Technical Committee on Heat Recovery Steam Generators and Other Combustion Turbine Exhaust Systems

Transcription

1 Technical Committee on Heat Recovery Steam Generators and Other Combustion Turbine Exhaust Systems AGENDA Entergy Corporation 639 Loyola Avenue New Orleans, LA February 28 March 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 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

2 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, The BCS-FUN meeting is tentatively scheduled for Dec 4-5, 2013 in Atlanta, GA. 9. Adjournment. 2

3 Attachment A: Fall 2014 Revision Cycle 3

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

5 Attachment B: Public Input 5

6 Page 27 of 78 Public Input No. 196-NFPA [ Section No ] 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 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 Full Name: Gordon Gaetke Organization: Affilliation: The Dow Chemical Company NFPA 85 HRSG Technical Committee Submittal 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 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 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 6

7 Page 28 of 78 Public Input No. 217-NFPA [ Section No ] 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 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 Public Input No. 216-NFPA [Section No ] Relationship Submitter Full Name: Ted Jablkowski Organization: Fives North American Combustio Submittal 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 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 7

8 Page 29 of 78 Public Input No. 197-NFPA [ Section No ] 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 Since this requirement is part of 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 ] 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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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 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 8

9 Page 30 of 78 Public Input No. 198-NFPA [ Section No ] Expansion provision shall be made for the movement of the duct between the 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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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 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 9

10 Page 31 of 78 Public Input No. 200-NFPA [ Sections 8.6.2, 8.6.3, ] Sections 8.6.2, 8.6.3, All wiring electrical equipment and wiring shall comply with the requirements of NFPA 70, National Electrical Code All high voltage equipment shall be marked in accordance with the requirements of NFPA 70, National Electrical Code * 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 and ). Lastly, it avoids creating a definition for high voltage which is a term used, but not defined, in 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 do not appear to contain any unique requirements for HRSGs or other combustion turbine exhaust systems. Paragraphs , , and 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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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. 10

11 Page 33 of 78 Public Input No. 202-NFPA [ Section No ] 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 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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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 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 11

12 Page 34 of 78 Public Input No. 201-NFPA [ Section No ] 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 combustion turbine, fresh air fan (if provided), and damper(s) (if provided) position(s) Combustion turbine trip except for systems operating as defined in 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 Light-off failure of first burner in multiple burner operation Failure 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 malfunction Manual trip [See (8).] Loss of augmented air supply where the operation of the duct burner requires augmented air Fresh air (if provided) transfer failure (See ) Logic controller failure [See (10) and (11).] Statement of Problem and Substantiation for Public Input 12

13 Page 35 of 78 Change from boiler control to HRSG control in (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 (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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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 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 13

14 Page 36 of 78 Public Input No. 203-NFPA [ Section No ] 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 (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 Full Name: Gordon Gaetke Organization: Affilliation: The Dow Chemical Company NFPA 85 HRSG Technical Committee Submittal 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 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 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 14

15 Page 37 of 78 Public Input No. 160-NFPA [ Section No ] Cold Start Preparation. Preparation for starting shall require an inspection by the owner/operator that includes 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 circulation and 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 15

16 Page 38 of 78 Related Input Public Input No. 132-NFPA [Section No ] Relationship Submitter Full Name: Brian Moore Organization: Hartford Steam Boiler Inspecti Submittal 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 16

17 Page 39 of 78 Public Input No. 134-NFPA [ Section No ] * System 1 Gaseous Fuels. Triple block and double vent valve arrangement in accordance with the following requirements: * Combustion turbine normal shutdown. 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 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 lightoff, in accordance with * 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. The combustion turbine purge credit period shall not exceed 8 days (192 hours). If a combustion turbine purge in accordance with 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 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: tmpl=component&page= 17

18 Page 41 of 78 Public Input No. 180-NFPA [ Section No ] * 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: * Combustion turbine normal shutdown shall be completed. 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 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 (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 The combustion turbine purge credit period is maintained as long as the conditions in (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 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 Approved Hold_NFPA85BCS-HRS_ pdf Held Comment Statement of Problem and Substantiation for Public Input NOTE: This public input appeared as Comment (Log #CC504) which was held from the F10 ROC on Proposal The committee modified the wording to clarify ambiguities in the text. Submitter Full Name: TC on BCS-HRS Organization: TC on Heat Recovery Steam Generators Submittal Date: Thu Jan 03 09:59:05 EST 2013 Copyright Assignment 18

19 Page 43 of 78 Public Input No. 129-NFPA [ New Section after ] * 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 following requirements: (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 (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 (5) The combustion turbine purge credit period is maintained as long as the conditions in (3), and (4) are met. The associated Annex A text is: A See Figure A 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 combustion turbine or HRSG. A (1) The combustion turbine normal shutdown includes sufficient postpurge airflow to satisfy the requirements of the combustion turbine purge. A (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. 19

20 Page 44 of 78 Figure A 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 Full Name: Lawrence Danner Organization: General Electric, Energy Submittal 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. 20

21 Page 46 of 78 Public Input No. 183-NFPA [ New Section after ] All duct burner fuel supply vent valves shall be opened. Renumber subsequent sections. Additional Proposed Changes File Name Description Approved Hold_NFPA85BCS-HRS_ _New_.pdf Held Comment Statement of Problem and Substantiation for Public Input NOTE: This public input appeared as Comment (Log #CC503) which was held from the F10 ROC on Proposal 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 Full Name: TC on BCS-HRS Organization: TC on Heat Recovery Steam Generators Submittal 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 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 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 21

22 Page 47 of 78 Public Input No. 224-NFPA [ Section No ] 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 Public Input No. 223-NFPA [Section No. 7.2] Relationship Submitter Full Name: Ted Jablkowski Organization: Fives North American Combustion Submittal 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 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 22

23 Page 45 of 72 Public Input No. 172-NFPA [ Section No. A ] A 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 systems Operator 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) 23

24 Page 46 of 72 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 Public Input No. 132-NFPA [Section No ] Relationship Submitter Full Name: Brian Moore Organization: Hartford Steam Boiler Inspecti Submittal 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 24

25 Page 47 of 72 Public Input No. 215-NFPA [ Section No. A ] A Usually this can be accomplished by providing full relieving capacity vented to a safe location. a location meeting the requirements of 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 Public Input No. 214-NFPA [Section No ] Relationship Submitter Full Name: Ted Jablkowski Organization: Fives North American Combustio Affilliation: October 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 25

26 Page 48 of 72 Public Input No. 63-NFPA [ Section No. A ] A Usually this can be accomplished by providing full relieving capacity vented to a safe location. Refer to the information included in Section 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, , and A Submitter Full Name: Dale Evely Organization: Southern Company Services, Inc Submittal 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 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 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 26

27 Page 49 of 72 Public Input No. 199-NFPA [ Section No. A ] A 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 the Classification 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 to A Paragraph 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 than Paragraph 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 Full Name: Gordon Gaetke Organization: The Dow Chemical Company Affilliation: NFPA 85 HRSG Technical Committee Submittal 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 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 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 27