a motion, but voting is limited to NFPA members who have joined at least 180 days prior to the session and have registered for the meeting. At the close of debate on each motion, voting takes place, and the motion requires a majority vote to carry. In order to amend a Technical Committee Report, successful amending motions must be confirmed by the responsible Technical Committee, which conducts a written ballot on all successful amending motions following the meeting and prior to the Document being forwarded to the Standards Council for issuance. Standards Council Issuance One of the primary responsibilities of the NFPA Standards Council, as the overseer of the NFPA codes and standards development process, is to act as the official issuer of all NFPA codes and standards. When it convenes to issue NFPA documents it also hears any appeals related to the Document. Appeals are an important part of assuring that all NFPA rules have been followed and that due process and fairness have been upheld throughout the codes and standards development process. The Council considers appeals both in writing and through the conduct of hearings at which all interested parties can participate. It decides appeals based on the entire record of the process as well as all submissions on the appeal. After deciding all appeals related to a Document before it, the Council, if appropriate, proceeds to issue the Document as an official NFPA code or standard. Subject only to limited review by the NFPA Board of Directors, the Decision of the Standards Council is final, and the new NFPA code or standard becomes effective twenty days after Standards Council issuance. The illustration on page 9 provides an overview of the entire process, which takes approximately two full years to complete.

III

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