-
Technical Committee on Heat Recovery Steam Generators and Other
Combustion Turbine Exhaust
Systems
AGENDA
Entergy Corporation 639 Loyola Avenue
New Orleans, LA 70113 February 28 – March 1, 2013
1. Chair’s welcome, call to order, and opening remarks at 8:30
a.m. 2. Self-Introduction of Committee Members and Guests 3.
Approval of Minutes from the May 23-25, 2013 Pre-First Draft
Meeting in Birmingham,
AL. See www.nfpa.org/85next to review. 4. Staff Liaison Report
A. Committee membership update (For the period March 5, 2010 – Feb.
5, 2013)
Name Category Change Date Michael Mulherin M (Alt. to G. Gaetke)
Resign 5/25/2010 John Stevens M (Alt. to S. Graf) Resign 4/25/2011
Steven Graf M (Principal) Change from Alt to P 8/10/2010 Philip
Souers M (Alt. to M. Cancelado) Change from P to Alt 10/22/2010
Miguel Cancelado M (Principal) Change from Alt to P 10/22/2011 Todd
Young U (Principal) Resign 7/18/2011 Joshua Kelly M (Alt to A.
Beaty) Resign 12/12/2012 Harley Ross M (Alt to R. Kleen) Appoint
8/2/2010 David Paul Cannon SE (Principal) Appoint 3/1/2011 George
Pyros M (Principal) Appoint 3/1/2011 Dwight Hyche I (Principal)
Appoint 3/1/2011 David Dexter M (Alt to G. Gaetke) Appoint 8/9/2011
Roy Reeves M (Principal) Appoint 8/9/2011 John Burney U (Principal)
Appoint 10/18/2011 Fedja Drndarevic E (Principal) Appoint
10/18/2011 Bruce Wertz SE (Principal) Appoint 8/9/2012 Adam
Kuentzler M (Alt to S. Meierotto) Appoint 8/9/2012 David King U
(Principal) Appoint 8/9/2012
(Total Voting Members – 27; M=30%, SE=33%, U=22%; I=11%; E = 4%)
B. Revision Cycle Review and timeline (Attachment A) 5. Old
Business (Also See Pre-FD Meeting Actions, Attachment D) A. Fresh
Air Firing. The committee established a task group in the Pre-FD
meeting
to further develop coverage on fresh air firing. The task group
members are: M. Polagye (chair); M. Fry, S. Meierotto, I.
Yarinovsky, and J. Walawender.
1
http://www.nfpa.org/85next�
-
B. Consistency with Fundamentals. A task group was established
in the Pre-FD meeting to identify issues in chapter 8 that may be
redundant, inconsistent, or incompatible with chapter 4. The task
group members are: J. Burney; G. Gaetke; D. Hinshaw; and R.
Reeves.
C. Vent Line Sizing for Triple Block/Double Bleed Systems. The
committee established a task group in the pre-FD meeting to review
relevant standards regarding sizing the downstream vent valve in a
triple block/double bleed system to determine if coverage can be
added to chapter 8 that would permit alternate sizing from the
requirement of chapter 4. The task group members are: R. Kleen
(chair); P. Cannon; D. Hyche; J. Walawender.
D. Purging of HRSG/Bypass Stack. The committee briefly discussed
ambiguity in the coverage on purging of the HRSG where a bypass
stack is also present. Mr. Kleen volunteered to develop specific
public input to clarify.
E. Pressurizing Air in Double Block and Bleed Systems. The
committee will continue to review this issue for the First Draft
meeting.
6. New Business A. Review BCS-FUN actions. The committee members
are asked to review the
actions of the Fundamentals committee (sent under separate
cover) and bring forward any items warranting further
dicussion.
B. Create First Revision of Chapter 6. The committee should
review the Public Input (Attachment B) and revise chapter 6 of NFPA
85 as appropriate.
C. Request from I. Yarinovsky. (Attachment C) 7. Other Items? 8.
Date/Location of Next Meeting. The Second Draft meeting must take
place between
Nov. 15, 2013 and January 24, 2014. The BCS-FUN meeting is
tentatively scheduled for Dec 4-5, 2013 in Atlanta, GA.
9. Adjournment.
2
-
Attachment A: Fall 2014 Revision Cycle
3
-
Process Stage Process Step
Dates for TCDates for TC with CC
Public Input Closing Date* 1/4/2013
1/4/2013Final date for TC First Draft Meeting
6/14/2013
3/15/2013Posting of First Draft and TC Ballot
8/2/2013
4/26/2013Final date for Receipt of TC First Draft ballot
8/23/2013
5/17/2013Final date for Receipt of TC First Draft ballot ‐ recirc
8/30/2013
5/24/2013Posting of First Draft for CC Meeting
5/31/2013Final date for CC First Draft Meeting
7/12/2013Posting of First Draft and CC Ballot
8/2/2013Final date for Receipt of CC First Draft ballot
8/23/2013Final date for Receipt of CC First Draft ballot ‐ recirc
8/30/2013Post Final First Draft for Public Comment
9/6/2013 9/6/2013
Public Comment closing date 11/15/2013
11/15/2013Final Date to Publish Notice of Consent Documents (Documents That Received No Comments)
11/22/2013 11/22/2013
Appeal Closing Date for Consent Documents (15 Days) (Documents That Received No Comments)
12/7/2013 12/7/2013
Final date for TC Second Draft Meeting
5/2/2014
1/24/2014Posting of Second Draft and TC Ballot
6/13/2014
3/7/2014Final date for Receipt of TC Second Draft Ballot
7/7/2014
3/28/2014Final date for receipt of TC Second Draft ballot ‐ recirc
7/14/2014
4/4/2014Posting of Second Draft for CC Mtg
4/11/2014Final date for CC Second Draft Meeting
5/23/2014Posting of Second Draft for CC Ballot
6/13/2014Final date for Receipt of CC Second Draft ballot
7/7/2014Final date for Receipt of CC Second Draft ballot ‐ recirc
7/14/2014Post Final Second Draft for NITMAM Review
7/18/2014 7/18/2014
Notice of Intent to Make a Motion (NITMAM) Closing Date
8/22/2014
8/22/2014Posting of Certified Amending Motions and Consent Documents
10/17/2014
10/17/2014Appeal Closing Date for Consent Documents (15 Days)
11/1/2014
11/1/2014SC Issuance Date for Consent Documents (25 Days)
11/11/2014 11/11/2014
Tech Session
Association Meeting for Documents with CAMs
6/22‐25/2015 6/22‐25/2015
Appeal Closing Date for Documents with CAMs (20 Days)
7/15/2015
7/15/2015SC Issuance Dates for Documents with CAMs
8/27/2015 8/27/2015
Comment Stage (Second Draft)
Tech Session Preparation (& Issuance)
Appeals and Issuance
2014 FALL REVISION CYCLE
Public Input Stage
(First Draft)
*Public Input Dates may vary according to documents and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab
4
-
Attachment B: Public Input
5
-
Public Input No. 196-NFPA 85-2013 [ Section No. 8.4.3.2.1.8
]
8.4.3.2.1.8 The fuel piping materials and system design shall be
in accordance with ASME B31.1, Power Piping , or ASME B31.3,
Process Piping .
Statement of Problem and Substantiation for Public Input
This requirement is redundant with 4.10.1 and does not offer
anything unique to chapter 8.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 11:58:39 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 27 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
6
-
Public Input No. 217-NFPA 85-2013 [ Section No. 8.4.3.2.3.5
]
8.4.3.2.3.5 Relief valve outlets, vents, drains, and telltales
shall be provided with piping to allow safe discharge allow for the
discharge of liquids or vapors to a location meeting the
requirements of 4.9.1 and shall be designed for the expected range
of external temperatures and protected against mechanical
damage.
Statement of Problem and Substantiation for Public Input
The objective of this suggested change is to replace "safe
discharge" as it may be unenforceable language.
Related Public Inputs for This Document
Related Input RelationshipPublic Input No. 216-NFPA 85-2013
[Section No. 6.7.3.1.2.2]
Submitter Information Verification
Submitter Full Name: Ted JablkowskiOrganization: Fives North
American CombustioSubmittal Date: Thu Jan 03 16:31:42 EST 2013
Copyright Assignment
I, Ted Jablkowski, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Ted Jablkowski, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 28 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
7
-
Public Input No. 197-NFPA 85-2013 [ Section No. 8.4.3.4.5 ]
8.4.3.4.5 The ignition transformer shall not be energized before
the HRSG enclosure Duct Burner purge is completed, and shall be
de-energized at the end of the igniter trial for the ignition
period.
Statement of Problem and Substantiation for Public Input
HRSG enclosure purge is not a defined term. There are defined
terms for “HRSG Enclosure”, “HRSG Purge”, “Duct Burner Purge” and
“Combustion Turbine Purge”. The definition for HRSG Purge is a
reference to other definitions and not a definition in itself;
therefore not a clear requirement for 8.4.3.4.5. Since this
requirement is part of 8.4.3 HRSG Fuel-Burning System, Duct Burner
Purge seems to be appropriate requirement instead of Combustion
Turbine Purge. [Note to editors: change “Aflow” to “A flow” in
3.3.118.3.]
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:01:42 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 29 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
8
-
Public Input No. 198-NFPA 85-2013 [ Section No. 8.5.4.1 ]
8.5.4.1 Expansion provision shall be made for the movement of
the duct betweenthe combustion turbine exhaust duct and the HRSG,
and HRSG enclosure and other combustion turbine exhaust
systems.
Statement of Problem and Substantiation for Public Input
By definition the combustion turbine exhaust duct is part of the
HRSG enclosure, so it is unclear of intent of original wording in
treating them as separate entities. Because the transition duct
from the combustion turbine exhaust to the HRSG is prone to thermal
expansion due to the very high thermal temperatures and is an
interface location, the original requirement may have been trying
to specifically identify this transition duct in the requirement.
The recommended wording may better define this piece in addition to
referring the user to the entire HRSG enclosure.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:05:38 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 30 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
9
-
Public Input No. 200-NFPA 85-2013 [ Sections 8.6.2, 8.6.3, 8.6.4
]
Sections 8.6.2, 8.6.3, 8.6.48.6.2 All wiring electrical
equipment and wiring shall comply with the requirements of NFPA 70,
National Electrical Code.8.6.3 All high voltage equipment shall be
marked in accordance with the requirements of NFPA 70 , National
Electrical Code .8.6.4 *Where an area is identified as a hazardous
location as defined by Article 500 of NFPA 70 , National Electrical
Code , the equipment design, the types of enclosures, and the
wiring methods shall be as specified by that code.
Statement of Problem and Substantiation for Public Input
The original paragraphs require following NFPA 70 for wiring
compliance, marking high voltage equipment, and design of hazardous
locations. There could be other electrical equipment requirements
which are not addressed. The recommended wording provides a more
encompassing requirement that includes the original intent. It also
is consistent with other chapters addressing electrical design (see
5.3.8.1 and 9.4.6.7.1). Lastly, it avoids creating a definition for
“high voltage” which is a term used, but not defined, in 8.6.3.
NFPA 70 may define “high voltage”, but HRSG TC’s application of
high voltage could be different than NFPA 70.
It may be prudent for Fundamentals TC to contain these
Electrical requirements in chapter 4 since multiple chapters are
showing redundancy. Paragraphs 8.6.2 – 8.6.4 do not appear to
contain any unique requirements for HRSGs or other combustion
turbine exhaust systems. Paragraphs 8.6.1.1, 8.6.1.2, 8.6.5 and
8.6.6 all seem to be fundamental requirements which could be of
value to all TC’s.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:14:37 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
Page 31 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
10
-
Public Input No. 202-NFPA 85-2013 [ Section No. 8.7.3.2.2.2
]
8.7.3.2.2.2 The pressure at the gas flowmeter shall be monitored
at the upstream tap if the gaseous fuel flowmeter is part of the
combustion HRSG control system and is not pressure compensated.
Statement of Problem and Substantiation for Public Input
“Combustion Control System” is a defined term which contains
phrases or concepts not applicable to Chapter 8 such as “furnace
fuel”, “air inputs”, “air-fuel ratio”. The phrase “HRSG Control
System” is a defined term that seems more applicable here.
“Combustion Control System” was used only one time in chapter 8 -
at 8.7.3.2.2.2.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:23:33 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 33 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
11
-
Public Input No. 201-NFPA 85-2013 [ Section No. 8.7.4.3 ]
8.7.4.3 Duct Burner Master Fuel Trip. For an operating duct
burner, including the start-up or shutdown sequences, a duct burner
master fuel trip shall be initiated by the following
conditions:
Low fuel pressure
Combustion turbine exhaust or fresh air (if provided) flow
across the duct burner that drops below the minimum required for
operation of the duct burner as specified by the burner
manufacturer or as proven by trial; it is permitted to infer this
flow from the operating status of the combustionturbine, fresh air
fan (if provided), and damper(s) (if provided)
position(s)Combustion turbine trip except for systems operating as
defined in 8.10.2.4
Loss of all burner flame other than during a normal duct burner
shutdown sequence
Partial loss of flame determined to create a hazardous
accumulation of unburned fuel at any burner element or zone
Loss of duct burner element(s) resulting in incorrect element
firing configuration, in accordance with 8.8.5.8.3.2
Light-off failure of first burner in multiple burner
operationFailure to prove a safety shutoff valve closed on command
to close
Closing of last individual burner safety shutoff valve other
than during a normal duct burner shutdown sequence
High fuel pressure
Low water level on high pressure section of HRSG
Loss of energy supply for boiler HRSG control, burner
management, or interlock system
Low atomizing media (if provided) supply pressure
Detection of burner management system malfunctionManual trip
[See 4.11.6 (8).]
Loss of augmented air supply where the operation of the duct
burner requires augmented air
Fresh air (if provided) transfer failure (See 8.10.2.4.)
Logic controller failure [See 4.11.6 (10) and 4.11.6 (11).]
Statement of Problem and Substantiation for Public Input
Page 34 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
12
-
Change from “boiler control” to “HRSG control” in 8.7.4.3 (12)
as shown. Definition of boiler refers to furnace which is not
representative of HRSGs. HRSG is a defined term and more fitting
than boiler. Term “boiler” used one time in chapter 8 at
8.7.4.3(12) so eliminating term in this paragraph will eliminate
“boiler” from chapter 8.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:20:46 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 35 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
13
-
Public Input No. 203-NFPA 85-2013 [ Section No. 8.7.5 ]
8.7.5 Burner management system logic shall be maintained either
in nonvolatile storage or in other memory that retains information
on the loss of system power.
Statement of Problem and Substantiation for Public Input
This paragraph is redundant with 4.11.6 (12).
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:25:31 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 36 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
14
-
Public Input No. 160-NFPA 85-2013 [ Section No. 8.8.3 ]
8.8.3 Cold Start Preparation. Preparation for starting shall
require an inspection by the owner/operator thatincludes the
following:
A unit free of foreign material and not in need of repair
A unit inspected for accumulated liquid fuel, and draining and
cleaning performed if such accumulation is present
All personnel evacuated from the unit and associated equipment
and all access and inspection doors closed
All combustion turbine fuel stop valves (or equivalent) and duct
burner and igniter safety shutoff valves proved closed by valve
position and all ignition sources de-energized Exception : Where
the igniter capacity is 1.5 MWt (5 million Btu/hr) or less, proof
of closure of igniter safety shutoff valves by means other than
valve position shall be permitted.
Gaseous fuel system vents open and venting to an outside
location that does not present a hazard; fuel lines drained of
condensate
Circulating valves open to provide and maintain liquid fuel flow
in the burner headers
Prescribed drum water levels established in natural and forced
circulation HRSGs and prescribed flow established in forced
circulationand once-through HRSGs
Burner elements and igniters positioned in accordance with
manufacturer's specification
Energy supplied to control systems and to interlocks
Meters or gauges indicating fuel header pressure to the unit
Instrumentation tested and functional
A complete functional check of the interlocks performed after an
overhaul or other interlock-related maintenance
Verification of an open flow path through the HRSG system
Statement of Problem and Substantiation for Public Input
As written, this paragraph is open to misinterpretation as to
who should do the inspection.
Jurisdictional authorities (AHJ) have for many years been
inappropriately interpreting NFPA 85 as containing in-service
inspection responsibilities for the National Board Commissioned
Boiler Inspectors employed by Authorized Inspection Agencies as
defined by the National Board document NB-369 Qualifications and
Duties for Authorized Inspection Agencies (AIAs) Performing
Inservice Inspection Activities and Qualifications for Inspectors
of Boilers and Pressure Vessels. This has caused significant legal
issues for Authorized Inspection Agencies. The proposed change is
intended to make it clear that NFPA 85 does not contain any
requirements.for in-service inspections for these agencies.
Related Public Inputs for This Document
Page 37 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
15
-
Related Input RelationshipPublic Input No. 132-NFPA 85-2013
[Section No. 3.2.2]
Submitter Information Verification
Submitter Full Name: Brian MooreOrganization: Hartford Steam
Boiler InspectiSubmittal Date: Wed Jan 02 14:38:33 EST 2013
Copyright Assignment
I, Brian Moore, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement of Problem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Brian Moore, and I agree
to be legally bound by the above Copyright Assignment and the terms
and conditions contained therein. I understand and intend that, by
checking this box, I am creating an electronic signature that will,
upon my submission of this form, have the same legal force and
effect as a handwritten signature
Page 38 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
16
-
Public Input No. 134-NFPA 85-2013 [ Section No. 8.8.4.6.1 ]
8.8.4.6.1* System 1 Gaseous Fuels. Triple block and double vent
valve arrangement in accordance with thefollowing requirements:
Fuel gas block and vent valve positions shall be continuously
monitored. If continuous monitoring is lost or any valve deviates
from its assigned position, purge credit is lost, and subsequent
start of the combustion turbine requires a combustion turbine purge
prior to light-off, in accordance with 8.8.4.2.Pressures in the two
double block and vent pipe sections shall be continuously
monitored. If continuous monitoring is lost or eitherpressure
indicates leakage, purge credit is lost, and subsequent start of
the combustion turbine requires a combustion turbine purge prior to
light-off, in accordance with 8.8.4.2.
The combustion turbine purge credit period shall not exceed 8
days (192 hours). If a combustion turbine purge in accordance with
8.8.4.2 is performed during the 8-day period, the combustion
turbine purge credit is reinitiated for an 8-day period.
If the 8-day period has been exceeded and 1) to 4) requirements
are still valid, the combustion turbine can be purged in accordance
to 8.8.4.2.1.1 and provided the CEMS (Continuous Emissions
Monitoring System) registers 0% LEL UHC at the exhaust stack outlet
during the purge, combustion turbine purge credit is reinitiated
for an 8-day period.
Statement of Problem and Substantiation for Public Input
Operators may not pay attention to the 8-day period count down
timer. If the 8-day period has been exceeded this does not
necessarily indicate that UHC has bled into the combustion turbine
combined cycle exhaust system, as the triple block and double vent
would typically provide the isolation needed. If UHC bleed through
does occur the CEMS system would indicate as such during the
combustion turbine purge process and so the combustion turbine
control system would close loop on LEL to determine if above 0%.
CEMS systems are standard equipment supplied and installed on all
combustion turbine plant exhaust systems. Here are URL links to
CEMS systems for reference:
http://www.americanecotech.com/Air_Monitoring_Equipment/Air_monitor_gas/CEMS.aspxhttp://www.ge-mcs.com/en/bently-nevada-software/performance/system-1-pems.html?tmpl=component&page=
Submitter Information Verification
* Combustion turbine normal shutdown.
* Prior to each start-up and following each normal shutdown,
block valves shall be validated for gas leak tightness via a
valve-proving system. As a minimum, the most downstream block valve
shall be valve proved during the start-up sequence, and the middle
block valve shall be valve proved during the shutdown sequence. The
most downstream block valve shall be tested only when airflow is
passing through the combustion turbine.
Page 39 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
17
-
Public Input No. 180-NFPA 85-2013 [ Section No. 8.8.4.6.3 ]
8.8.4.6.2. 3* System 3 Liquid Fuels with Pressurized Pipe
Section. Triple block and double drain valve arrangement filled
with an inert gas or air and maintained at a pressure that prevents
liquid fuel from entering the combustion turbine or duct burner in
accordance with the following requirements:
Air or inert gas shall be introduced to create and maintain a
pressurized pipe section between the middle and most downstream
block valves.
The liquid fuel block and drain valve positions shall be
continuously monitored. If continuous monitoring is lost or any
valve deviates from its assigned position, purge credit is lost and
subsequent start of the combustion turbine requires a combustion
turbine purge prior to light-off, in accordance with 8.8.4.2.
Pressures in the two double block and drain pipe sections shall
be continuously monitored. If the continuous monitoring is lost or
thepressure downstream of the middle block valve decreases to less
than 20.7 kPa (3 psid) above the upstream pressure, purge credit is
lost and subsequent start-up of the combustion turbine requires a
combustion turbine purge prior to light-off, in accordance with
8.8.4.2.
The combustion turbine purge credit period is maintained as long
as the conditions in 8.8.4.6.3 (2), (3), and (4) are met.
Provisions shall be made to ensure that fuel cannot enter the
air or inert gas supply line at any time.
8.8.4.6.3.1 An inert liquid shall be permitted to be used in
lieu of inert gas if acceptable to the original equipment
manufacturer.
Additional Proposed Changes
File Name Description ApprovedHold_NFPA85BCS-HRS_8.8.4.6.2.3.pdf
Held Comment 85-32
Statement of Problem and Substantiation for Public Input
NOTE: This public input appeared as Comment 85-32 (Log #CC504)
which was held from the F10 ROC on Proposal 85-109.The committee
modified the wording to clarify ambiguities in the text.
Submitter Information Verification
Submitter Full Name: TC on BCS-HRSOrganization: TC on Heat
Recovery Steam GeneratorsSubmittal Date: Thu Jan 03 09:59:05 EST
2013
Copyright Assignment
* Combustion turbine normal shutdown shall be completed .
Page 41 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
18
-
Public Input No. 129-NFPA 85-2012 [ New Section after
8.8.4.6.3.1 ]
8.8.4.6.4* System 4 Liquid Fuels with Liquid Level Sensing.
Triple block and double drain valve arrangement with a pipe
section that includes a vertical rise above the liquid supply level
and below the lowest combustor / duct burner nozzle in which the
liquid level is monitored so as to prevent liquid fuel from
entering the combustion turbine or duct burner in accordance with
the followingrequirements:(1)*Combustion turbine normal
shutdown.(2) A section of piping at an elevation lower than the
lowest fuel nozzle for the combustion turbine or duct burner shall
exist between the middle and most downstream block valves.(3) The
liquid fuel upstream and middle block valves, drain valves and the
vent valve positions shall be continuously monitored. If continuous
monitoring is lost or any valve deviates from its assigned
position, purge credit is lost and subsequent start of the
combustion turbine requires a combustion turbine purge prior to
light-off, in accordance with 8.8.4.2.(4)* The limit liquid fuel
level in the piping between the fuel supply and the combustor /
duct burner shall be continuously monitored. If the continuous
monitoring is lost or the liquid fuel level rises above the limit
level, purge credit is lost and subsequent start-up of the
combustion turbine requires a combustion turbine purge prior to
light-off, in accordance with 8.8.4.2.(5) The combustion turbine
purge credit period is maintained as long as the conditions in
8.8.4.6.4 (3), and (4) are met.The associated Annex A text
is:A.8.8.4.6.4 See Figure A.8.8.4.6.4. The intent of this section
is to assure the liquid fuel level in the piping between the fuel
supply and the combustor / duct burner nozzles never rises to a
height that would allow the fuel to enter the combustionturbine or
HRSG.A.8.8.4.6.4(1) The combustion turbine normal shutdown includes
sufficient postpurge airflow to satisfy the requirements of the
combustion turbine purge.A.8.8.4.6.4(4) The liquid level monitoring
required by this paragraph may be accomplished by means of a level
switch, level transmitter, pressure sensor or any other device that
provides a positive indication of liquid level within the piping
between the block valves and the fuel nozzles.
Page 43 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
19
-
Figure A.8.8.4.6.4 System 4 Liquid Fuels with Liquid Level
Sensing
Statement of Problem and Substantiation for Public Input
The current Purge Credit requirements for liquid fuel systems
are specific and do not offer significant flexibility in design.
The proposed alternative provides a simplified approach that
assures liquid fuel cannot reach with the GT combustion nozzles or
(if used) Duct Burner nozzles by virtue of having the stop valves
at a lower elevation than the nozzles and monitoring the liquid
level between the valves and the nozzles. The level monitoring,
which can take any of several approaches, serves the same function
as providing a pressure plug - a positive method of assuring fuel
cannot flow to the nozzles - allowing an unlimited purge credit
period. Additionally, the level monitoring approach is very robust
and not dependent on valve tightness to assure the safety of the
system.
Additionally; some GT liquid fuel designs include separate fuel
valves (V3 in the drawing) for each fuel nozzle. In these designs,
the requirement to monitor valve position places a monitoring
device (possibly redundant for reliability purposes) for each
valve. For a unit with 14 separate nozzles where reliability
requirements drive a redundant signal with voting (e.g. 2oo3 logic)
the system will end up with 42 separate position signals that must
be monitored and any faults resolved. The proposed approach avoids
this cost and complexity while assuring fuel cannot enter the GT of
HRSG during the Purge Credit period.
Submitter Information Verification
Submitter Full Name: Lawrence DannerOrganization: General
Electric, EnergySubmittal Date: Thu Dec 27 12:03:42 EST 2012
Copyright Assignment
I, Lawrence Danner, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement of Problem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
Page 44 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
20
-
Public Input No. 183-NFPA 85-2013 [ New Section after 8.8.7.2
]
8.8.7.2 All duct burner fuel supply vent valves shall be opened.
Renumber subsequent sections.
Additional Proposed Changes
File Name Description
ApprovedHold_NFPA85BCS-HRS_8.8.7.2_New_.pdf Held Comment 85-35
Statement of Problem and Substantiation for Public Input
NOTE: This public input appeared as Comment 85-35 (Log #CC503)
which was held from the F10 ROC on Proposal 85-109.The committee
recognizes that there is no specific requirement to open the vent
valves on
a normal duct burner shutdown. The committee believes that this
is good engineering practice.
Submitter Information Verification
Submitter Full Name: TC on BCS-HRSOrganization: TC on Heat
Recovery Steam GeneratorsSubmittal Date: Thu Jan 03 10:15:36 EST
2013
Copyright Assignment
I, TC on BCS-HRS, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am TC on BCS-HRS, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 46 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
21
-
Public Input No. 224-NFPA 85-2013 [ Section No. 8.10.2.2 ]
8.10.2.2 Each system's operating mode shall be evaluated to
ensure safe operation ensure the design operation during transfer
from combustion turbine operation to fresh air firing mode and from
fresh air firing mode to combustion turbine mode.
Statement of Problem and Substantiation for Public Input
The objective of this suggested change is to replace "safe
operation" as it may not be unenforceable language.
Related Public Inputs for This Document
Related Input RelationshipPublic Input No. 223-NFPA 85-2013
[Section No. 7.2]
Submitter Information Verification
Submitter Full Name: Ted JablkowskiOrganization: Fives North
American CombustionSubmittal Date: Thu Jan 03 16:53:08 EST 2013
Copyright Assignment
I, Ted Jablkowski, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Ted Jablkowski, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 47 of 78National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
22
-
Public Input No. 172-NFPA 85-2013 [ Section No. A.8.3.3.1 ]
A.8.3.3.1 The following factors, at minimum, should be
considered during the design evaluation:
Single versus multiple steam pressure levels
Allowable combustion turbine exhaust backpressure
Supplementary, auxiliary, or augmented firing
Combustion turbine exhaust bypass system
Corrosiveness and fouling of by-products of combustion (e.g.,
fin tube versus bare tube, metallurgy, cold-end metal
temperature)Single or multiple fuels
SCR or other environmental control systems
Heat transfer surface cleaning (during operation and shutdowns)
and inspection by the owner/operator
Freeze protection
Rapid start, operating and transients, and thermal shock
Dry operation
Protective systems
Degree of automation and complexity of control systemsOperator
interface
Overall system performance evaluation, feedback, and iteration
(expert system database consideration)
Description of start-up validation test program (reference test
cases and simulator data library where available)
Combustion turbine (purge exhaust)
Bypass stack and damper
HRSG and interconnecting ducts
Forced draft fan, induced draft fan, or discharge stack, in any
combination
Burner management system logic
Flame monitoring and tripping systems
Combustion control system
Power supplies configuration and codes
Piping system configuration and codes
Operating information
Input/output selection
Information displayed
Data transmission (noise accuracy considerations)
Page 45 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
23
-
Logic controller software and hardware considerations
Requirements for operation from a remote location
Initial control tuning
Statement of Problem and Substantiation for Public Input
As written, this paragraph is open to misinterpretation as to
who should do the inspection.
Jurisdictional authorities (AHJ) have for many years been
inappropriately interpreting NFPA 85 as containing in-service
inspection responsibilities for the National Board Commissioned
Boiler Inspectors employed by Authorized Inspection Agencies as
defined by the National Board document NB-369 Qualifications and
Duties for Authorized Inspection Agencies (AIAs) Performing
Inservice Inspection Activities and Qualifications for Inspectors
of Boilers and Pressure Vessels. This has caused significant legal
issues for Authorized Inspection Agencies. The proposed change is
intended to make it clear that NFPA 85 does not contain any
requirements.for in-service inspections for these agencies.
Related Public Inputs for This Document
Related Input RelationshipPublic Input No. 132-NFPA 85-2013
[Section No. 3.2.2]
Submitter Information Verification
Submitter Full Name: Brian MooreOrganization: Hartford Steam
Boiler InspectiSubmittal Date: Wed Jan 02 15:35:41 EST 2013
Copyright Assignment
I, Brian Moore, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement of Problem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Brian Moore, and I agree
to be legally bound by the above Copyright Assignment and the terms
and conditions contained therein. I understand and intend that, by
checking this box, I am creating an electronic signature that will,
upon my submission of this form, have the same legal force and
effect as a handwritten signature
Page 46 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
24
-
Public Input No. 215-NFPA 85-2013 [ Section No. A.8.4.3.2.2.1
]
A.8.4.3.2.2.1 Usually this can be accomplished by providing full
relieving capacity vented to a safe location. a location meeting
the requirements of 4.9.1.
Statement of Problem and Substantiation for Public Input
The objective of this suggested change is to replace "safe
location" as it is unenforceable language.
Related Public Inputs for This Document
Related Input RelationshipPublic Input No. 214-NFPA 85-2013
[Section No. 6.6.3.1.2.2]
Submitter Information Verification
Submitter Full Name: Ted JablkowskiOrganization: Fives North
American CombustioAffilliation: October 2012 email consensus of
several NFPA 85 TC members.Submittal Date: Thu Jan 03 16:17:57 EST
2013
Copyright Assignment
I, Ted Jablkowski, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement of Problem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Ted Jablkowski, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 47 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
25
-
Public Input No. 63-NFPA 85-2012 [ Section No. A.8.4.3.2.2.1
]
A.8.4.3.2.2.1 Usually this can be accomplished by providing full
relieving capacity vented to a safe location. Refer to the
information included in Section 4.9.1 as guidance regarding what
might constitute a safe location.
Statement of Problem and Substantiation for Public Input
The phrase “safe location” may not be specific enough guidance
for some individuals who might refer to this Annex material. This
change would utilize language already included in NFPA 85 to
provide more specifics related to the intent of this phrase.
Related public inputs are being submitted against sections 4.9.1,
6.6.2, 6.6.3.1.2.2, 6.6.3.1.12 and A.8.4.3.2.2.1.
Submitter Information Verification
Submitter Full Name: Dale EvelyOrganization: Southern Company
Services, IncSubmittal Date: Thu Nov 29 07:28:39 EST 2012
Copyright Assignment
I, Dale Evely, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement of Problem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I
herebywarrant that I am the author of this Public Input and that I
have full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Dale Evely, and I agree
to be legally bound by the above Copyright Assignment and the terms
and conditions contained therein. I understand and intend that, by
checking this box, I am creating an electronic signature that will,
upon my submission of this form, have the same legal force and
effect as a handwritten signature
Page 48 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
26
-
Public Input No. 199-NFPA 85-2013 [ Section No. A.8.6.4 ]
A.8.6.4 3.3.3 For guidance in determining area classification,
see NFPA 497, Recommended Practice for the Classification of
Flammable Liquids, Gases, or Vapors and of Hazardous (Classified)
Locations for Electrical Installations in Chemical Process Areas;
NFPA 499, Recommended Practice for theClassification of Combustible
Dusts and of Hazardous (Classified) Locations for Electrical
Installations in Chemical Process Areas; NFPA 70, National
Electrical Code, Article 500; and either API RP 500, Recommended
Practice for Classification of Locations for Electrical
Installations at Petroleum Facilities Classified as Class I,
Division 1 and Division 2, or API RP 505, Recommended Practice for
Classification of Locations for Electrical Installations at
Petroleum Facilities Classified as Class I, Zone 0, Zone 1, and
Zone 2.
Statement of Problem and Substantiation for Public Input
Change the Electrical Area Classification appendix reference
from A.8.6.4 to A.8.3.3.3. Paragraph 8.3.3.3 is the only
requirement for defining Electrical area classification in chapter
8. The appendix provides references for determining that
classification which seems better suited to 8.3.3.3 than 8.6.4.
Paragraph 8.6.4 addresses electrical design requirements for
hazardous locations.
This comment is the result of work by a Task Group created by
the HRSG Technical Committee to review chapters 3 & 4 for
inconsistencies or non-essential material relative to chapter
8.
Submitter Information Verification
Submitter Full Name: Gordon GaetkeOrganization: The Dow Chemical
CompanyAffilliation: NFPA 85 HRSG Technical CommitteeSubmittal
Date: Thu Jan 03 12:10:45 EST 2013
Copyright Assignment
I, Gordon Gaetke, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
By checking this box I affirm that I am Gordon Gaetke, and I
agree to be legally bound by the above Copyright Assignment and the
terms and conditions contained therein. I understand and intend
that, by checking this box, I am creating an electronic signature
that will, upon my submission of this form, have the same legal
force and effect as a handwritten signature
Page 49 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
27
-
Public Input No. 179-NFPA 85-2013 [ Section No. A.8.8.4.6.2
]
A.8.8.4.6.2 2.2 See Figure A.8.8.4.6.2. 2 . The intent of this
section is to maintain an air or inert gas plug in the fuel piping
to prevent fuel from entering the combustion turbine or HRSG, and
not to prove valve leak tightness. The Combustion Turbine Purge
Credit can be maintained as long as the conditions in 8.8.4.6.2.2
are met.Figure A.8.8.4.6.2 System 2.2 System 2 Gaseous Fuels with
Pressurized Pipe Section.
Additional Proposed Changes
File Name Description ApprovedHold_NFPA85BCS-HRS_8.8.4.6.pdf
Held Comment 85-30
Statement of Problem and Substantiation for Public Input
NOTE: This public input appeared as Comment 85-30 (Log #CC502)
which was held from the F10 ROC on Proposal 85-109.The committee
modified and reorganized the paragraphs to prioritize the actions
and
clarify some ambiguities in the text.
Submitter Information Verification
Submitter Full Name: TC on BCS-HRSOrganization: TC on Heat
Recovery Steam GeneratorsSubmittal Date: Thu Jan 03 09:56:37 EST
2013
Copyright Assignment
I, TC on BCS-HRS, hereby irrevocably grant and assign to the
National Fire Protection Association (NFPA) all and full rights in
copyright in this Public Input (including both the Proposed Change
and the Statement ofProblem and Substantiation). I understand and
intend that I acquire no rights, including rights as a joint
author, in any publication of the NFPA in which this Public Input
in this or another similar or derivative form is used. I hereby
warrant that I am the author of this Public Input and that I have
full power and authority to enter into this copyright
assignment.
Page 50 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
28
-
Public Input No. 181-NFPA 85-2013 [ Section No. A.8.8.4.6.3
]
A.8.8.4.6.2. 3 See Figure A.8.8.4.6.2. 3. The intent of this
section is to maintain an air or inert gas plug in the fuel piping
to prevent fuel from entering the combustion turbine or HRSG and
not to prove valve leak tightness. The Combustion Turbine Purge
Credit can be maintained as long as the conditions in 8.8.4.6.2.2
are met.Figure A.8.8.4.6.2. 3 System 3 Liquid Fuels with
Pressurized Pipe Section.
Additional Proposed Changes
File Name Description ApprovedHold_NFPA85BCS-HRS_8.8.4.6.2.3.pdf
Held Comment 85-32
Statement of Problem and Substantiation for Public Input
NOTE: This public input appeared as Comment 85-32 (Log #CC504)
which was held from the F10 ROC on Proposal 85-109.The committee
modified the wording to clarify ambiguities in the text.
Submitter Information Verification
Submitter Full Name: TC on BCS-HRSOrganization: TC on Heat
Recovery Steam GeneratorsSubmittal Date: Thu Jan 03 10:02:08 EST
2013
Page 52 of 72National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
29
-
Attachment C: Request from I. Yarinovsky
30
-
NOTE: New text is shown in RED. 8.9.2.1.4.3 In the event that
HRSG isolation is disabled and the combustion turbine can continue
to be operated with an exhaust temperature at least 56°C (100°F)
lower than the lowest autoignition temperature of the constituents
comprising the fuels designed for use in the specific combustion
turbine, the combustion turbine exhaust gas at this lower
temperature shall be permitted to be used to purge the HRSG.
8.9.2.2.2.2 In the event that the HRSG isolation is disabled and
the combustion turbine can continue to be operated with an exhaust
temperature at least 56°C (100°F) lower than the lowest
autoignition temperature of the constituents comprising the fuels
designed for use in the specific combustion turbine and duct
burner, the combustion turbine exhaust gas at this lower
temperature shall be permitted to be used to purge the HRSG.
31
-
Attachment D: Pre-FD Meeting Actions
32
-
First Revision No. 9-NFPA 85-2013 [ Global Input ]
Chapter 8 change - replace "stop valve or equivalent valve" with
"safety shutoff valve" everywhere it appears.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 11:11:29 EST 2013
Committee Statement and Meeting Notes
Committee Statement:
The committee replaced the term "stop valve" with "safety
shutoff valve" for consistency with the rest of the document and
NFPA 37. The committee removed the reference to "equivalent valves"
because, for a duct burner system, only safety shutoff valves are
used to stop fuel flow. It is the intent of the committee to enable
designers and/or operators to use the individual burner safety
shutoff valve, where provided in accordance with 8.4.3.2.1.11, as
the most downstream safety shutoff valve when it is not practical
to install the third shutoff valve in the main fuel supply line.
The previous text wasworded to require the individual burner safety
shutoff valves to be used as the "third valve".
ResponseMessage:
FR-9-NFPA 85-2013
Page 1 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
33
-
First Revision No. 11-NFPA 85-2013 [ Section No. 8.4.2.2.1 ]
8.4.2.2.1 The HRSG system's required interlocks shall prevent
starting of the combustion turbine unless the HRSG starting
conditions are satisfied, which shall include but not be limited to
the following:
The water levels in drum(s), if provided, are within the defined
start-uprange.
The feedwater supply system is available to respond to
demand.
The pressure in steam or water spaces is not high.
The exit temperature of duct burner(s), if provided, is not
high.The position of stack closure, if provided, is correct.
The pressure in the HRSG enclosure is not high.
The augmented air supply, if provided, is in operation. (See
8.8.4.2.4 .)
Where a combustion turbine purge credit is being used, all fuel
systems connected to the HRSG are satisfactorily isolated.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 11:31:49 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee deleted subparagraph (7) because the starting
sequence requires flow to be established through the combustion
turbine prior to starting augmented air systems.
Response Message:
FR-11-NFPA 85-2013
Page 22 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
34
-
First Revision No. 12-NFPA 85-2013 [ Section No. 8.4.2.2.4 ]
8.4.2.2.4 The combustion turbine exhaust system's required
interlocks shall preventWhere a HRSG is not provided, an interlock
shall prohibit starting the combustion turbine unless the following
starting conditions are satisfied: The pressure in the if the
combustion turbine exhaust ductwork system pressure is not
high.
The tempering air supply, if provided, is in operation.•
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 11:37:23 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee modified paragraph 8.4.2.2.4 because the starting
sequence requires flow to be established through the combustion
turbine prior to starting tempering air systems.
Response Message:
FR-12-NFPA 85-2013
Page 23 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
35
-
First Revision No. 14-NFPA 85-2013 [ Section No. 8.4.3.2.2.3
]
8.4.3.2.2.3 Triple Block and Double Vent Valve Arrangement.
Three stop safety shutoff valves or equivalent valves in series,
with proof of closure, shall be provided in each the fuel line to
the duct burner for units with combustion turbine purge credit
provisions in accordance with 8.8.4.6. Automatic An automatic vent
valves valve shall be provided between each of these valves. The
most downstream valve for a duct burner installation shall be
located in each burner line (runner) in
8.4.3.2.2.4* Where individual burner safety shutoff valves are
installed in accordance with 8.4.3.2.1.11 , the individual burner
safety shutoff valve shall be permitted to be the most downstream
safety shutoff valve required in 8 . 4.3.2.2.3.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 11:43:59 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee replaced the term "stop valve" with "safety
shutoff valve" for consistency with the rest of the document and
NFPA 37. The committee removed the reference to "equivalent valves"
because, for a duct burner system, only safety shutoff valves are
used to stop fuel flow. It is the intent of the committee to enable
designers and/or operators to use the individual burner safety
shutoff valve, where provided in accordance with 8.4.3.2.1.11, as
the most downstream safety shutoff valve when it is not practical
to install the third shutoff valve in the main fuel supply line.
The previous text was worded to require the individual burner
safety shutoff valves to be used as the "third valve".
ResponseMessage:
FR-14-NFPA 85-2013
Page 24 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
36
-
First Revision No. 17-NFPA 85-2013 [ Section No. 8.7.4.1.6 ]
8.7.4.1.6 Interlock functions shall be initiated by one or more
of the following:
A switch or transmitter independent of control functions and
signals
Two analog signals with a divergence alarm
Three analog signals employing an auctioneering system and a
divergence alarm or other fault diagnostic alarm
, including those functions outside the burner management
system, shall meet the functional requirements of 4.11.3.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 12:02:15 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee deleted the requirement and referenced the chapter
4 material to eliminate redundancy in the code.
ResponseMessage:
FR-17-NFPA 85-2013
Public Input No. 154-NFPA 85-2013 [Section No. 8.7.4.1.6]
Page 25 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
37
-
First Revision No. 20-NFPA 85-2013 [ Section No. 8.8.4.1 ]
8.8.4.1* Combustion Turbine Purge Process. The purge of the
combustion turbine shall be in accordance with the manufacturer's
instructions and with the requirements of 8.8.4.2 or 8.8.4.6 and 8
.8.4.7, as applicable.
8.8.4.1.1 Where a combustion turbine or HRSG is provided with
fuelsystems for multiple fuels, the purge requirements for each
type of fuel shallbe met.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 12:06:58 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The paragraph is revised to be consistent with changes made in
FR37 to separate purge credit requirements for liquid fuel
systems.
ResponseMessage:
FR-20-NFPA 85-2013
Page 26 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
38
-
First Revision No. 23-NFPA 85-2013 [ Section No. 8.8.4.2.4 ]
8.8.4.2.4 4*Where augmented air firing or tempering air is
provided, a means shall be supplied for interlocking and purging
the augmented or tempering air system prior to initiating and shall
be purged during the combustion turbine purge in accordance with
the combustion turbine and HRSG manufacturers'
operatinginstructions .
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 12:09:58 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee recognized that 8.8.4.2.4 did not clearly prevent
operators from running the augmenting or tempering air fans while
the combustion turbine is not in operation or purge. It is not good
practice to have air flowing in the reverse direction into the
combustion turbine and this reverse flow can come from the
augmenting or tempering air system. Tempering air was added to the
section because it was reported to the committee that there are
tempering air systems other than those associated with SCRs.
Response Message:
FR-23-NFPA 85-2013
Page 27 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
39
-
First Revision No. 30-NFPA 85-2013 [ Section No. 8.8.4.6 ]
8.8.4.6* Combustion Turbine Purge Credit for Gaseous Fuel
Systems .
Following a combustion turbine normal shutdown, combustion
turbine purge credit shall be allowed permitted to be established
for the next start-up event provided that one of the systems
described in the following requirements aremet for each combustion
turbine and duct burner fuel system.8.8.4.6.1
through*
Combustion turbine and duct burner manufacturer's valve-proving
requirements, fuel supply system requirements, and safety control
system requirements shall be met.8.8.4.6.
3 is incorporated for each combustion turbine and duct burner
fuel system. In addition, a
2 A positive means to prevent leakage of ammonia into the idle
HRSG or other combustion turbine exhaust system shall be provided
in accordance with 4.10.3 .8.8.4.6.
1 * System 1 Gaseous Fuels. Triple3 A triple block and double
vent valve arrangement is installed on the combustion turbine in
accordance with 8.4.2.1.2.2 and is installed on the
following requirements:HRSG fuel burning system (if provided) in
accordance with 8.4.3.2.2.3
8.8.4.6.4 One of the following shall be used to establish the
purge credit.(A)* Valve-proving Method (Note: Renumber A.8.8.4.6.1
here.)
(1) * Combustion turbine normal shutdown and duct burner normal
shutdown, where provided, shall be accomplished . (2) Fuel gas
block and vent valve positions shall be continuously monitored. If
continuous monitoring is lost or any valve deviates from its
assigned position, purge credit is lost, and subsequent start of
the combustion turbine requires a combustion turbine purge prior to
light-off, in accordance with 8.8.4.2 . (3) Pressures in the two
double block and vent pipe sections shall be continuously
monitored. If continuous monitoring is lost or either pressure
indicates leakage, purge credit is lost, and subsequent start of
the combustion turbine requires a combustion turbine purge prior to
light-off, in accordance with 8.8.4.2 . (4) * Prior to each
start-up and following each normal shutdown, block valves shall be
validated for gas leak tightness via a valve-proving system. As a
minimum, the most downstream block valve shall be valve proved
during the start-up sequence, and the middle block valve shall be
valve proved during the shutdown sequence. The most downstream
block valve shall be tested only when airflow is passing through
the combustion turbine.
Page 28 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
40
-
(5) The combustion turbine purge credit period shall not exceed
8 days (192 hours). If a combustion turbine purge in accordance
with 8.8.4.2 isperformed during the 8-day period, the combustion
turbine purge credit isreinitiated for an 8-day period.(B)*
Pressurized Pipe Section Method. (Renumber A. 8.8.4.6.2
* System 2 Gaseous Fuels with Pressurized Pipe Section. Triple
block and double vent valve arrangement filled with an inert gas or
air and maintained at a pressure that prevents gaseous fuel from
entering the combustion turbine or duct burner in accordance with
the following requirements:
here)(1) * Combustion turbine normal shutdown and duct burner
normal
shutdown, if provided, shall be accomplished . (2) Air or inert
gas shall be introduced to create and maintain a pressurized pipe
section between the middle and most downstream blockvalves. (3)
Fuel gas block and vent valve positions shall be continuously
monitored. If continuous monitoring is lost or any valve deviates
from its assigned position, purge credit is lost and subsequent
start-up of the combustion turbine requires a combustion turbine
purge prior to light-off, in accordance with 8.8.4.2 . (4)
Pressures in the two double block and vent pipe sections shall be
continuously monitored. If the continuous monitoring is lost or the
pressure downstream of the middle block valve decreases to less
than 20.7 kPa (3 psid) above the upstream pressure, purge credit is
lost and subsequent start-up of the combustion turbine requires a
combustion turbine purge prior to light-off, in accordance with
8.8.4.2 . (5) Combustion turbine purge credit period is shall be
considered to be maintained as long as the conditions in 8.8.4.6.2
(2), (3), and (4) are met.
Provisions shall be made to ensure that fuel cannot enter the
air or inert gas supply line at any time.
•
8.8.4.6.3 * System 3 Liquid Fuels with Pressurized Pipe
Section.
Triple block and double drain valve arrangement filled with an
inert gas or air and maintained at a pressure that prevents liquid
fuel from entering the combustion turbine or duct burner in
accordance with the following requirements:
•
Air or inert gas shall be introduced to create and maintain a
pressurized pipe section between the middle and most downstream
block valves.
•
The liquid fuel block and drain valve positions shall be
continuously monitored. If continuous monitoring is lost or any
valve deviates from its assigned position, purge credit is lost and
subsequent start of the combustion turbine requires a combustion
turbine purge prior to light-off, in accordance with 8.8.4.2 .
•
Pressures in the two double block and drain pipe sections shall
be continuously monitored. If the continuous monitoring is lost or
the pressure downstream of the middle block valve decreases to less
than 20.7 kPa
(
* Combustion turbine normal shutdown.
Page 29 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
41
-
3 psid) above the upstream pressure, purge credit is lost and
subsequent start-up of the combustion turbine requires a combustion
turbine purge prior to light-off, in accordance with 8.8.4.2 . The
combustion turbine purge credit period is maintained as long as the
conditions in 8.8.4.
6
.3(2)
, (3), and (4) are met.
Provisions shall be made to ensure that fuel cannot enter the
air or inert gas supply line at any time.
8.8.4.6.3.1 An inert liquid shall be permitted to be used in
lieu of inert gas if acceptable to the original equipment
manufacturer.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 13:10:19 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The committee restructured the paragraphs to be consistent with
the NFPA Manual of Style. The introductory paragraph referred to
systems being installed, but the subsequent subparagraphs described
operational sequences. The committee separated the requirements
from the sequences and renumbered accordingly. The committee added
the requirement for a normal duct burner shutdown to make it clear
that all systems must be in a "normal" condition in order for the
combustion turbine purge credit to be established. The committee
added the requirement for meeting the requirements of OEM of the
combustion turbine to ensure that the integrity of the combustion
turbine fuel systems and safety controls are maintained. This is
particularly important for any retrofit installed to meet the
combustion turbine purge credit requirements.
ResponseMessage:
FR-30-NFPA 85-2013
Public Input No. 178-NFPA 85-2013 [Section No. 8.8.4.6]
Page 30 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
42
-
First Revision No. 37-NFPA 85-2013 [ Section No. 8.8.4.6 ]
8.8.4.6 7 * Combustion Turbine Purge Credit for Liquid Fuel
Systems .
Following a combustion turbine normal shutdown, combustion
turbine purge credit shall be allowed permitted to be established
for the next start-up event provided that one of the systems
described in the following requirements aremet for each combustion
turbine and duct burner fuel system. 8.8.4.
6.1 through 7.1 *
Combustion turbine and duct burner manufacturer's fuel supply
valve monitoring system requirements and safety control
systemrequirements shall be met.
8.8.4.6.3 is incorporated for each combustion turbine and duct
burner fuel system. In addition, a
7.2 A positive means to prevent leakage of ammonia into the idle
HRSG or other combustion turbine exhaust system shall be provided
in accordance with 4.10.3 .8.8.4.
6.1 * System 1 Gaseous Fuels. Triple7.3 A triple block and
double
ventdrain valve arrangement is install on the combustion turbine
in accordance with 8.4.2.1.1.2 and is installed on the
following requirements:HRSG fuel burning system (if provided) in
accordance with 8.4.3.2.2.4.
8.8.4.7.4
One of the following shall be used to establish the purge
credit:
(A) Proof-of-Closure Method (1) * Combustion turbine normal
shutdown
. Fuel gas block and vent and duct burner normal shutdown, where
provided, shall be accomplished.(2) Liquid fuel block and drain
valve positions shall be continuously
monitored. If continuous monitoring is lost or any valve
deviates from its assigned position, purge credit is lost, and
subsequent start of the combustion turbine requires a combustion
turbine purge prior to light-off, in accordance with 8.8.4.2 . (3)
Pressures in the two double block and
vent
Page 31 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
43
-
drain pipe sections shall be continuously monitored. If
continuous monitoring is lost or either pressure indicates leakage,
purge credit is lost, and subsequent start of the combustion
turbine requires a combustion turbine purge prior to light-off, in
accordance with 8.8.4.2 .
•
The combustion turbine following requirements:
•
(4) The combustion turbine purge credit period shall not exceed
8 days (192 hours). If a combustion turbine purge in accordance
with 8.8.4.2 isperformed during the 8-day period, the combustion
turbine purge credit isreinitiated for an 8-day period.8.8.4.6.2 *
System 2 Gaseous Fuels with Pressurized Pipe Section. Triple block
and double vent valve arrangement filled with an inert gas or air
and maintained at a pressure that prevents gaseous fuel from
entering the combustion turbine or duct burner in accordance with
the following requirements:
Air or inert gas shall be introduced to create and maintain a
pressurized pipe section between the middle and most downstream
block valves.
Fuel gas block and vent valve positions shall be continuously
monitored. If continuous monitoring is lost or any valve deviates
from its assigned position, purge credit is lost and subsequent
start-up ofthe combustion turbine requires a combustion turbine
purge prior to light-off, in accordance with 8.8.4.2 .
Pressures in the two double block and vent pipe sections shall
be continuously monitored. If the continuous monitoring is lost or
the pressure downstream of the middle block valve decreases to less
than20.7 kPa (3 psid) above the upstream pressure, purge credit is
lost and subsequent start-up of the combustion turbine requires a
combustion turbine purge prior to light-off, in accordance with
8.8.4.2 .Combustion turbine purge credit period is maintained as
long as the conditions in 8.8.4.6.2 (2), (3), and (4) are met.
Provisions shall be made to ensure that fuel cannot enter the
air or inert gas supply line at any time.
8.8.4.6.3 * System 3 Liquid Fuels with Pressurized Pipe Section.
Triple block and double drain valve arrangement filled with an
inert gas or air and maintained at a pressure that prevents liquid
fuel from entering the combustion turbine or duct burner in
accordance with the
(B)* Pressurized Pipe Section Method (Renumber A.8.8.4.6.3 here)
(1)*Combustion turbine normal shutdown and duct burner normal
shutdown, where provided, shall be accomplished.
* Prior to each start-up and following each normal shutdown,
block valves shall be validated for gas leak tightness via a
valve-proving system. As a minimum, the most downstream block valve
shall be valve proved during the start-up sequence, and the middle
block valve shall be valve proved during the shutdown sequence. The
most downstream block valve shall be tested only when airflow is
passing through the combustion turbine.
* Combustion turbine normal shutdown.
* Combustion turbine normal shutdown.
Page 32 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
44
-
(2) Air or inert gas shall be introduced to create and maintain
a pressurized pipe section between the middle and most downstream
blockvalves. (3) The liquid fuel block and drain valve positions
shall be continuously monitored. If continuous monitoring is lost
or any valve deviates from its assigned position,
purge credit purge credit is lost and subsequent start of the
combustion turbine requires a combustion turbine purge prior to
light-offlightoff , in accordance with 8.8.4.2 . (4) Pressures
in the two double block and drain pipe sections shall be
continuously monitored. If the continuous monitoring is lost or the
pressure downstream of the
middle block middle block valve decreases to less than 20.7 kPa
(3 psid) above the upstream pressure, purge credit is lost and
subsequent start-up of the combustion turbine requires a combustion
turbine purge prior to light-off, in accordance with 8.8.4.2 . (5)
The combustion turbine purge credit period is maintained as long as
the conditions in 8.8.4.
67 .
34 ( B)( 2), (3), and (4) are met. (6) Provisions shall be made
to ensure that fuel cannot enter the air or inert gas supply line
at any time.8.8.4.6.3.1 7.5 An inert liquid shall be permitted to
be used in lieu of inert gas if acceptable to the original
equipment manufacturer.
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 14:42:15 EST 2013
Committee Statement and Meeting Notes
Page 33 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
45
-
CommitteeStatement:
The committee separated the purge credit requirements for liquid
fuels from the requirements for gaseous fuels. The introductory
paragraphs are repeated for completeness. The committee added the
proof-of-closure method to enable operators of liquid-fuel fired
units to establish purge credit without the use of an inert gas or
air plug. Realizing that the plug provides an infinite time for
purge credit, the proof-of-closure method only provides an 8 day
limit. With multiple drains in the system between the safety
shutoff valves that are gravity-fed to safe areas, and no pressure
on the middle or downstream safety shutoff valves, there is minimal
opportunity for fuel to leak into the combustionturbine or duct
burner. The committee added the requirement for a normalduct burner
shutdown to make it clear that all systems must be in a "normal"
condition in order for the combustion turbine purge credit to be
established. The committee added the requirement for meeting the
requirements of OEM of the combustion turbine to ensure that the
integrity of the combustion turbine fuel systems and safety
controls are maintained. This is particularly important for any
retrofit installed to meet the combustion turbine purge credit
requirements.
Response Message:
FR-37-NFPA 85-2013
Public Input No. 182-NFPA 85-2013 [Section No. 8.8.4.6]
Page 34 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
46
-
First Revision No. 41-NFPA 85-2013 [ Section No. 8.8.7.3
[Excluding
any Sub-Sections] ]
8.8.7.3 The automated vent or drain valve associated with the
main safety shutoff valves shall be opened.8.8.7.4* The duct
burners shall be taken out of service in a manner that relieves
fuel pressure in the pipe section between the two most downstream
safety shutoff valves.8.8.7.5 When the unit (combustion turbine and
duct burner) is being taken out of service, the combustion turbine
load shall be reduced in accordance with the manufacturer's
shutdown procedures.
Submitter Information Verification
Submitter Full Name: Kimberly SheaOrganization: National Fire
Protection AssocSubmittal Date: Mon Jan 14 10:51:58 EST 2013
Committee Statement and Meeting Notes
Committee Statement:
The committee recognizes that there is no specific requirement
to open the vent or drain valves on a normal duct burner shutdown.
Pressure should be relieved in the pipe section immediately
upstream of the safety shutoff valve(s) closest to the duct burner
during a shutdown to prevent the possibility of leakage into the
HRSG.
ResponseMessage:
FR-41-NFPA 85-2013
Page 35 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
47
-
First Revision No. 40-NFPA 85-2013 [ Section No. 8.8.7.4 ]
8.8.7.4 When establishing a combustion turbine purge credit in
accordance with 8.8.4.6.2 4(B) , the following procedure shall be
implemented prior to combustion turbine shutdown for duct burners
utilizing gaseous fuels (System2 Pressurized Pipe Section Method
):
Open both vent valves of the duct burner fuel supply.
Admit the blocking medium to purge any remaining fuel until the
fuel level is less than 25 percent of the LEL.
Close the downstream (header) vent valve.Establish and maintain
the required blocking pressure
Submitter Information Verification
Submitter Full Name: Jenny DepewOrganization: NFPASubmittal
Date: Fri Jan 11 15:28:40 EST 2013
Committee Statement and Meeting Notes
CommitteeStatement:
The paragraph is revised to be consistent with changes made in
FR30.
Response Message: FR-40-NFPA 85-2013
Page 36 of 58National Fire Protection Association Report
2/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...
48
-
First Revision No. 42-NFPA 85-2013 [ Section No. 8.8.7.5 ]
8.8.7.5 When establishing a combustio