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Public Comment No. 20-NFPA 11-2013 [ Section No. 1.1.1 ] 1.1.1 This standard covers the design, installation, operation, testing, and maintenance of low-, medium-, and high-expansion and , compressed air and self-expanding foam systems for fire protection. Additional Proposed Changes File Name Description Approved FFGR_SYSTEM_COMPARISON.pdf FOAMFATALE SYSTEM COMPARISON FFPV_inspection_en.pdf PRESSURE VESSEL INSPECTION EN FFPV_inspection_hu.pdf PRESSURE VESSEL INSPECTION HU HEMPEL_certification.pdf HEMPEL CERTIFICATION SEF_labtest_en.pdf SEF LABTEST EN SEF_labtest_hu.pdf SEF LABTEST HU SEFS_Test_results.xls SEFS Tests Statement of Problem and Substantiation for Public Comment Self-Expanding Foam System is a different fire protection arrangement than prescribed in the current standard. 1. Committee Statement (CS): „Foam Fatale (FF) has proposed a dramatic decrease in the required discharge time(s) for application of foam to tank fires. The FF recommended application times are 2 or 3 minutes, depending on tank size, compared to 50-65 minutes depending on fuel type required by NFPA 11 Para. 5.4.2 and 60 minutes required by EN13565-2 Table 3. These times are for fixed systems on cone roof tanks.” Public Comment (PC): The Public Inputs No. 49, 50, 53, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70 were not just about to decrease the application times. I proposed a new patented system arrangement with associated patented foam introduction device (foam ring) among the others. The one-shot system arrangement, the ready-to-use foam with the unique pattern of foam introduction results in a breakthrough extinguishing performance, the system is capable to put out a 5370 ft2 gasoline storage tank fire in 40 seconds. As a safety factor, the proposed application time is three times higher than the extinguishing time. Please see the attached FFGR_SYSTEM_COMPARISON.pdf file as a comparision between the conventional technologies and the Self-Expanding Foam System (SEFS). Committee Statement (CS): This recommendation is supported by only one fire test on an 82 ft diameter tank containing gasoline. In this test there was virtually no freeboard of tank wall above the fuel and foam application was started immediately after ignition. We believe that this does not replicate real world conditions and that much additional testing is needed to validate this system. Public Comment (PC): The Public Input No. 70 included three cold foam spread and two fire extiguishing test results. The second sheet of the attached „SEFS_Test_results.xls” might have not been considered. For further justification a DVD has been sent to Mr. Barry Chase as a video demonstration of this Public Comment about the extinguishing performance of the proposed Self-Expanding Foam System (SEFS). The video includes two fire tests, one foam spread test and two storage tank fire extinguishments simulating real world conditions. Please watch the video demonstration, which can also be found on youtube.com, title The Self-Expanding Foam System (SEFS). It can be seen on the videos that there is a freeboard of 0,65 meter, which exceeds the LASTFIRE recommendation. The foam application has not started immediately, in the fire extinguishments simulating real world conditions there was a 30 seconds pre-burn time, and during this time even middle-layer effect could develop. Please see pictures about the freeboard and middle layer effect. Beside of the tests that have already been carried out, FoamFatale Greece contacted Underwriters Laboratories, FM Global for testing the Self-Expanding Foam System (SEFS). We received the following answers to our request: National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 1 of 42 3/24/2014 3:00 PM

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Public Comment No. 20-NFPA 11-2013 [ Section No. 1.1.1 ]

1.1.1

This standard covers the design, installation, operation, testing, and maintenance of low-, medium-, andhigh-expansion and , compressed air and self-expanding foam systems for fire protection.

Additional Proposed Changes

File Name Description Approved

FFGR_SYSTEM_COMPARISON.pdf FOAMFATALE SYSTEM COMPARISON

FFPV_inspection_en.pdf PRESSURE VESSEL INSPECTION EN

FFPV_inspection_hu.pdf PRESSURE VESSEL INSPECTION HU

HEMPEL_certification.pdf HEMPEL CERTIFICATION

SEF_labtest_en.pdf SEF LABTEST EN

SEF_labtest_hu.pdf SEF LABTEST HU

SEFS_Test_results.xls SEFS Tests

Statement of Problem and Substantiation for Public Comment

Self-Expanding Foam System is a different fire protection arrangement than prescribed in the current standard.

1. Committee Statement (CS): „Foam Fatale (FF) has proposed a dramatic decrease in the required discharge time(s) for application of foam to tank fires. The FF recommended application times are 2 or 3 minutes, depending on tank size, compared to 50-65 minutes depending on fuel type required by NFPA 11 Para. 5.4.2 and 60 minutes required by EN13565-2 Table 3. These times are for fixed systems on cone roof tanks.”

Public Comment (PC): The Public Inputs No. 49, 50, 53, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70 were not just about to decrease the application times. I proposed a new patented system arrangement with associated patented foam introduction device (foam ring) among the others. The one-shot system arrangement, the ready-to-use foam with the unique pattern of foam introduction results in a breakthrough extinguishing performance, the system is capable to put out a 5370 ft2 gasoline storage tank fire in 40 seconds. As a safety factor, the proposed application time is three times higher than the extinguishing time. Please see the attached FFGR_SYSTEM_COMPARISON.pdf file as a comparision between the conventional technologies and the Self-Expanding Foam System (SEFS).

Committee Statement (CS): This recommendation is supported by only one fire test on an 82 ft diameter tank containing gasoline. In this test there was virtually no freeboard of tank wall above the fuel and foam application was started immediately after ignition. We believe that this does not replicate real world conditions and that much additional testing is needed to validate this system.

Public Comment (PC): The Public Input No. 70 included three cold foam spread and two fire extiguishing test results. The second sheet of the attached „SEFS_Test_results.xls” might have not been considered. For further justification a DVD has been sent to Mr. Barry Chase as a video demonstration of this Public Comment about the extinguishing performance of the proposed Self-Expanding Foam System (SEFS). The video includes two fire tests, one foam spread test and two storage tank fire extinguishments simulating real world conditions. Please watch the video demonstration, which can also be found on youtube.com, title The Self-Expanding Foam System (SEFS). It can be seen on the videos that there is a freeboard of 0,65 meter, which exceeds the LASTFIRE recommendation. The foam application has not started immediately, in the fire extinguishments simulating real world conditions there was a 30 seconds pre-burn time, and during this time even middle-layer effect could develop. Please see pictures about the freeboard and middle layer effect.

Beside of the tests that have already been carried out, FoamFatale Greece contacted Underwriters Laboratories, FM Global for testing the Self-Expanding Foam System (SEFS). We received the following answers to our request:

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„This product is an innovative product and either by its design, use or features it does not currently fit within the scope of existing UL certification programs. UL has made the decision to not develop requirements to include this under our UL Listing, Classification or Recognition programs.”, „Unfortunately, we are unable to offer FM Approval since it doesn’t satisfy our Class 5130 Approval Standard. A new standard would need to be developed or the existing one would need to be modified in such a way that it would allow us to adequately test and certify your system.”

The Self-Expanding Foam System (SEFS) has been witness tested by TUV Germany and complies with EN-13565:2 European Standard of Fixed firefighting systems - Foam systems. Part 2: Design, construction and maintenance. Please see the attachment of Public Input No. 70, TUV_FF_en.jpg file.

2. Committee Statement (CS): FF supports the idea of immediate application by suggesting that the system will be actuated by detectors. No provision is made for backup manual actuation as required by NFPA 11 Para. 4.9.1.2 and EN 13565-2 Para. 4.7.2 Moreover, FF does not provide fire test data simulating a scenario in which detector driven automatic actuation fails and manual actuation is required. We believe that this is important because tank fires are often ignited by lightning that has the potential to disable detectors and/or automatic actuation systems, making it important to test with longer preburns and design systems for the longer run times that would be required in the case of long preburns caused by failure of automatic actuation.

Public Comment (PC): Please see Public Input No. 68 for manual actuation provision. Revision shall be made if the proposed language does not cover manual actuation. In the fire extinguishments when simulating world conditions the detector system was turned off with sufficient pre-burn time and the system was actuated manually. Please see the submitted storage tank fire extinguishment video at 5 min 04 sec.

3. Committee Statement (CS): In the fire test shown by FF the application rate is at the recommended application rate. There is no provision for a safety factor as is the case in UL and NFPA standards where design rates are much higher than the test rates. It is generally accepted by NFPA that typical critical application rates are approximately 50% of design rates.

Public Comment (PC): The attachment of Public Input No. 70 FFGR-PI-NFPA11-01.pdf mentions 12,8 L/min*m2 recommended min. application rate for a storage tank less than 30 meters in diameter, meanwhile the storage tank in fire was 25,2 meter in diameter and the application rates were less than 10 L/min*m2, which means a 25% safety factor was considered. Please see SEFS_Test_results.xls second sheet for the application rates.

The Committee Statement refers to UL standard, meanwhile UL does not carry out low-expansion foam system test, only for foam concetrates and other system components, moreover NFPA or NFPA 11 does not recommend any test rates for storage tank foam systems. It worths mentioning that the reduced application rate tests applied by UL is to test foam concentrates. According to the current edition of NFPA 11 the foam concentrate shall be listed so as to the Self-Expanding Foam System. The proposal is about a complete system which incorporates an already UL listed foam concentrate.

Furthermore I would like to mention that Mr. Fay Purvis Chair voted negative on CAF System with the following explanation: „this proposal states that the minimum acceptable discharge density shall be in accordance with the applicable occupancy standards and not less than 1.63 l/min/sq meter or 0.04 gpm/sq ft. This density is based on laboratory scale testing and does not include a safety factor to allow for unforeseen conditions that are experienced in field conditions.” (ref: NFPA, 2009 Fall Revision Cycle, Report on Proposals) The proposal of the Compressed Air Foam System has been voted by the Committee as „accepted” without safety factor.

The question is: which test is more adequate to validate a system? A reduced application rate foam concentrate test or a complete low-expansion foam system test simulating real world conditions with a safety factor?

One of the difference between the conventional systems and the Self-Expanding Foam System is that the first is designed to discharge on a given application rate for a certain period of time, while the Self-Expanding Foam System (SEFS) is engineered to extinguish. 4. Committee Statement (CS): Performing hydraulic calculations for the FF system appears to us to be quite a challenge. The foam solution is stored in a pressure vessel that is pressurized with carbon dioxide, a gas that is soluble in water. Whether there is any gas headspace or all of the carbon dioxide is in solution is not clear. The

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system relies on the pressure of the carbon dioxide to drive the solution through piping and the discharge device. It is obvious that as the solution is discharged the headspace in the pressure vessel will increase, reducing the pressure and, therefore, the flow rate. The pressure/temperature curve of carbon dioxide is quite steep, suggesting a large variation in discharge pressure and flow with variations in ambient temperature. Further, as the solution flows through the piping to the fire its pressure will decrease due to pipe friction. That will allow the solution to release more carbon dioxide that will then exist as bubbles in the solution increasing its volume and, therefore, its velocity and friction loss. At the same time the density of the solution is decreasing, decreasing friction loss. FF does not suggest a calculation method to handle these problems.

Public Comment (PC): FoamFatale Greece proposed the Self-Expanding Foam System, which system is a kind of improved Compressed Air Foam System. The patented Self-Expanding Foam System is one step ahead in the foam generation process, the last stage before the expanded foam. There is no need for mixing chamber, ready-to-use foam is stored in the pressure vessel. The foam flow characteristics downstream of the valve are similar to CAF System hydraulics. Foam flow instead of foam solution reduces the friction loss and increases the discharge. Pressure loss due to elevation is reduced also. The same hydraulic calculations shall be performed as with CAFS. The pressure in the pressure vessel shall be set according to the Operation and Instruction Manual of the manufacturer.

5. Committee Statement (CS): Solutions of carbon dioxide in water are quite acidic, having a pH value between 3 and 4, about the same as vinegar. FF proposes corrosion protection for the pressure vessel but does not suggest how this might be accomplished.

Public Comment (PC): Please see attached the 12-years pressure vessel inspection certificate of a FoamFatale installation (original FFPV_inspection_hu.pdf and translation to english FFPV_inspection_en.pdf). The corrosion protected vessel is intact and clean internally after twelve years of continuous operation. As one option for internal corrosion protection a certification is attached from HEMPEL (HEMPEL_certification.pdf).

6. Committee Statement (CS): FF suggests freeze protection in cold climates, but again does not suggest a practical method. Adding freeze point depressants to foam solution severely degrades fire extinguishing performance.

Public Comment (PC): Please see attached the 10-years foam laboratory test results (original language SEF_labtest_hu.pdf and english translation SEF_labtest_en.pdf). Glykol, as freeze point depressant did not degrade the quality of the foam with solidification point below -15 C degree. The foam solution is approved for further usage.

7. Committee Statement (CS): Most, if not all, of the AFFF, ARAFFF and F3 foam concentrates now on the market use alkyl sulfates and/or alkyl ether sulfates as foaming agents. These chemicals undergo rapid autocatalytic hydrolysis at acidic pH, destroying their effectiveness as foamers. Additionally, foam concentrates based on hydrolyzed protein i.e. FFFP, ARFFFP, FP and regular protein will also lose efficacy over time due to exposure to acidic conditions.

Public Comment (PC): Please see previous PC for foam laboratory test results after 10 years in acidic environment. The foam solution is approved for further usage. F3, FFFP, ARFFFP, FP and regular protein foam concentrates shall not be used to produce Self-Expanding Foam.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Nov 14 12:16:36 EST 2013

Committee Statement

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CommitteeAction:

Rejected

Resolution: The Technical Committee for NFPA 11 is not an approval body and is not charged with evaluatingnew foam technologies for viability in the marketplace. New technologies are incorporated into NFPA11 only when the available data is sufficient to permit appropriate technical requirements to beestablished. Therefore, the committee’s decision to not incorporate Self-Expanding Foam into NFPA11 at this time should not be construed as a rejection of the technology or a commentary on itseffectiveness as a fire-fighting system. While the committee feels that the technical substantiation iscurrently insufficient to allow proper standardization, it is still within the purview of an authority havingjurisdiction to approve the use of Self-Expanding Foam Systems, per 1.2.2 of NFPA 11. Following athorough review of the related Public Comments and the submitted materials, the committee findsthat several previously identified technical concerns remain unaddressed and that new questionshave been raised, including: 1. A proposed new concept, especially one that is not listed or thatdeviates significantly from the established norms, is typically substantiated by a formal technicalreport that addresses the conduct and results of tests. The content of these reports are used by thecommittee to develop design criteria and system limitations. However, in this case, the committeeonly received demonstration videos and test summaries, which lacked critical information, such as: -What concentrate was used (AFFF, FFFP, AR, freeze protected), and at what percentage foam use?What are any limits in concentrate use for the proposed system (fuel types, use with CO2)? - Whatare the set up and discharge characteristics, such as flow measurements, particularly the variabledischarge rate? How do these parameters affect: - foam quality (e.g., expansion, drainage) -burnback characteristics (as function of discharge time/foam quantity) - vapor security for extendedtimes (hours) Of particular note is the submitted TUV test certificate, which states that the system“complies with the safety objective defined in EN 13565-2.” Without the full test report, the committeehas no basis for determining what this means or how it substantiates any of the proposedrequirements. 2. The fire extinguishment tests that were included in the summary report and thatwere shown in the submitted video did not incorporate an extended pre-burn time (e.g., 3-5 minutes)before application of the self-expanding foam. In both cases, the pre-burn time was 30 seconds orless. The committee believes that longer pre-burn times are necessary, in order to test theeffectiveness of the system when manual actuation is necessary. 3. The proposed designconfiguration contradicts the established fixed roof tank protection concept. Section 9.5.1 of NFPA 11requires the laterals to each foam discharge outlet to be separately valved outside the diked area.The purpose of this is to provide redundancy and accessible, individual controls, in the event that anexplosion causes damage to the foam system piping or outlets. However, the proposed SEF systemdoes not offer similar robustness. There is a lack of detailed information regarding installation of thefoam ring or performance of the system if the foam ring is compromised. 4. Table 8.8 in PC #30proposes to establish minimum design densities, which increase as the size of the tank increases.However, the submittal did not provide the technical derivation or basis of these foam applicationrates. The scalability of the completed intermediate scale tests was not substantiated. It is unclearwhether extinguishment densities translate 1:1 or if there is a scaling factor, as in AFFF (see SFPEHandbook for a discussion of foam scaling; published scaling data is also available). Criteria forrequired foam “velocity” and rationale for rates above 200ft diameter were not provided. 5. Thesubmitted material does not address the means of creating/mixing the self-expanding foam solutionprior to storage in the pressure vessel. It is unclear whether it is mixed on-site or by the manufacturer.6. The limitations/restrictions on engineering designs (e.g., 2-phase flow calculation) were notprovided. 7. Selection of materials, with regard to acidity, pressure, etc., was not substantiated toallow the committee to develop engineering requirements for this technology. 8. The 10-year foamsolution study provides insufficient detail to understand the interaction between the CO2 and foamsolution. The committee remains open and receptive to learning more about this technology. Thesubmitter is invited to resubmit with additional data and analysis to continue the process at the nextcycle.

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Public Comment No. 21-NFPA 11-2013 [ Section No. 1.2.1 ]

1.2.1

This standard is intended for the use and guidance of those responsible for designing, installing, testing,inspecting, approving, listing, operating, or maintaining fixed, semifixed, or portable low-, medium-, andhigh-expansion and , compressed air and self-expanding foam fire-extinguishing systems for interior orexterior hazards.

Statement of Problem and Substantiation for Public Comment

Self-Expanding Foam System is a different fire protection arrangement than prescribed in the current standard.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 03:40:28 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 4-NFPA 11-2013 [ Section No. 3.3.3 ]

3.3.3 Discharge Device.

3.3.3.1* General. A device designed to discharge water or foam-water solution in a predetermined, fixed,or adjustable pattern. Examples include, but are not limited to, sprinklers, spray nozzles, and hosenozzles.

3.3.3.1 2 Air-Aspirating Discharge Devices.

Devices specially designed to aspirate and mix air into the foam solution to generate foam, followed byfoam discharge in a specific design pattern.

3.3.3.2 3 Compressed Air Foam Discharge Device.

A device specifically designed to discharge compressed air foam in a predetermined pattern.

3.3.3.3 4 * Non-Air-Aspirating Discharge Devices.

Devices designed to provide a specific water discharge pattern.

A.3.3.3.1 Examples include, but are not limited to, sprinklers, spray nozzles, and hose nozzles.

Statement of Problem and Substantiation for Public Comment

This public comment is submitted on behalf of the NFPA Glossary Committee on Terminology. Examples that are lists should not be part of a definition but are best placed in the annex or in a different part of the document. The general definition should have a number and a title also. This comment needs to be tied in to a renumbering of an annex section for 3.3.3.3 now becoming annex section for 3.3.3.4.

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 11:43:33 EDT 2013

Committee Statement

Committee Action: Accepted

Resolution: SR-1-NFPA 11-2014

Statement: The list of examples was moved to the annex, since it is not part of the definition.

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Public Comment No. 23-NFPA 11-2013 [ New Section after 3.3.4 ]

3.3.5 Self-expanding Foam Introduction Device (foam ring). A torus shape devicepermanently attached along the inner shell of a tank to introduce self-expanding foam in apredetermined pattern.

Statement of Problem and Substantiation for Public Comment

A new device shall be introduced that releases self-expanding foam. This device has many advantages: a) capable to serve superintensive foam application rates, b) immediately starts to cool the inner tank shell, c) with the continuous, curtain-like foam flow from the first intorduction point, the oxigen is excluded, d) there are not uncovered surfaces like between the points of foam generation devices, e) the foam loss (dehydration and deconsumption) compared to point-like introduction, arising from fires between the uncovered surfaces, is negligible, f) the foam blanket is closing in the center of the surface, forming a reignition safe thickness. According to the current edition of NFPA 11 A.5.2.6.1, "foam generation equipment (foam chamber) disruption often arises as a result of an initial tank explosion or the presence of fire surrounding the tank". Therefore different foam introduction device shall also be recommended. The self-expanding foam introduction device is attached to the inner shell of the cone roof tank on the whole circumference under the weak seam and in case of an explosion, which is considered as one of the most frequent sources of cone roof tank fires, it acts also like a support frame. The self-expanding foam intoduction device directs foam to the tank shell and then the foam flows down on the whole surface of the inner tank shell cooling it very effectively. The one and only function of the self-expanding foam introduction device is to release foam, hence malfunction is excluded.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:00:50 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 24-NFPA 11-2013 [ New Section after 3.3.9.1 ]

3.3.9.2 Self-expanding Foam (SEF). A homogeneous foam produced in advance of afire by the combination of water, foam concentrate, and carbon-dioxide or the gasmixture of carbon-dioxide and nitrogen under pressure, and stored in a location notexposed to the hazard.

Statement of Problem and Substantiation for Public Comment

Self-expanding Foam (SEF) shall be introduced. SEF is the fire extinguishing media of the Self-Expanding Foam Systems (SEFS). The SEF is a ready-to-use homogenous foam, can be alcohol-resistant or non alcohol-resistant, can be frost proof and non frost proof too. The physical and the chemical features of the SEF can be adjusted to the stored material. SEF is perfectly produced well in advance of a fire, there is no preparation, foam solution mixing and foam generation time in case of a given fire, and of course the equipment required for doing these steps are not needed also, the only thing that has to do to introduce the required foam volume to put out the fire.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:09:48 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 25-NFPA 11-2013 [ New Section after 3.3.16.1 ]

3.3.16.2 Self-expanding Foam System (SEFS). A system employing self-expandingfoam introduction device or monitors attached to a piping system through which foam istransported from a pressure vessel. Introduction of self-expanding foam begins withautomatic actuation of a detection system, or manual actuation that opens valvespermitting self-expanding foam stored in the pressure vessel, to flow through a pipingsystem and introduced over the surface or area served by the self-expanding foamintroduction device or monitors.

Statement of Problem and Substantiation for Public Comment

Self-Expanding Foam System has been brought to the market in Europe more than 10 years ago. The SEFS could not gained wide acceptance during these years because of the strict regulations coming from standard prescriptions that recommend 'flow-through' systems only. SEFS, a kind of improved CAF system, has a totaly different arrangement compared to the flow-trough systems. SEFS is a fully pre-engineered 'one-shot' fixed system with semi-fixed supplementary protection devices. No external water, seawater, water tanks are required, it has automatic operation with manual option, the maintenance of the system is low-to-zero. The ready-to-use foam, the one-shot system arrangement, the foam introduction pattern makes the Self-Expanding Foam System capable to put out a 500m2 gasoline fire in less than one minute. There is no NFPA standard addressing these systems which are substantially different technically from the flow-trough systems, currently covered and recommended by NFPA 11. In order to enable Self-Expanding Foam System to be listed, approved and accepted, listing organizations, approval bodies, regulatory authorities and others require some form of recognition and acknowledgement of the SEFS in NFPA 11 standard. Without the recognition of SEFS within NFPA standards and codes, this technology and system could not enter to the marketplace as NFPA is the most recognized body and its standards are the most adopted worldwide in fire protection. SEF system complies with EN-13565:2, European Standard of Fixed firefighting systems ― Foam systems. Part 2: Design, construction and maintenance.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:13:28 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 6-NFPA 11-2013 [ Section No. 3.3.17.1 ]

3.3.17.1 * Compressed Air Foam-Generating Method.

A method of generating compressed air foam recognized in this standard using a mixing chamber tocombine air or nitrogen under pressure, water, and foam concentrate in the correct proportions.

A.3.3.17.1 The resulting compressed air foam flows through piping or hoses to the hazard being protected.

Statement of Problem and Substantiation for Public Comment

The second sentence is really explanation and not part of the definition. If the committee feels that this information needs to be enforced it should be moved to a different part of the document since definitions and annex material are not enforceable.

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 11:51:35 EDT 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-2-NFPA 11-2014

Statement: The second sentence is really explanation and not part of the definition. It was moved to theannex.

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Public Comment No. 9-NFPA 11-2013 [ Section No. 3.3.23.1.1 ]

3.3.23.1.1* In-Line Balanced Pressure Proportioning.

A foam proportioning system utilizing a foam concentrate pump or a bladder tank in conjunction with alisted pressure reducing valve. At all design flow rates, the constant foam concentrate pressure is greaterthan the maximum water pressure at the inlet to the in-line balanced pressure proportioner. A pressurebalancing valve integral to the in-line balanced pressure proportioner regulates the foam concentratepressure to be balanced to incoming water pressure.

Statement of Problem and Substantiation for Public Comment

All sentences following the first sentence are not really part of the definition and need to be moved, either to the annex (as suggested here) or to some enforceable portion of the standard.

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 13:58:47 EDT 2013

Committee Statement

Committee Action: Rejected

Resolution: This type of proportioner requires more than one sentence to define, due to its complexity.

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Public Comment No. 26-NFPA 11-2013 [ New Section after 3.3.27.2 ]

3.3.27.3Self-expanding Foam Pressure Vessel. A self-expanding foam tank fitted with safetyvalve, pressure transmitter and pressure gauges that stores the self-expanding foam underpressure.

Statement of Problem and Substantiation for Public Comment

With the recommendation of the Self-Expanding Foam System, new type of foam storage shall be introduced.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:22:07 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 7-NFPA 11-2013 [ Section No. 3.3.27.2 ]

3.3.27.2* Pressure Proportioning Tank.

A foam concentrate tank with no bladder that uses waterflow through an orifice to displace the foamconcentrate in the tank with water to add foam concentrate through an orifice into a water line at a specifiedrate. This device is only suitable for foams having a specific gravity of at least 1.15.

Statement of Problem and Substantiation for Public Comment

The second sentence is not part of the definition but a requirement that needs to be somewhere else, for example added to the annex section or somewhere in the body of the standard, for example in chapter 4.

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 12:36:08 EDT 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution:

Statement: The definition was revised to combine the two sentences into a single definition. This type ofproportioner, by definition, only works with foam concentrates having this specific gravity, so thespecification belongs in the definition, not as annex text.

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Public Comment No. 1-NFPA 11-2013 [ Section No. 4.7.2.1 ]

4.7.2.1

Foam solution pipe shall be made of one of the following materials:

(1) Galvanized steel

(2) Stainless steel

(3) Internal/external corrosion-resistant pipe in accordance with the foam manufacturer’s specification forcompatibility and acceptable to the authority having jurisdiction pipe

(4) Unprotected carbon steel pipe, when the discharge devices are closed to the atmosphere

Statement of Problem and Substantiation for Public Comment

I have a large aircraft hangar we are presently working on. The AHJ is adament about following NFPA #11 just because it says galvanized pipe? In 2010 they talk about deluge systems?? A system utilizing generators is a deluge system? Explain to me the difference in operation of a deluge water sprinkler system and a deluge system utilzing generators? Both are open ended systems. Tyco/Cheguard are adament that galvanized pipe should not be used but NFPA #11 says it has to be. This has put us in a very difficult position. All manufacturers are telling us that black pipe is the standard for installation in hangars. Even there technical data sheets clearly say black pipe is acceptable. We need to take the AHJ out of the picture and have a clear path what is acceptable and what is not. The manufacturer says there are many more issues if galvanized is used on solution pipe?? as opposed to using black?

Submitter Information Verification

Submitter Full Name: PAUL CHARETTE

Organization: ROYAL FIRE PROTECTION INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 10 11:53:52 EDT 2013

Committee Statement

CommitteeAction:

Rejected

Resolution: The manufacturer's representatives to the technical committee clarified that they are not opposed tothe requirement for galvanized pipe in foam solution piping. No technical substantiation wasprovided to deviate from the revisions accepted at the First Draft. The AHJ can be an architect,insurer, or fire code official. The proposed revision would leave the use of alternative corrosionresistant pipe open-ended.

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Public Comment No. 40-NFPA 11-2013 [ Section No. 4.7.2.1 ]

4.7.2.1

Foam solution pipe shall be made of one of the following materials:

(1) Galvanized steel

(2) Stainless steel

(3) Internal/external corrosion-resistant pipe in accordance with the foam manufacturer’s specification forcompatibility and acceptable to the authority having jurisdiction

(4) Unprotected carbon steel pipe, when filled with foam solution and the discharge devices are closed tothe atmosphere

Statement of Problem and Substantiation for Public Comment

This corrects the contradiction from the First Revision substantiation to address the resulting corrosion and the condition when carbon steel pipe is permitted.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Affilliation: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 17:42:44 EST 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-12-NFPA 11-2014

Statement: This corrects the contradiction from the First Revision substantiation to address the resultingcorrosion and the condition when carbon steel pipe is permitted.

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Public Comment No. 38-NFPA 11-2013 [ Section No. 4.7.2.2 ]

4.7.2.2

Pipe carrying foam concentrate shall not be galvanized.

Statement of Problem and Substantiation for Public Comment

This requirement is not appropriate for this section and is covered under as a requirement in Foam Concentrate piping in Section 4.7.1.3 as identified by Richard Coppola in First Revision ballot

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Affilliation: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 17:32:01 EST 2013

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-13-NFPA 11-2014

Statement: This requirement is not appropriate for this section and is covered under as a requirement inFoam Concentrate piping in Section 4.7.1.3 as identified by Richard Coppola in First Revisionballot

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Public Comment No. 39-NFPA 11-2013 [ Section No. 4.7.2.5 ]

4.7.2.5

Pipe with within the hazard area shall be able to withstand the anticipated exposure to fire.

Statement of Problem and Substantiation for Public Comment

Editorial error identified by Blake Shugarman in First Revision ballot

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Affilliation: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 17:35:56 EST 2013

Committee Statement

Committee Action: Accepted

Resolution: SR-14-NFPA 11-2014

Statement: Editorial error.

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Public Comment No. 2-NFPA 11-2013 [ Section No. 4.7.3.1.1 ]

4.7.3.1.1

Foam concentrate piping shall use fittings made of the following materials, as appropriate to the foamconcentrate pipe material:

(1) Brass (red or naval)

(2) Bronze

(3) Stainless steel (304 or 316)

(4) Other material, in accordance with the foam concentrate manufacturer’s certification of compatibilityand with approval from AHJ .

Statement of Problem and Substantiation for Public Comment

We have to take the AHJ out of this because it leaves them to make decisions where in most cases they are not qualified to do so. Let's make the decision rather than let less competent people make these decisions. It is leaving us contractors in the middle and making it very difficult to do proper busines.

Submitter Information Verification

Submitter Full Name: PAUL CHARETTE

Organization: ROYAL FIRE PROTECTION INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 10 12:07:42 EDT 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-15-NFPA 11-2014 The AHJ can be an architect, insurer, or fire code official. The proposedrevision would leave the use of alternative fittings open-ended.

Statement: Field experience has demonstrated that foam concentrate piping and fittings should not beconstructed with carbon steel or galvanized pipe. The committee recognizes that other materialsmay be appropriate, but it is not the intent of this allowance to permit carbon steel or galvanizedpipe.

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Public Comment No. 3-NFPA 11-2013 [ Section No. 4.7.3.1.2 ]

4.7.3.1.2

Foam concentrate fittings shall not be carbon steel or galvanized. Design to manufacturers specification

Statement of Problem and Substantiation for Public Comment

Because NFPA and the manufacturers are far apart on there opinions on this subject. NFPA is saying ss steel and the manufacturers are saying bthere foam concentrate is fine going with carbon steel.

Submitter Information Verification

Submitter Full Name: PAUL CHARETTE

Organization: ROYAL FIRE PROTECTION INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 10 12:11:39 EDT 2013

Committee Statement

Committee Action: Rejected

Resolution: See SR 15.

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Public Comment No. 27-NFPA 11-2013 [ Section No. 5.2 [Excluding any Sub-Sections] ]

The following methods for protecting exterior fixed-roof tanks shall be included within this section and shallnot be considered to be in any order of preference:

(1) Foam monitors and handlines

(2) Surface application with fixed foam discharge outlets

(3) Surface application with self-expanding foam introduction device shall be designed according toChapter 8.

(4) Subsurface application

(5) Semisubsurface injection methods

Statement of Problem and Substantiation for Public Comment

According to the current edition of NFPA 11 A.5.2.6.1, "foam generation equipment (foam chamber) disruption often arises as a result of an initial tank explosion or the presence of fire surrounding the tank". Therefore different foam introduction device is recommended. The self-expanding foam introduction device is attached to the inner shell of the cone roof tank on the whole circumference under the weak seam and in case of an explosion, which is considered as one of the most frequent sources of cone roof tank fires, it acts also like a support frame. The self-expanding foam intoduction device directs foam to the tank shell and then the foam flows down on the whole surface of the inner tank shell cooling it very effectively. The one and only function of the self-expanding foam introduction device is to release foam, hence malfunction is excluded. NFPA 11 A.5.3.4.3 states: "Foam can fail to seal against the tank shell as a result of prolonged free burning to agent discharge". The recommended foam introduction device can eliminate this problem also.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:29:07 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 28-NFPA 11-2013 [ New Section after 5.3.3.2 ]

5.3.3.3 Full Surface Area Protection. Full surface area protection with self-expandingfoam introduction device shall be designed according to Chapter 8.

Statement of Problem and Substantiation for Public Comment

Because of the limitations of the flow-through systems, the available foam solution application rate limited by the fire pumps, and the foam discharge device, and the point-like arrangement of foam introduction, fixed systems were not considered as an effective way of open-top floating roof tank full surface fire protection, therefore mobile protection became the applied strategy to fight against these fires. Mobile applications need preparation time. During this preparation which takes a lot of time, the whole tank is exposed to the heat and flames of the fire, the terminal is exposed to the risk of fire escalation and even to boilover scenario. According to NFPA 11 A.5.6 "The speed of system operation is always critical in minimizing life and property loss". Self-expanding Foam System is a perfectly pre-engineered fixed system which is capable to put out a large scale full surface fire in minutes. The huge catastrophes, fatalities and unacceptable environmental pollution that happaned in the last decades can be avoided.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:33:40 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 29-NFPA 11-2013 [ Section No. 5.3.4.1 ]

5.3.4.1

The following methods for fire protection of seals in open-top floating roof tanks shall be as required in5.3.5 through 5.3.7:

(1) Fixed discharge outlets

(2) Foam handlines

(3) Foam monitors

(4) Self-expanding foam introduction device application shall be designed according to Chapter 8.

Statement of Problem and Substantiation for Public Comment

In case of a rim seal fire only, the curtain-like foam introduction of the Self-expanding Foam Introduction Device results in a very effective pattern of foam application. The design calculation shall be the same as for full suface fires. In case of a given fire, the released foam volume prevents escalation to full surface fire. The additional foam release method on the floating roof is an applied strategy in fire escalation prevention.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:37:40 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 30-NFPA 11-2013 [ New Section after 7.20 ]

Insertion of a new Chapter 8 according to the attached FFGR-PC-NFPA11-01 file and renumbering thefollowing chapters

Additional Proposed Changes

File Name Description Approved

FFGR-PC-NFPA11-01.pdf FFGR-PC-NFPA11-01 - The Self Expanding Foam System Design

TUV_FF_en.jpg EN 13565-2 system compliance, TUV Germany

FoamFatale_manual.pdf FoamFatale Manual

Statement of Problem and Substantiation for Public Comment

Without the recognition of SEFS within NFPA standards and codes, this technology and system could not enter to the marketplace as NFPA is the most recognized body and its standards are the most adopted worldwide in fire protection. Listing and/or approval of the system or the components cannot be accomplished without NFPA recognition.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 04:45:58 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 31-NFPA 11-2013 [ Section No. 8.3.3 ]

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8.3.3

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The plans shall include or be accompanied by the following information, where applicable:

(1) Name of owner and occupant

(2) Location, including street address

(3) Point of compass

(4) Full height cross section, or schematic diagram, includng structural member information constructionof dike and tank

(5) Size of supply main and whether dead end or circulating — if dead end, direction and distance tonearest circulating main — and water flow test results and system elevation relative to test hydrant

(6) Other sources of water supply with pressure or elevation

(7) Make, type, model, and model number of discharge devices

(8) Pipe type and schedule of wall thickness

(9) Nominal pipe size and cutting lengths of pipe (or center-to-center dimensions).

(10) Types of fittings and joints, and locations of all welds and bends. The contractor shall specify ondrawing any sections to be shop welded and types of fittings or formations to be used.

(11) Types and locations of hangers, sleeves, braces, and methods of securing foam chambers or otherdischarge devices when applicable

(12) All control valves, check valves, drain pipes, and test connections

(13) Piping provisions for flushing

(14) For hydraulically designed systems, the information on the hydraullic data nameplate

(15) Graphic representations of the scale used on all plans

(16) Name and address of contractor

(17) Hydraulic reference points shown on the plan that correspond with comparable reference points on thehydraulic calculation sheets

(18) Information about backflow preventers (manufacturer, size, type)

(19) Sizes and locations of hydrants, showing sizes and numbers of outlets and whether outlets are to beequipped with independent gate valves. Whether hose houses and equipment are to be provided, andby whom, shall be indicated. Static and residual hydrants that were used in flow tests shall be shown

(20) Sizes, locations, and piping arrangements of fire department connections

(21) Physical details of the hazard, including the location, arrangement, and hazardous materials involved

(22) Type and percentage of foam concentrate

(23) Required solution application rate

(24) Submergence volume calculations

(25) Water requirements

(26) Calculations specifying required amount of concentrate

(27)

(28) Calculation specifying required amount of air

(29) CAFS flow calculations report

(30) SEFS flow calculations report

(31) Self-expanding foam volume and foam blanket thickness calculations

(32) Identification and capacity of all equipment and devices

(33) Location of piping, detection devices, operating devices, generators, discharge outlets, and auxiliaryequipment

(34) Schematic wiring diagram

(35) Explanations of any special features

* Hydraulic calculations

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Statement of Problem and Substantiation for Public Comment

These calculations are necessary for the proper design of the Self-expanding Foam System (SEFS).

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 05:27:41 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 32-NFPA 11-2013 [ New Section after 11.2.5.2 ]

11.2.5.3 All self-expanding foam system piping interiors shall be carefully visuallyexamined and, if necessary, cleaned during installation of the pipe.

11.2.5.4 Self-expanding foam system piping shall be flushed after installation. The foamflow shall be unobstructed in the piping system.

Statement of Problem and Substantiation for Public Comment

The way of the foam flow shall be unobstructed by the residues of the installation.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 05:34:00 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 33-NFPA 11-2013 [ New Section after 11.6.2.1 ]

11.6.2.2 For self-expanding foam systems, the following data shall be recorded as part of anyfoam test:

(1) Self-expanding foam pressure vessel pressure

(2) System pressure at the control valve

(3) Self-expanding foam concentration

Statement of Problem and Substantiation for Public Comment

These data are necessary to collect ensuring proper system operation.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 05:40:39 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 34-NFPA 11-2013 [ New Section after 12.6.3 ]

12.7 Self-Expanding Foam Inspection

12.7.1 At least annually, an inspection shall be made of self-expanding foam and its pressurevessels for evidence of excessive sludging or deterioration.

12.7.2 Samples of self-expanding foam shall be taken for quality condition testing.

12.7.3 Quantity of self-expanding foam in pressure vessel shall meet design requirements.

Statement of Problem and Substantiation for Public Comment

Regular inspection of the self-expanding foam shall be carried out in order to ensure that the extinguishing foam is in ready-to-use condition.

Submitter Information Verification

Submitter Full Name: CHRISTOS SIDEROPOULOS

Organization: FOAMFATALE GREECE LTD.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 05:49:52 EST 2013

Committee Statement

Committee Action: Rejected

Resolution: See Public Comment #20 (1.1.1).

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Public Comment No. 5-NFPA 11-2013 [ Section No. A.3.3.3.3 ]

A.3.3.3.3 4 Non-Air-Aspirating Discharge Devices.

When discharging AFFF or FFFP solution, they generate an effective AFFF or FFFP with a dischargepattern similar to the water discharge pattern.

Statement of Problem and Substantiation for Public Comment

The section in chapter 3 is being renumbered.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 4-NFPA 11-2013 [Section No. 3.3.3]

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 11:48:54 EDT 2013

Committee Statement

CommitteeAction:

Rejected

Resolution: The proposed change is editorial and will be incorporated automatically by the NFPA editorialstaff.

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Public Comment No. 10-NFPA 11-2013 [ Section No. A.3.3.23.1.1 ]

A.3.3.23.1.1 In-Line Balanced Pressure Proportioning.

A bladder tank in conjunction with a water pressure–reducing valve upstream of the proportioner can beutilized in place of the foam concentrate pump package. See Figure A.3.3.23.1.1(a) and FigureA.3.3.23.1.1(b).At all design flow rates, the constant foam concentrate pressure is greater than themaximum water pressure at the inlet to the in-line balanced pressure proportioner.A pressure balancingvalve integral to the in-line balanced pressure proportioner regulates the foam concentrate pressure to bebalanced to incoming water pressure.

Figure A.3.3.23.1.1(a) In-Line Balanced Pressure (Pump-Type) Proportioning with Multiple InjectionPoints.

Figure A.3.3.23.1.1(b) In-Line Balanced Pressure (Bladder Tank Type) Proportioning with MultipleInjection Points.

Statement of Problem and Substantiation for Public Comment

This just moves information from the definition, sentences 2 and 3. Alternately this information could be placed somewhere in the body of the standard where it would be enforceable.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 9-NFPA 11-2013 [Section No. 3.3.23.1.1]

Submitter Information Verification

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Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 14:15:16 EDT 2013

Committee Statement

Committee Action: Rejected

Resolution: This type of proportioner requires more than one sentence to define it, due to its complexity.

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Public Comment No. 8-NFPA 11-2013 [ Section No. A.3.3.27.2 ]

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A.3.3.27.2 Pressure Proportioning Tank.

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This method employs water pressure as the source of power. This device is only suitable for foams havinga specific gravity of at least 1.15. With this device, the water supply pressurizes the foam concentratestorage tank. At the same time, water flowing through an adjacent venturi or orifice creates a pressuredifferential. The low-pressure area of the venturi is connected to the foam concentrate tank, so that thedifference between the water supply pressure and this low-pressure area forces the foam concentratethrough a metering orifice and into the venturi. Also, the differential across the venturi varies in proportion tothe flow, so one venturi will proportion properly over a wide flow range. The pressure drop through this unitis relatively low. [See Figure A.3.3.27.2(a).]

A special test procedure is available to permit the use of a minimum amount of concentrate when thepressure proportioner system is testing.

The pressure proportioning tank has the following limitations:

(1) Foam concentrates with specific gravities similar to water can create a problem when mixed.

(2) The capacity of these proportioners can be varied from approximately 50 percent to 200 percent oftheir rated capacity.

(3) The pressure drop across the proportioner ranges from 34 kPa to 207 kPa (5 psi to 30 psi), dependingon the volume of water flowing within the capacity limits of item (2).

(4) When the concentrate is exhausted, the system must be turned off, and the tank drained of water andrefilled with foam concentrate.

(5) Since water enters the tank as the foam concentrate is discharged, the concentrate supply cannot bereplenished during operation, as with other methods.

(6) This system proportions at a significantly reduced percentage at low flow rates and should not be usedbelow minimum design flow rate.

A diaphragm (bladder) pressure proportioning tank also uses water pressure as a source of power. Thisdevice incorporates all the advantages of the pressure proportioning tank with the added advantage of acollapsible diaphragm that physically separates the foam concentrate from the water supply.

Diaphragm pressure proportioning tanks operate through a similar range of water flows and according tothe same principles as pressure proportioning tanks. The added design feature is a reinforced elastomericdiaphragm (bladder) that can be used with all concentrates listed for use with that particular diaphragm(bladder) material. [See Figure A.3.3.27.2(b).]

The proportioner is a modified venturi device with a foam concentrate feed line from the diaphragm tankconnected to the low-pressure area of the venturi. Water under pressure passes through the controller, andpart of this flow is diverted into the water feed line to the diaphragm tank. This water pressurizes the tank,forcing the diaphragm filled with foam concentrate to slowly collapse. This forces the foam concentrate outthrough the foam concentrate feed line and into the low-pressure area of the proportioner controller. Theconcentrate is metered by use of an orifice or metering valve and mixes in the proper proportion with themain water supply, sending the correct foam solution downstream to the foam makers.

The limitations are the same as those listed for the pressure proportioning tank, except that the system canbe used for all types of concentrates.

Figure A.3.3.27.2(a) Typical Arrangement of Pressure Proportioning Tank.

Figure A.3.3.27.2(b) Diaphragm (Bladder) Proportioning Tank.

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Statement of Problem and Substantiation for Public Comment

This is a sentence that came from the definition and is being moved.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 7-NFPA 11-2013 [Section No. 3.3.27.2]

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Affilliation: NFPA GOT

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 16 12:42:31 EDT 2013

Committee Statement

Committee Action: Rejected

Resolution: See Second Revision No. 3.

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Public Comment No. 37-NFPA 11-2013 [ New Section after A.4.3.1.2 ]

A.4.3.1.4(4)

The method of measurement should be identified including the device used and parameters such asspindle speed and revolutions per minute, such as when using a Brookfield viscometer.

Statement of Problem and Substantiation for Public Comment

This text will provide clarification to the new requirement that has been proposed on the First Revision.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Affilliation: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 17:17:44 EST 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-20-NFPA 11-2014

Statement: The new annex text will provide clarification to the new requirement that has been proposed onthe First Revision. See attachment.

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Public Comment No. 35-NFPA 11-2013 [ Section No. D.5.2.2 ]

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D.5.2.2 Surrogate Liquid Test Method.

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In this approach, surrogate test liquids are formulated specifically to simulate the flow behavior (viscositycharacteristics) and approximate conductivity or refractive index of the foam concentrate used in thesystem. An example of a graph generated from the recorded data is shown in Figure D.5.2.2(a) .

Figure D.5.2.2(a) Plot of Real-Time Test Data Gathered from Surrogate Liquid Injection Rate Test.

For initial system commissioning, the surrogate liquid can be placed directly in the foam system tank forinjection rate tests and then flushed out before filling the tank with foam concentrate. After the system hasbeen filled with foam concentrate it can still be tested using a surrogate test liquid, but installation of someadditional connections on the proportioning system piping are required. These additional connectionsenable the surrogate test liquid to be injected into the proportioning system in place of the foamconcentrate already in the foam storage tank. Since there are many types of proportioning systems, thetest set-up arrangement varies according to the system type.

Figure D.5.2.2(b) through Figure D.5.2.2(d) are illustrations of surrogate liquid test set-up arrangementsfor types of the most commonly used proportioning systems.

Figure D.5.2.2(b) Bladder Tank Proportioning System (Containing Foam) Setup for SurrogateLiquid Type Test.

Figure D.5.2.2(c) In-Line Balanced Pressure (Pump Type) System Using Surrogate Liquid Method.

Figure D.5.2.2(d) Balanced Pressure Pump System Using Surrogate Liquid Method.

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Additional Proposed Changes

File Name Description Approved

Figure_D_5_2_2_a_edit.docx Edit to header - delete text after "Flow vs. Injection Rate"

Statement of Problem and Substantiation for Public Comment

The text in the header referneces a specific commercial test - this should be deleted. Just describe the graphic as Flow vs. Injection Rate

Submitter Information Verification

Submitter Full Name: Joseph Scheffey

Organization: Hughes Associates, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 08:18:41 EST 2013

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-17-NFPA 11-2014

Statement: The text in the header of Figure D.5.2.2(a) references a specific commercial test. The referenceshould be deleted to leave just "Flow vs. Injection Rate".

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