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Public Input No. 79-NFPA 409-2013 [ Section No. 1.1 ] 1.1 Scope. 1.1.1 This standard contains the minimum requirements for the proper construction of aircraft hangars and protection of aircraft hangars from fire. 1.1.2 This standard applies only to buildings or structures used for aircraft storage, maintenance, or related activities. Fire protection systems shall be designed to minimize fire damage to the hangar structure, and to the extent practicable, the hangar’s contents, including spare parts, maintenance equipment and aircraft. Other uses within an aircraft hangar shall be protected in accordance with other applicable NFPA Standards. Additional Proposed Changes File Name Description Approved NFPA_409_1.1_Extend_scope.docx Cover Sheet Statement of Problem and Substantiation for Public Input 1.1.1 no change 1.1.2 The value of modern commercial and military aircraft within a hangar is often an order of magnitude higher than the hangar itself. NFPA 409 needs to provide in addition to life safety, protection for all the property within a hangar not just for the building. Aircraft are notoriously sensitive to fire, FM Global Loss Prevention Data Sheet 7-93N: “Tests by the US Federal Aviation Authority and others indicate that an aircraft fuselage skin will fail within 45 seconds from a flammable liquid fire exposure” (exposure being interpreted as engulfed in flames). On the other hand NFPA 69 (Explosion Prevention Systems) defines systems that extinguish fires within fractions of a second. So a fire protection system able to extinguish a fuel spill fire below an aircraft within, 20 to 30 seconds has to be a realistic possibility. Clearly, setting a minimum requirement of “protecting aircraft from any significant damage” is not reasonably practicable, but it would seem to be an acceptable outcome if fire damage is limited to the replacement of a few sections of fuselage skin, which would seem readily achievable using flame detection and fast acting foam delivery. Submitter Information Verification Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Street Address: City: State: Zip: Submittal Date: Fri Jul 12 08:55:24 EDT 2013 Committee Statement Resolution: An available protection scheme has not been developed that has been proven to extinguish a fire before the aircraft is damaged extensively. Such protection would be beyond the scope of what is considered to be a "minimum standard". National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 1 of 80 7/22/2015 2:42 PM

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Page 1: Statement of Problem and Substantiation for Public Input€¦ · 3.3.11 Membrane Hangar. The flexible structural fabric or film that supports the imposed loads and transmits them

Public Input No. 79-NFPA 409-2013 [ Section No. 1.1 ]

1.1 Scope.

1.1.1

This standard contains the minimum requirements for the proper construction of aircraft hangars andprotection of aircraft hangars from fire.

1.1.2

This standard applies only to buildings or structures used for aircraft storage, maintenance, orrelated activities. Fire protection systems shall be designed to minimize fire damage to the hangarstructure, and to the extent practicable, the hangar’s contents, including spare parts, maintenanceequipment and aircraft. Other uses within an aircraft hangar shall be protected in accordance withother applicable NFPA Standards.

Additional Proposed Changes

File Name Description Approved

NFPA_409_1.1_Extend_scope.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

1.1.1 no change1.1.2 The value of modern commercial and military aircraft within a hangar is often an order of magnitude higher than the hangar itself. NFPA 409 needs to provide in addition to life safety, protection for all the property within a hangar not just for the building.

Aircraft are notoriously sensitive to fire, FM Global Loss Prevention Data Sheet 7-93N: “Tests by the US Federal Aviation Authority and others indicate that an aircraft fuselage skin will fail within 45 seconds from a flammable liquid fire exposure” (exposure being interpreted as engulfed in flames). On the other hand NFPA 69 (Explosion Prevention Systems) defines systems that extinguish fires within fractions of a second.

So a fire protection system able to extinguish a fuel spill fire below an aircraft within, 20 to 30 seconds has to be a realistic possibility. Clearly, setting a minimum requirement of “protecting aircraft from any significant damage” is not reasonably practicable, but it would seem to be an acceptable outcome if fire damage is limited to the replacement of a few sections of fuselage skin, which would seem readily achievable using flame detection and fast acting foam delivery.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 08:55:24 EDT 2013

Committee Statement

Resolution: An available protection scheme has not been developed that has been proven to extinguish a firebefore the aircraft is damaged extensively. Such protection would be beyond the scope of what isconsidered to be a "minimum standard".

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Public Input No. 41-NFPA 409-2013 [ Section No. 3.3.11 ]

3.3.11 Membrane Hangar .

The flexible structural fabric or film that supports the imposed loads and transmits them to the supportingstructure. The membrane carries only tension or shear in the plane of the membrane.

Statement of Problem and Substantiation for Public Input

Definition is for "membrane", not "membrane hangar".

Submitter Information Verification

Submitter Full Name: LIANE OZMUN

Organization: FRANKFURT-SHORT-BRUZA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 02 18:32:05 EDT 2013

Committee Statement

Resolution: FR-12-NFPA 409-2013

Statement: The definition has been modified to better represent the term.

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Public Input No. 78-NFPA 409-2013 [ New Section after 3.3.17 ]

3.3.18 Foam Concentrate.

For the purpose of determining the concentrate percentage, the definition of ‘Foam Concentrate’shall be also mean any substitutes for actual foam producing liquids, such as substituting AFFFwith plain or colored water.

Additional Proposed Changes

File Name Description Approved

nfpapublicinputform_-_Kaare_Holm_NoFoam_Systems_section_3-3-18.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

NFPA 412 recently adopted the concept of ‘input based testing’ as an optional alternative to ‘output based testing’ (such as the refractometer test for determining the concentrate percentage produced by the proportioner). The proposed new definition above would effectively allow the AHJ the same privilege under this revised NFPA 409.Input based testing simply defines that you can determine the concentrate percentage from the proportioner by measuring the flowrates of both water and foam concentrate being put into the proportioner, and this concentrate proportion will by natural logic be the same as the foam/water solution coming out of the proportioner (which is what is currently being sampled and then analyzed with a refractometer to determine the concentrate percentage). As is well known and accepted, the proportioner does not need to be adjusted when changing from one type of foam concentrate to another, because it will mix any foam concentrate liquid to the same percentage. Likewise, it will mix plain or colored water to the same proportion as well. Therefore, it is possible to test the proportioner by replacing foam concentrate with plain or colored water. Testing with colored water instead of AFFF for that purpose will eliminate significant clean-up cost and associated environmental issues, and in doing so it would be more acceptable for the AHJ to test more frequently.This approach is already demonstrated by the Navy, and accepted broadly by the DoD, and new installations (foam systems in hangers) are in construction with requirements of being able to test with colored water instead of with AFFF concentrate. The basic principle being used is to simultaneously measure the water-pipe’s and the concentrate-pipe’s flow-rates with external flow meters, before they enter the proportioner, and used math to calculate the concentrate percentage.It would be in the interest of this standard to allow the AHJ to perform parts of the testing with water, while still being in full compliance with the NFPA 409.The proposed change is simply an added tool/approach, which does not take away from anyone who wishes to test as has been done in the past. The proposed change also does not modify the requirement to test with actual foam for any other purpose, as required in the standard, other than for testing the proportioner’s performance.

Submitter Information Verification

Submitter Full Name: KAARE HOLM

Organization: NOFOAM SYSTEMS, EGE

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 08:22:02 EDT 2013

Committee Statement

Resolution: The appropriate definition of "foam concentrate" is found in NFPA 11.

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Public Input No. 88-NFPA 409-2013 [ New Section after 3.3.17 ]

3.3.x Foam Generators . Foam generators mix air with foam solution to deliver expanded foamto a fire or risk area.

Low-expansion generators deliver expanded foam with an expansion ratios approximately 4 to10:1.

High-expansion generators deliver expanded foam with an expansion ratios approximately 500to 1200:1.

High expansion generators can be fan-driven or use air-induction to introduce air to the foamsolution.

Outside-air high-expansion generators use air from outside the fire compartment.

Inside-air high-expansion generators use air from inside the fire compartment.

Additional Proposed Changes

File Name Description Approved

NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

Definition of the foam generator types is suggested as helpful.Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound.Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types. Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:29:18 EDT 2013

Committee Statement

Resolution: The appropriate definitions for these terms are found in NFPA 11.

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Public Input No. 80-NFPA 409-2013 [ New Section after 5.2.4 ]

5.2.5 Fixed water or foam-water systems shall be permitted to be used in lieu of the passive fireresistance separations detailed in 5.2.1, 5.2.2, 5.2.3 & 5.2.4 provided they are automaticallyoperated, installed on both sides of the wall, and designed in accordance with 5.6, and other NFPAstandards as appropriate.

Additional Proposed Changes

File Name Description Approved

NFPA_409_5.2_Internal_Separations.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

NFPA 409 has long allowed active fire separation, in its requirement to protect steel columns without passive fire rated covering by spraying water on them. This proposal is an extension of that principle.It is intended that this would allow the installation of sprinklers in low rise offices, workshops, etc. adjoining hangars as a substitute for fire rated walls, doors and shutters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 08:57:41 EDT 2013

Committee Statement

Resolution: Section 5.6 applies to columns, but is not appropriate for walls. References to "other NFPAstandards" is not specific enough.

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Public Input No. 42-NFPA 409-2013 [ Section No. 5.9.1 ]

5.9.1 *

Landing gear pits, ducts, and tunnels tunnels which are located below floor level shall be designed onthe premise that flammable liquids and vapor will be present at all times . Materials , unless they do notconnect to the hangar floor or the classified area above the floor. Materials and equipment shall beimpervious to liquids and shall be fire resistant or noncombustible.

Statement of Problem and Substantiation for Public Input

This paragraph before modification appears to apply to open landing pits and ducts and tunnels which connect to the hangar floor or classified area. As written, it also could apply to a tunnel below the hangar floor that does not have openings into the hangar or hangar floor, but only sealed piping or conduit which enters the hangar from the tunnel. It could also apply to a duct which passes below the hangar slab, but does not communicate with the hangar floor.

The modification limits the classified area to the landing gear pits, ducts and tunnels which communicate with the hangar classified areas.

Submitter Information Verification

Submitter Full Name: LIANE OZMUN

Organization: FRANKFURT-SHORT-BRUZA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 02 18:37:47 EDT 2013

Committee Statement

Resolution: There is concern that the areas in and around a hangar will be contaminated with hydrocarbon liquidsand vapors over time. These contaminates could create a classified atmosphere in tunnels that arelocated under the hangar, although the tunnels are not directly connected to the hangar floor. Tunnelsoutside the scope of 409 are not included in the requirements of 5.9.1.

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Public Input No. 81-NFPA 409-2013 [ Section No. 5.11.2.2 ]

5.11.2.2 *

Floor trench drainage systems shall be provided to restrict the spread of fuel in order to reduce the fire andexplosion hazards from fuel spillage , and prevent fire spread to aircraft down-slope from a burning fuelspill .

Additional Proposed Changes

File Name Description Approved

NFPA_409_5.11.2_Hangar_Floor_Trench_Drainage.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

The need for these changes is self evident.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 08:59:24 EDT 2013

Committee Statement

Resolution: Provided substantiation is inadequate.

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Public Input No. 49-NFPA 409-2013 [ Section No. 5.11.2.4 ]

5.11.2.4 *

Trench drainage systems in aircraft storage or servicing areas shall be designed and constructedso that they have a capacity large enough to prevent buildup of flammable liquids and water overthe drain inlet when all fire protection systems and 125 percent of the sum of all closed head automaticsprinkler systems, hose streams allowances and hand hose streams are discharging at the design rate. The discharge of low level foam systems, foam-water deluge sprinklers systems, and supplementary foamsystems are excluded from the required drainage capacity.

Statement of Problem and Substantiation for Public Input

This section is a remnant unchanged over the years from older editions of the standard when plain water deluge systems were permitted and the concept was to flush fuel off the floor. Since foam agents blanket and secure spilled fuel, this requirement offers little benefit while imposing a high cost burden. This drainage makes little sense in high expansion foam applications when much of the liquid is bound up in bubbles. 125% is intended to provide a reasonable safety factor in removing plain water from the sprinkler system which will tend to flow beneath the foam.

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:04:41 EDT 2013

Committee Statement

Resolution: The proposal does not address the true water flow that could be expected.

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Public Input No. 82-NFPA 409-2013 [ Section No. 5.11.2.10 ]

5.11.2.10

Oil separators and flame traps shall be provided for the trench drainage systems serving all aircraftstorage and servicing areas. These separators shall be permitted to serve each hangar trench drainagesystem or a group of hangar trench drainage systems or be installed as part of a general airport trenchdrainage system.

Additional Proposed Changes

File Name Description Approved

NFPA_409_5.11.2_Hangar_Floor_Trench_Drainage.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

The need for these changes is self evident.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:01:04 EDT 2013

Committee Statement

Resolution: "Flame trap" is not a recognized term. The substantiation was inadequate to explain the submitter'sintent.

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Public Input No. 30-NFPA 409-2013 [ Section No. 5.12.2 ]

5.12.2

In aircraft storage and servicing areas, no heating, ventilating, and air-conditioning equipment employingan open flame or glowing element shall be installed, other than as provided for in 5.12.5 . Open flameshall mean burners that utilize combustion air from within the aircraft storage and servicing area. Equipment with sealed burners and ducted combustion air shall be permitted to be installed within theaircraft the aircraft storage and servicing area.

Statement of Problem and Substantiation for Public Input

Use of term "open flame" needs clarification. The HVAC industry defines this as a visible flame or a flame that pulls air from within the space the the equipment is installed.

Submitter Information Verification

Submitter Full Name: STEPHEN TAMANKO

Organization: Bascon Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Mar 05 13:07:21 EST 2013

Committee Statement

Resolution: The current wording would not necessarily prohibit the use of sealed burners and ducted combustionair that do not comply with 5.12.5. The definition of an open flame device should be interpreted inaccordance with standard HVAC industry practices.

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Public Input No. 31-NFPA 409-2013 [ Section No. 5.12.4 [Excluding any Sub-Sections] ]

In aircraft storage and servicing areas, heating, ventilating, and air-conditioning systems employingrecirculation of air within aircraft storage and servicing areas with open flame or glowing element shall havereturn air openings not less than 3 m (10 ft) above the floor and in addition must be in accordance with5 .12.5. Supply air openings shall not be installed in the floor and shall be at least 152 mm (6 in.) from thefloor measured to the bottom of the opening.

Statement of Problem and Substantiation for Public Input

The way this is written, no air rotation type heaters can be utilized including but not limited to hot water coil type.

Submitter Information Verification

Submitter Full Name: STEPHEN TAMANKO

Organization: Bascon, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Mar 05 14:05:22 EST 2013

Committee Statement

Resolution: The requirement is concerned with more than just ignition sources. One additional concern is theredistribution of flammable vapors that might be at the floor level to other areas within the hangar.

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Public Input No. 24-NFPA 409-2013 [ Section No. 5.15.1 ]

5.15.1*

Aircraft storage and servicing areas, shall be provided with grounding facilities for removal and control ofstatic electrical accumulations on aircraft while aircraft are stored or undergoing servicing in a hangar shallbe permitted in accordance with 5.15.2 and 5.15.3.

Statement of Problem and Substantiation for Public Input

Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment.

Submitter Information Verification

Submitter Full Name: Donald Cook

Organization: Shelby County Department of De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 28 15:46:30 EST 2013

Committee Statement

Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply withNFPA 410 or other standards for aircraft maintenance operations. Whether and how the groundingfacilities are used is not within the scope of NFPA 409.

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Public Input No. 28-NFPA 409-2013 [ Section No. 5.15.2 ]

5.15.2

Floor-grounding receptacles shall be provided permitted and where installed shall be either groundedthrough individual driven electrodes or electrically bonded together in a grid system and the entire systemgrounded to underground metal piping, such as cold water piping, or driven electrodes. Where drivenelectrodes are used, they shall consist of 15.9 mm ( 5?8 in.) diameter or larger metal rods driven at least 1.5m (5 ft) into the ground. Floor-grounding receptacles shall be designed to minimize the tripping hazard.

Statement of Problem and Substantiation for Public Input

Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment.

Submitter Information Verification

Submitter Full Name: Donald Cook

Organization: Shelby County Department of De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 28 16:22:32 EST 2013

Committee Statement

Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply withNFPA 410 or other standards for aircraft maintenance operations. Whether and how the groundingfacilities are used is not within the scope of NFPA 409.

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Public Input No. 83-NFPA 409-2013 [ Section No. 5.17.1 ]

5.17.1

Draft curtains shall be required in Group I hangars where heat actuated fire detection devices are locatedbelow the roof .

Additional Proposed Changes

File Name Description Approved

NFPA_409_5.17_Draft_Curtains.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

Draft curtains are designed to collect and concentrate hot air and fire gasses to increase the speed at which thermal devices respond. When other types of fire detection are used draft curtains do not assist fire protection, and are not economically justified.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:02:57 EDT 2013

Committee Statement

Resolution: The requirement for draft curtains to be installed in all Group I hangars is based on testing thatshowed that the draft curtains substantially improved the response of the closed-head sprinklersystem.

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Public Input No. 51-NFPA 409-2013 [ New Section after 6.1.1 ]

new 6.1.6

Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11,except that foam system piping shall not be required to be galvanized.

Statement of Problem and Substantiation for Public Input

NFPA 11 (2010 edition) 4.7.2.1 states "Galvanized pipe shall be used." While this requirement maybe useful for tanks farms it is inappropriate for foam systems inside hangars. Galvanized piping is generally incompatible with the foams. It contributes nothing to system corrosion resistance and may be harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentially releasing flakes of zinc which may clog orifices. FM Global and others are eliminating requirements for galvanized piping.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 52-NFPA 409-2013 [New Section after 7.1]

Public Input No. 53-NFPA 409-2013 [Section No. 9.14.5.3]

Public Input No. 54-NFPA 409-2013 [Section No. 6.2.3.3]

Public Input No. 55-NFPA 409-2013 [Section No. 6.2.5.2]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:23:04 EDT 2013

Committee Statement

Resolution: FR-13-NFPA 409-2013

Statement: NFPA 11 (2010 edition) 4.7.2.1 states "Galvanized pipe shall be used." While this requirement may beuseful for tank farms, it is inappropriate for foam systems inside hangars. Galvanized piping isgenerally incompatible with the foams. It contributes nothing to system corrosion resistance and maybe harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentiallyreleasing flakes of zinc which may clog orifices.

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Public Input No. 47-NFPA 409-2013 [ Section No. 6.1.1 ]

6.1.1

The protection of aircraft storage and servicing areas for Group I aircraft hangars shall be in accordancewith any one of the following:

(1) A foam-water deluge system, as specified in 6.2.2. In addition, supplementary protection systems asspecified in 6.2.3 shall be provided in hangars housing single aircraft having wing areas greater than

279 m2 (3000 ft2).

(2) A combination of automatic sprinkler protection in accordance with 6.2.4 and an automatic low-levellow-expansion foam system in accordance with 6.2.5.

(3) A combination of automatic sprinkler protection in accordance with 6.2.4 and an automatic low-levelhigh-expansion foam system in accordance with 6.2.5.

(4) A combination of automatic sprinkler protection in accordance with 6.2.4 and a fuel containment floorsystem in accordance with 6.2.X

Statement of Problem and Substantiation for Public Input

The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection.

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Organization: Fireless Flooring

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 05 11:33:36 EDT 2013

Committee Statement

Resolution: The fuel containment floor system technology has not been fully tested.

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Public Input No. 56-NFPA 409-2013 [ Section No. 6.2.2.3 ]

6.2.2.3

In aircraft storage and servicing areas, the protection area as projected on the floor shall be limited

to 12 m 2 (130 ft 2 ). The maximum distance between sprinklers either on branch lines or betweenbranch lines shall be 3.7 m (12 ft). In buildings with storage bays 7.6 m (25 ft) wide, a distance of 3.8 m (12ft 6 in.) shall be permitted.

Statement of Problem and Substantiation for Public Input

Allow NFPA 13 to set parameters for spacing along and between branchlines. Note this section is also referenced by also 7.2.3 and 9.14.2(3)(c).

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:41:23 EDT 2013

Committee Statement

Resolution: The existing requirements were justified during the previous revision cycle (see Proposal 18 andComment 5). There is inadequate justification to revise this section as suggested at this time.

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Public Input No. 54-NFPA 409-2013 [ Section No. 6.2.3.3 ]

6.2.3.3

Each supplementary protection system shall be designed, installed, and maintained in accordance withNFPA 11.

Statement of Problem and Substantiation for Public Input

Delete as redundant with proposed new 6.1.6 to apply to all foam systems: "Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11, except that foam system piping shall not be required to be galvanized." See PI 51.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:32:14 EDT 2013

Committee Statement

Resolution: FR-14-NFPA 409-2013

Statement: Delete as redundant with new 6.1.6 (FR 13) to apply to all foam systems.

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Public Input No. 84-NFPA 409-2013 [ Sections 6.2.3.5.1, 6.2.3.5.2, 6.2.3.5.3, 6.2.3.5.4,

6.2.3.... ]

Sections 6.2.3.5.1, 6.2.3.5.2, 6.2.3.5.3, 6.2.3.5.4, 6.2.3.5.5

6.2.3.5.1

Supplementary high

-expansion foam systems shall

utilize surfactants as the foaming ingredient and shall be designed for local application.comply with 6.2.

35 .5

.2 *

These systems shall be designed to discharge at a rate to cover the protected area to a depth of at least0.9 m (3 ft) within 1 minute.

6.2.3.5.3 Discharge rates shall take into consideration the sprinkler breakdown factor required in6.12.8.2.2(2) of NFPA 11.except that they shall be designed for local or portable application including all parts of the hangar floorbeneath an aircraft’s wings when parked in the hangar. This shall allow additional foam as necessary tomaintain the application density over all alternative wing locations.

6.2.3.5.

4

The foam generators shall be located at the ceiling or on exterior walls in such a way that only air fromoutside the aircraft storage and servicing area can be used for foam generation. Roof vents shall belocated to avoid recirculation of combustion products into the air inlets of the foam generators.

6.2.3.5.5 * Generators shall be powered by reliable water-driven or electric motors. Electric powerreliability for generators shall be in accordance with electric fire pump requirements of NFPA 202 Supplementary high expansion foam system generators may be fixed or portable as necessary tofacilitate aircraft movement and types, and shall be supported by work procedures to ensure they are used

when aircraft with wing areas above 279 m 2 are parked in the hangar .

Additional Proposed Changes

File Name Description Approved

NFPA_409_6.2.3.5_6.2.5.5_Rationalisation.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

6.2.3.5 and 6.2.5.5 largely repeat each other and this proposed arrangement reduces this duplication6.2.3.5.2 Guidance of high-expansion foam local delivery.6.2.5.5 The term low level is not defined and following the inference that outside-air high-expansion generators should be mounted in hangar walls, not practicable for Group I hangars which have with only two or three exterior walls. Due to the slow horizontal spread of Hi-Ex the use of wall mounted generators should be discouraged.6.2.5.5.1 changed to be used defining all types of Hi-Ex generation.6.2.5.5.2 changed to be consistent with the requirement to follow NFPA 11 calculation methodology.6.2.5.5.3 Expanded to allow zoning of large systems6.2.5.5.4 Changed to better describe the requirements of general area coverage and supplementary systems6.2.5.5.5 & 6 Changed to allow inside-air generators 6.2.5.5.6 Minimum quality statement for inside-air generatorsInside-air generators offer several advantages over fan driven and outside-air types, the main advantages being :-• They have no moving parts thus require less maintenance

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• They are light weight reducing hangar roof loads• They are better able to withstand fire conditions before use.• They cost less than fan driven generators and deliver a more fluid foam blanket which improves the horizontal spread velocity, offering quicker fire suppression.• They offer significant economies in water and foam consumption and discharges into the environment

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:04:57 EDT 2013

Committee Statement

Resolution: The proposed text would radically change the intent of the low-level foam system without adequatejustification. Adequate technical data has not been provided to support the use of inside air. The foamapplication rate does not need to match NFPA 11. Low-level foam systems (6.2.5.5) do not have thesame performance criteria as supplementary foam systems (6.2.3.5), as these protection options areused in different protection schemes. The committee has formed a task group to study the issue ofzoning of the low-level foam systems. Portable foam generators would not meet the minimumreliability and suppression time that is required for aircraft hangars. Inadequate substantiation wasprovided to remove the requirement to use surfactants.

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Public Input No. 74-NFPA 409-2013 [ Section No. 6.2.3.5.3 ]

6.2.3.5.3

Discharge rates shall take into consideration the sprinkler breakdown factor required in6.12.8.2. 3. 2 (2) of NFPA 11 using the total actual discharge from the number of sprinklers expected tooperate in L/min (gpm) .

Additional Proposed Changes

File Name Description Approved

nfpa409_PI_Kasiski_6-2-3-5-3.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

The revised wording provides clarity on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 11 13:28:18 EDT 2013

Committee Statement

Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

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Public Input No. 89-NFPA 409-2013 [ Sections 6.2.3.5.4, 6.2.3.5.5 ]

Sections 6.2.3.5.4, 6.2.3.5.5

6.2.3.5.4

The Outside-air foam generators shall be located at the ceiling or on exterior walls in such a way that onlyair from outside the aircraft storage and servicing area can be used for foam generation. Roof vents shallbe located to avoid recirculation of combustion products into the air inlets of the foam generators.

6.2.3.5.5 *

Generators Outside-air generators shall be powered by reliable water-driven or electric motors.Electric power reliability for generators shall be in accordance with electric fire pump requirementsof NFPA 20.

6.2.3.5.6 Inside-air generators shall be listed and shall be oriented and located in accordance with themanufacturer's approvals in respect to air inlet clearance and direction of discharge.

Additional Proposed Changes

File Name Description Approved

NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

Definition of the foam generator types is suggested as helpful.Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound.Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types. Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:31:26 EDT 2013

Committee Statement

Resolution: Adequate technical data has not been provided to support the use of inside air.

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Public Input No. 4-NFPA 409-2012 [ Section No. 6.2.3.5.5 ]

6.2.3.5.5*

Foam Generators shall be powered by reliable water-driven or electric motors. Electric power reliability forgenerators foam generators shall be in accordance with electric fire pump requirements of NFPA 20.

Statement of Problem and Substantiation for Public Input

Clarifies that the section is specifically addressing foam generators.

Submitter Information Verification

Submitter Full Name: John Chartier

Organization: Northeastern Regional Fire Cod

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 11:27:16 EDT 2012

Committee Statement

Resolution: FR-17-NFPA 409-2013

Statement: Clarifies that the section is specifically addressing foam generators.

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Public Input No. 35-NFPA 409-2013 [ Section No. 6.2.4.5 ]

6.2.4.5

The design Regardless of the ceiling slope, the design density of water from sprinkler systems shall be a

minimum of 6.9 L/min/m 2 (0.17 gpm/ft 2 ) over any 1394 m 2 (15,000 ft 2 ) area, including thehydraulically most demanding area as defined in NFPA 13.

Statement of Problem and Substantiation for Public Input

There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies.

Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area.

NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently.

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association

Affilliation: NFSA E&S Committee

Street Address:

City:

State:

Zip:

Submittal Date: Sat Jun 29 13:11:06 EDT 2013

Committee Statement

Resolution: FR-15-NFPA 409-2013

Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the designarea for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which onlyapplies to those hazard classifications). But many people try to apply it to other occupancies. Thesafety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document toadequately protect sloped roof/ceilings without the 30% increase in the design area. The committeealso clarified that the increase for preaction systems also does not apply to NFPA 409.

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Public Input No. 55-NFPA 409-2013 [ Section No. 6.2.5.2 ]

6.2.5.2

Each low-level foam protection system shall be designed, installed, and maintained in accordance withNFPA 11.

Statement of Problem and Substantiation for Public Input

Delete as redundant with proposed new 6.1.6 to apply to all foam systems: "Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11, except that foam system piping shall not be required to be galvanized." See PI 51.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:38:54 EDT 2013

Committee Statement

Resolution: FR-39-NFPA 409-2013

Statement: Delete as redundant with new 6.1.6 (FR 13) to apply to all foam systems.

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Public Input No. 85-NFPA 409-2013 [ Section No. 6.2.5.5 ]

6.2.5.5 Low-Level High-Expansion Foam Systems.

6.2.5.5.1

Low High - level high- expansion foam systems shall be designed and installed in accordance withrequirements for local application systems of NFPA 11 6 . 12.4.

6.2.5.5.2

The minimum application rate shall be a minimum of 0.9 m 3 /min/m 2 (3 ft 3 /min/ft 2 ) determinedfor a flammable liquids hazard using the calculation method of NFPA 11, Section 6.12 .

6.2.5.5.3

The discharge rate of the system shall be based on the application rate multiplied by the entireaircraft storage and servicing zone floor area. The application total discharge rate shall include thesprinkler breakdown factor specified in 6.12.8.2.2(2) of NFPA 11. rate, unless there are no sprinklers

or low expansion deluge nozzles above. Zones shall be the larger of 2500 m 2 (27,000 ft 2 ), or thearea assigned to a single aircraft.

The design shall allow for the worst case number of wall openings to have foam spilling out to form awedge outside. Openings shall include hangar doors, workshop hatches, boundaries between zones, etc.unless there is a wall or barrier able to contain the foam. The foam angle of repose used for thesecalculations shall be determined by testing and confirmed during commissioning.

6.2.5.5.4

The high-expansion foam generators shall be arranged to achieve initial foam coverage in theexpected aircraft parking potential fuel spill area.

6.2.5.5.5

Foam Outside-air foam generators shall be supplied with air from outside the aircraft storage andservicing area. Roof vents shall be located to avoid recirculation of combustion products into theair inlets of the foam generators.

6.2.5.5.6 *

Foam Outside-air generators shall be powered by reliable water-driven or electric motors. Electricpower reliability for foam generators shall be consistent in accordance with electric fire pumprequirements specified in Chapters 6 and 7 of NFPA 20.

6.2.5.5.7 Inside-air generators shall be listed and shall be oriented and located in accordance withthe manufacturer’s approvals in respect to air inlet clearance and direction of discharge.

Additional Proposed Changes

File Name Description Approved

NFPA_409_6.2.3.5_6.2.5.5_Rationalisation.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

6.2.3.5 and 6.2.5.5 largely repeat each other and this proposed arrangement reduces this duplication6.2.3.5.2 Guidance of high-expansion foam local delivery.6.2.5.5 The term low level is not defined and following the inference that outside-air high-expansion generators should be mounted in hangar walls, not practicable for Group I hangars which have with only two or three exterior walls. Due to the slow horizontal spread of Hi-Ex the use of wall mounted generators should be discouraged.6.2.5.5.1 changed to be used defining all types of Hi-Ex generation.6.2.5.5.2 changed to be consistent with the requirement to follow NFPA 11 calculation methodology.6.2.5.5.3 Expanded to allow zoning of large systems6.2.5.5.4 Changed to better describe the requirements of general area coverage and supplementary systems6.2.5.5.5 & 6 Changed to allow inside-air generators 6.2.5.5.6 Minimum quality statement for inside-air generatorsInside-air generators offer several advantages over fan driven and outside-air types, the main advantages being :-• They have no moving parts thus require less maintenance

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• They are light weight reducing hangar roof loads• They are better able to withstand fire conditions before use.• They cost less than fan driven generators and deliver a more fluid foam blanket which improves the horizontal spread velocity, offering quicker fire suppression.• They offer significant economies in water and foam consumption and discharges into the environment

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:07:13 EDT 2013

Committee Statement

Resolution: The proposed text would radically change the intent of the low-level foam system without adequatejustification. Adequate technical data has not been provided to support the use of inside air. The foamapplication rate does not need to match NFPA 11. Low-level foam systems (6.2.5.5) do not have thesame performance criteria as supplementary foam systems (6.2.3.5), as these protection options areused in different protection schemes. The committee has formed a task group to study the issue ofzoning of the low-level foam systems. Portable foam generators would not meet the minimumreliability and suppression time that is required for aircraft hangars. Inadequate substantiation wasprovided to remove the requirement to use surfactants.

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Public Input No. 75-NFPA 409-2013 [ Section No. 6.2.5.5.3 ]

6.2.5.5.3

The discharge rate of the system shall be based on the application rate multiplied by the entireaircraft storage and servicing floor area. The application total discharge rate shall include thesprinkler breakdown factor specified in 6.12.8.2. 3. 2 (2) of NFPA 11 using the total actual dischargefrom the number of sprinklers expected to operate in L/min (gpm) .

Additional Proposed Changes

File Name Description Approved

nfpa409_PI_Kasiski_6-2-5-5-3.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

The revised wording provides clartiy on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 11 13:31:14 EDT 2013

Committee Statement

Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

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Public Input No. 60-NFPA 409-2013 [ Section No. 6.2.5.5.5 ]

6.2.5.5.5

Foam generators shall be supplied with air from outside the or inside the aircraft storage andservicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inletsof the foam generators. area in accordance with the provisions of 6.9 of NFPA 11.

Statement of Problem and Substantiation for Public Input

In past NFPA 409 TC meetings inside air test data was presented by Ansul which demonstrated compliance with NFPA 11 6.9.1 and 6.9.2 for high expansion foam produced with inside air. At the time the TC rejected the proposal to allow inside air with some members citing life safety concerns. However there is no compelling reason to believe that life safety is more at risk in an aircraft hangar than in a flammable liquids warehouse with aisles of rack storage. Therefore it is recommended that the TC accept this proposal which will allow HEF systems to be implemented more reliably by eliminating roof penetrations and dampers.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 61-NFPA 409-2013 [Section No. 7.5.5]

Public Input No. 62-NFPA 409-2013 [Section No. 9.14.7.5.5]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:59:25 EDT 2013

Committee Statement

Resolution: Adequate technical data has not been provided to support the use of inside air.

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Public Input No. 90-NFPA 409-2013 [ Sections 6.2.5.5.5, 6.2.5.5.6 ]

Sections 6.2.5.5.5, 6.2.5.5.6

6.2.5.5.5

Foam Outside-air foam generators shall be supplied with air from outside the aircraft storage andservicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inletsof the foam generators.

6.2.5.5.6 *

Foam Outside-air generators shall be powered by reliable water-driven or electric motors. Electricpower reliability for foam generators shall be consistent with electric fire pump requirementsspecified in Chapters 6 and 7 of NFPA 20.

6.2.5.5.7 Inside-air generators shall be listed and shall be oriented and located in accordance with themanufacturer’s approvals in respect to air inlet clearance and direction of discharge,

Additional Proposed Changes

File Name Description Approved

NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

Definition of the foam generator types is suggested as helpful.Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound.Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types.Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 09:36:12 EDT 2013

Committee Statement

Resolution: Adequate technical data has not been provided to support the use of inside air.

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Public Input No. 86-NFPA 409-2013 [ Section No. 6.2.6 ]

6.2.6 * Foam Concentrate Supply.

The friction losses in piping carrying foam concentrate shall be calculated using the Darcy formula, alsoknown as the Fanning formula.

6.2.6.1 *

The quantities of low-expansion foam concentrate , either protein foam, fluoroprotein, or AFFF, shallbe large enough for a 10-minute foam discharge based on the supply calculation in 6.2.2.4 and NFPA 16 .

6.2.6.2 *

The quantity of high-expansion foam concentrate shall be large enough for a 12 15 -minutedischarge at the water flow rate based on the supply calculation method required in 6.2.2.4 . ofNFPA 11.

6.2.6.3

A reserve supply of foam concentrate of compatible type for the system shall be directly connected to thesystem and immediately available. The reserve supply shall be in the same quantity as the main supply. Toprevent accidental depletion of this reserve supply, it shall be available to the system only by intentionalmanual operation.

6.2.6.4

Control valves, foam concentrate liquid storage tanks, concentrate pumps, controllers, and bypassbalancing equipment shall be located outside the aircraft storage and service area.

6.2.6.5 Where possible all foam systems within a hangar should use the same foam type, in terms offoam concentrate compatibility and expansion ratio. Differing types shall only be permitted where thecombination is endorsed by the foam manufacturer(s).

6.2.6.6 To prevent unnecessary sprinkler breakdown, low-expansion foam shall not be applied abovehigh-expansion foam unless the low-expansion foam is released under control of heat detectors and thehigh-expansion foam by flame detectors.

Additional Proposed Changes

File Name Description Approved

NFPA_409_6.2.6_Foam_Concentrate_Supply.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

6.2.6.1 Protein foam is no longer manufactured, and Lo-Ex foam types do not include FFFP, this level of detail does not seem necessary.6.2.6.2 NFPA 409 requires compliance with NFPA 11, which requires 2x 15 minute supplies. The calculation method in 6.2.2.4 is only part of the necessary calculation, and NFPA 11 offers a better calculation method.6.2.6.5 Since the formulation of high-expansion foam concentrate is significantly different to all other types of foam, it is unlikely that any manufacturer would endorse Lo-Ex and Hi-Ex in combination.6.2.6.6 It is necessary for Group I hangars (6.1.1 (1)) for aircraft with wing areas over 279 m2 to allow AFFF deluge with Hi-Ex supplementary protection. Given that flame detectors are used to initiate the supplementary Hi-Ex protection, if the heat detectors at roof level operate it can be assumed the Hi-Ex system has failed, one or more aircraft within the hangar will be severely damaged, and the high level system will provide protection to the hangar roof structure. Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

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City:

State:

Zip:

Submittal Date: Fri Jul 12 09:11:32 EDT 2013

Committee Statement

Resolution: Fluoroprotein is still available. There is inadequate substantiation to increase the supply duration. SeeFR 55 (6.2.6.3) regarding changes to the requirements for a reserve foam supply. The standard doesnot necessitate the use of low-expansion foam below high-expansion foam in a single hangar.

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Public Input No. 45-NFPA 409-2013 [ New Section after 6.2.7.10 ]

6.2.X Fuel Containment Floor System.

6.2.X.1 Hangars protected in accordance with 6.1.1(4) shall be protected with a fuel containmentfloor system.

6.2.X.2 The fuel containment floor system shall be designed to achieve (1) containment of aviationfuel spilled out of aircrafts within the storage and service area and prevent the fuel from being(re)ignited. (2) Suppression of burning aviation fuel spilled out of aircrafts within the storage andservice area.

6.2.X.3 System floor size

6.2.X.3.1 In aircraft storage and servicing areas where the aircraft parking area is fixed, a fuelcontainment floor system shall be installed directly underneath the aircraft’s fuel tanks inaccordance with 6.2.X.3.2

6.2.X.3.2 The fuel containment floor system shall cover the floor from the perimeter of theaircraft’s fuel tanks and all area within.

6.2.X.3.2.1 The fuel containment floor system shall consist of a single continuous floor per eachaircraft.

6.2.X.3.2 In aircraft storage and servicing areas where the aircraft parking area is flexible, a fuelcontainment floor system shall cover the entire area where an aircraft can potential be parked inaccordance with 6.2.X.3.2

6.2.X.3.3 The edge of the fuel containment floor system should be a minimum of 6m. (18 ft.) inhorizontal distance from the perimeter of the fuel tanks.

6.2.X.4 Activated water sprinklers as per 6.2.4 shall not affect the performance of the fuelcontainment floor system. The drainage capacity of the system shall include the maximum amountof water deployed by the overhead sprinkler system.

6.2.X.5 Fuel removal

6.2.X.5.1 The system shall have an integrated flush capability to flush out contained fuel. Theflush system shall be discharged into the trench drain system in accordance with 5.11.2

6.2.X.5.2 In case of existing aircraft storage and service areas where (1) the trench drain layout isnot practically located in relation to the fuel containment floor system, (2) or the concrete floor slabdoes not have sufficient pitch, a suction system may be installed to remove liquids from thesystem into the nearest trench drain or directly to a safe outside location in accordance with5.11.2.3.

Statement of Problem and Substantiation for Public Input

The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection.

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Organization: Fireless Flooring

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 05 11:23:31 EDT 2013

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Committee Statement

Resolution: The fuel containment floor system technology has not been fully tested.

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Public Input No. 29-NFPA 409-2013 [ Section No. 6.2.7.10 ]

6.2.7.10

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower) , a listed electricfoam pump controller shall be used.

(2) For electric-drive foam concentrate pumps not exceeding 22.4kW (30 horsepower), a listed electricfoam pump controller or limited-service foam pump controller shall be used.

(2) For diesel engine–driven foam concentrate pumps, a listed fire pump controller shall be used.

Additional Proposed Changes

File Name Description Approved

6.2.7.10_1_.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

Foam pumps feed full service controllers and should be no less than full service controllers. Listed full service controllers are now available in horsepowers down to 1.0 Hp. Also, Limited Service Controllers are no longer Listed (Approved) by Factory Mutual.Note: At one time, full service controllers were not available below 30 Hp.Note: Similar proposals have been submitted to NFPA-11 and NFPA-16.

Submitter Information Verification

Submitter Full Name: James Nasby

Organization: Columbia Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Fri Mar 01 07:48:06 EST 2013

Committee Statement

Resolution: FR-16-NFPA 409-2013

Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancyrequirements throughout this standard.

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Public Input No. 57-NFPA 409-2013 [ Section No. 6.2.7.10 ]

6.2.7.10

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower), a listed fullservice electric foam pump controller shall be used.

(2) For

electric-drive foam concentrate pumps not exceeding 22.4kW (30 horsepower), a listed electric foampump controller or limited-service foam pump controller shall be used.

(3) For diesel engine–driven foam concentrate pumps, a listed fire pump controller shall be used.

Statement of Problem and Substantiation for Public Input

Limited service fire pump controllers have been recommended for deletion twice by the NFPA 20 TC. Since full service controllers are available for all pump motor sizes at only a small additional cost, this should be the minimum requirement. To allow limited service foam pump controllers is inconsistent with the reliability and redundancy requirements throughout this standard. Also the language in 6.2.7.10 should be identical to 7.3.3.9 and 9.14.9.3.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 58-NFPA 409-2013 [Section No. 7.3.3.9]

Public Input No. 59-NFPA 409-2013 [Section No. 9.14.9.3]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:45:11 EDT 2013

Committee Statement

Resolution: FR-16-NFPA 409-2013

Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancyrequirements throughout this standard.

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Public Input No. 67-NFPA 409-2013 [ New Section after 6.2.8.1 ]

proposed new 6.2.8.1.4

Listed detection systems (such as optical flame detection) shall be acceptable in lieu of heat detection ifboth approved by the Authority Having Jurisdiction and installed in accordance with NFPA 72.

Statement of Problem and Substantiation for Public Input

The purpose of this change is to make it clear than an owner and AHJ may agree to adopt an alternate detection system without requiring two detection systems.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 68-NFPA 409-2013 [New Section after 7.7]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:33:45 EDT 2013

Committee Statement

Resolution: FR-18-NFPA 409-2013

Statement: The purpose of this change is to make it clear than an owner and AHJ may agree to adopt analternate detection system without requiring two detection systems.

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Public Input No. 65-NFPA 409-2013 [ New Section after 6.2.8.4 ]

proposed new 6.2.8.4.1

Where wet-pipe sprinkler systems are provided, detection of sprinkler water flow shall be acceptable as themeans of heat detection.

Statement of Problem and Substantiation for Public Input

This is a clarification of the intent of the standard.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 66-NFPA 409-2013 [New Section after 7.7.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:25:02 EDT 2013

Committee Statement

Resolution: The proposed text would place requirements regarding the actuation of the low-level foam systemwithin the section that addresses the actuation of preaction sprinkler systems.

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Public Input No. 73-NFPA 409-2013 [ Section No. 6.2.8.5.1 ]

6.2.8.5.1 *

Actuation of any closed-head sprinkler system shall simultaneously operate the low-level foam protectionsystem (s) associated with it's area of coverage .

Statement of Problem and Substantiation for Public Input

In Group I hangars low-level foam systems may need to be divided into multiple systems or zones. The standard is very clear that the capability to discharge all zones of a low-level foam system must be provided. For foam-water deluge sprinklers the standard implies that the systems are to be operated on a system by system basis in response to fire alarm initiating devices. Similarly for low-level foam, the standard needs to clarify if the systems or zones must all be discharged simultaneously, or if the response can be zoned in some manner. The recommendation is to allow a zoned response of the low-level systems.

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 08 23:17:33 EDT 2013

Committee Statement

Resolution: The committee has formed a task group to study the issue of zoning of the low-level foam systems.

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Public Input No. 40-NFPA 409-2013 [ Section No. 6.2.9.3.1.1 ]

6.2.9.3.1.1

Where aircraft storage and servicing areas house only unfueled aircraft, as defined in 3.3.15 , hand hosesystems shall be provided in accordance with 6.2.9.4 of this standard.

Statement of Problem and Substantiation for Public Input

Hand hose systems for hangars housing unfueled aircraft are addressed in Chapter 12, Unfueled Aircraft Hangars. Paragraphs 12.5.10 and 12.5.6.1 indicate inside hand hose systems are not required.

This change relocates unfueled aircraft hangar criteria to the chapter covering the subject, and eliminates conflicting criteria.

Submitter Information Verification

Submitter Full Name: LIANE OZMUN

Organization: FRANKFURT-SHORT-BRUZA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 02 13:20:53 EDT 2013

Committee Statement

Resolution: FR-19-NFPA 409-2013

Statement: Hand hose systems for hangars housing unfueled aircraft are addressed in Chapter 12, UnfueledAircraft Hangars. Paragraphs 12.5.10 and 12.5.6.1 indicate inside hand hose systems are notrequired.

This change relocates unfueled aircraft hangar criteria to the chapter covering the subject, andeliminates conflicting criteria.

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Public Input No. 63-NFPA 409-2013 [ Section No. 6.2.10.8.2 ]

6.2.10.8.2

The total pumping capacity shall be such that the maximum demand is met with the largest fire pumpout of service. be provided using fire pumps of equal capacity. No fewer than two fire pumps shall beprovided.

Statement of Problem and Substantiation for Public Input

The "largest fire pump out of service" requirement is a level of redundancy not found in any other NFPA occupancy standard. NFPA 20 takes considerable care in ensuring fire pump reliability. This proposal relaxes the requirement for water supply redundancy in a manner analogous to the divided water supply requirement of.6.2.10.7 and does not allow the hangar to be protected by only a single fire pump.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 64-NFPA 409-2013 [Section No. 9.14.13.2]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:17:04 EDT 2013

Committee Statement

Resolution: FR-41-NFPA 409-2013

Statement: The "largest fire pump out of service" requirement is a level of redundancy not found in any otherNFPA occupancy standard. NFPA 20 takes considerable care in ensuring fire pump reliability. Thisrevision relaxes the requirement for water supply redundancy, but does not allow the hangar to beprotected by only a single fire pump. See also CI 40, which proposes an alternative revision for thissection.

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Public Input No. 1-NFPA 409-2012 [ Section No. 6.2.10.9 ]

6.2.10.9* Flushing Underground Pipe.

Underground mains and each lead-in connection shall be flushed as specified in NFPA 15 24 .

Statement of Problem and Substantiation for Public Input

The addition of NFPA 24 into this section makes the document more consistent with the flushing guidelines established in the reference for Private Underground Fire Service Mains and is consistent with section 9.14.13.7.

Submitter Information Verification

Submitter Full Name: Doug Hohbein

Organization: Northcentral Fire Code Develop

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 09:52:47 EDT 2012

Committee Statement

Resolution: FR-20-NFPA 409-2013

Statement: The addition of NFPA 24 into this section makes the document more consistent with the flushingguidelines established in the reference for Private Underground Fire Service Mains and is consistentwith section 9.14.13.7.

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Public Input No. 3-NFPA 409-2012 [ Section No. 6.2.10.9 ]

6.2.10.9* Flushing Underground Pipe.

Underground mains and each lead-in connection shall be flushed as specified in NFPA 15 25 .

Statement of Problem and Substantiation for Public Input

NFPA 25 addresses testing, inspection, and maintenance of water based systems.

Submitter Information Verification

Submitter Full Name: John Chartier

Organization: Northeastern Regional Fire Cod

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 11:25:42 EDT 2012

Committee Statement

Resolution: FR-20-NFPA 409-2013

Statement: The addition of NFPA 24 into this section makes the document more consistent with the flushingguidelines established in the reference for Private Underground Fire Service Mains and is consistentwith section 9.14.13.7.

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Public Input No. 52-NFPA 409-2013 [ New Section after 7.1 ]

new 7.1.5

Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11,except that foam system piping shall not be required to be galvanized.

Statement of Problem and Substantiation for Public Input

See proposed new 6.1.6 which is PI 51.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:26:28 EDT 2013

Committee Statement

Resolution: FR-42-NFPA 409-2013

Statement: NFPA 11 (2010 edition) 4.7.2.1 states "Galvanized pipe shall be used." While this requirement may beuseful for tank farms, it is inappropriate for foam systems inside hangars. Galvanized piping isgenerally incompatible with the foams. It contributes nothing to system corrosion resistance and maybe harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentiallyreleasing flakes of zinc which may clog orifices.

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Public Input No. 70-NFPA 409-2013 [ Sections 7.1, 7.2, 7.3, 7.4 ]

7.1

Sections 7.1, 7.2, 7.3, 7.4

7.1 General.

7.1.1

The protection of aircraft storage and servicing areas of Group II aircraft hangars shall be in accordancewith any one of the following:

(1) The provisions of Chapter 6 , unless foam-water deluge systems utilizing air-aspirating dischargedevices are installed for the protection of Group II aircraft hangars, in which case the discharge rate

specified in 6.2.2.12 of this standard is permitted to be reduced to a minimum of 6.5 L/min/m 2

(0.16 gpm/ft 2 ) of floor area

(2) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,low-level, low-expansion foam system in accordance with Sections 7.3 and 7.4

(3) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,high-expansion foam system in accordance with Sections 7.3 and 7.5

(4) A closed-head foam-water sprinkler system in accordance with Section 7.6

7.1.2

Group II aircraft hangar storage and service areas housing unfueled aircraft shall be provided withautomatic sprinkler protection as specified in Chapter 12 .

7.1.3

Automatic closed-head sprinkler protection shall be provided inside separate shop, office, and storageareas located inside aircraft maintenance and servicing areas. The design shall be in accordance withhazard classifications specified in NFPA 13.

7.1.4

In addition to the provision for sprinkler and foam extinguishing systems as required by this chapter,protection as required by 6.2.9 and Sections 6.3 and 6.4 also shall be provided.

7.2 Closed-Head Water Sprinkler System for Aircraft Storage and Servicing Areas.

7.2.1 *

Sprinkler systems shall be either wet pipe or preaction, designed and installed in accordance with theapplicable sections of NFPA 13 and the provisions of this chapter.

7.2.2

Sprinkler piping shall be hydraulically sized in accordance with NFPA 13.

7.2.3

Sprinkler spacing shall be as specified in 6.2.2.3 .

7.2.4

Where open hangar doors result in interference with the distribution of water from the hangar sprinklersystems, additional sprinklers shall be provided to ensure required floor coverage.

7.2.5

The design density of water from sprinkler systems shall be a minimum of 6.9 L/min/m 2 (0.17 gpm/ft 2 )

over any 464.5 m 2 (5000 ft 2 ) area, including the hydraulically most demanding area as defined in NFPA13.

7.2.6

Sprinklers shall be nominal K-80 (K-5.6) or K-115 (K-8.0) sprinklers.

7.2.7

Sprinklers shall have a temperature rating of 162°C to 190°C (325°F to 375°F).

7.2.8

Sprinkler systems shall be flushed and tested in accordance with NFPA 13.

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7.3 * Foam Concentrate — General.

The friction losses in piping carrying foam concentrate shall be calculated using the Darcy formula, alsoknown as the Fanning formula.

7.3.1

The foam concentrate supplied with the system shall be listed for use with the distribution equipment.

7.3.2

There shall be a reserve of foam concentrate of a compatible type directly connected to the system. Thereserve supply shall be in the same quantity as the main supply. To prevent accidental depletion of thisreserve supply, it shall be available to the system only by intentional manual operation.

7.3.3 Foam Concentrate Pumps.

7.3.3.1

Foam concentrate pump installations shall comply with the applicable provisions of NFPA 20, except asmodified by this standard.

7.3.3.2

Where foam concentrate is introduced into the water stream by pumping, the total foam concentratepumping capacity shall be such that the maximum flows and pressures are met with the largest foamconcentrate pump out of service. The reserve pump(s) shall be arranged to operate only upon failure of theprimary pump(s).

7.3.3.3

Piping shall be arranged so that maximum foam concentrate demand is supplied by any foam concentratepump from either primary or reserve foam concentrate tanks.

7.3.3.4

Foam concentrate pumps shall be provided with means of pressure relief from the pump discharge toprevent excessive pressure and temperature. Discharge from the relief valve shall be piped back to thefoam concentrate storage tank. Connection to the suction piping shall not be permitted.

7.3.3.5

The pressure-regulating valve shall not be used as the pressure relief valve. Foam concentrate pumps shallbe started automatically by either a pressure drop in the foam concentrate piping system or a signal fromthe detection system control panel.

7.3.3.6

A pressure maintenance pump shall be provided to maintain pressure in the foam concentrate pipingsystem where foam concentrate lines to the protective system injection points are run underground orwhere they run aboveground for more than 15 m (50 ft).

7.3.3.7

Once started, foam concentrate pumps shall be arranged to run continuously until stopped manually. Thereshall be an audible “pump running” alarm in a constantly attended location.

7.3.3.8

Power supply for the drivers of foam concentrate pumps shall be installed in accordance with NFPA 20 andNFPA 70 . Power supplies shall be arranged such that disconnecting power to the protected facility during afire shall not disconnect the power supply to the foam concentrate pump feeder circuit.

7.3.3.9

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed fire pumpcontroller shall be used.

(2) For electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding22.4 kW (30 horsepower), a listed fire pump controller or listed limited service controller shall be used.

(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited servicecontroller shall be used.

(4) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.

7.3.4

The control valves, foam–liquid concentrate storage, injection system, and foam concentrate pump shall belocated outside aircraft storage and servicing areas.

7.3.5

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Plans and specifications for closed-head foam-water sprinkler systems shall provide the informationrequired by 6.2.1 of this standard and NFPA 16. Plans and specifications for other foam extinguishingsystems shall provide the information required by 6.2.1 .

7.3.6 Acceptance Tests.

7.3.6.1

Acceptance tests for closed-head foam-water sprinkler systems shall be performed in accordance withNFPA 16.

7.3.6.2

Acceptance tests for foam extinguishing systems shall be performed in accordance with 6.2.11.1 ,6.2.11.2 , 6.2.11.6 , and 6.2.11.8 .

7.3.6.2.1

The systems shall be subjected to flow tests, with foam flowing from the maximum number of foamdistributors expected to operate, in order to ensure that the hangar is protected in conformance with thedesign specifications and to determine if the flow pressures, agent discharge capacity, foam coverage, andpercentage of concentration are satisfactory.

7.3.6.2.1.1

A flow test shall be performed with only the foam system operating.

7.3.6.2.1.2

A flow test shall be performed with the foam system operating at the design pressure with the sprinklersystem and hose demand.

7.3.6.3 *

The timing of foam system discharge shall be measured beginning at the time of system actuation.

7.3.7

The installing company shall furnish a written statement to the effect that the work has been completed inaccordance with approved plans and specifications and tested in accordance with the provisions of 7.3.6 .

7.4 * Low-Expansion Foam System.

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7.4.1

Foam systems shall be of the fixed type and shall be designed and installed in accordance with therequirements for fixed-type systems in NFPA 11.

7.4.2

The minimum application rate of foam solution shall be 6.5 L/min/m 2 (0.16 gpm/ft 2 ) where protein-basedor fluoroprotein-based concentrate is used. Where AFFF concentrate is used, the minimum application rate

of foam solution shall be 4.1 L/min/m 2 (0.10 gpm/ft 2 ).

7.4.3 *

The discharge rate of the system shall be based on the rate of application multiplied by the entire aircraftstorage and servicing floor area.

7.4.4

The foam system shall use low-level monitor-type discharge nozzles, with individual manual shutoff valvesfor each nozzle. The discharge nozzles shall be arranged to achieve initial foam coverage in the expectedaircraft parking area.

7.4.5 *

The quantity of foam concentrate shall be calculated for a 10-minute discharge at the water flow rate basedon the supply calculation method.

7.4.6 The low-level foam system shall be designed to achieve distribution of foam over the entire aircraftstorage and service area. The design objective shall be to achieve coverage of the entire aircraft storageand servicing area to within 1.5 m (5 ft) of the perimeter walls and doors within 3 minutes of systemactuation.We propose that subparts (1), (2), (3), and (4) of 7.1.1 be removed and replaced with the followingamendment:

(1) Group II hangars used for storage of aircraft and routine maintenance only shall have an automaticsprinkler protection system in accordance with Section 7.2, but the hangar shall be exempt from foamrequirements per 412.4.6 of the International Building Code.

(2) Hazardous operations and equipment (doping, hot work, fuel transfer, fuel tankrepair/maintenance, and spray finishing) per International Building Code 412.4.6.1 and412.4.6.3 is prohibited in Group II hangars without a foam fire suppression system in accordancewith sections 7.3, 7.4, 7.5, and 7.6.

Additional Proposed Changes

File Name Description Approved

NFPA_Letter_2_.docx NFPA Ch. 7 proposed changes

Statement of Problem and Substantiation for Public Input

Group II Hangars would no longer be required to install foam fire suppression systems. See letter attached.

Submitter Information Verification

Submitter Full Name: Will Hickman

Organization: City of Fort Worth

Affilliation: Fort Worth Spinks Airport

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 08 15:04:04 EDT 2013

Committee Statement

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Resolution: No new information has been provided to change the protection criteria for Group II hangars.

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Public Input No. 46-NFPA 409-2013 [ Section No. 7.1.1 ]

7.1.1

The protection of aircraft storage and servicing areas of Group II aircraft hangars shall be in accordancewith any one of the following:

(1) The provisions of Chapter 6, unless foam-water deluge systems utilizing air-aspirating dischargedevices are installed for the protection of Group II aircraft hangars, in which case the discharge rate

specified in 6.2.2.12 of this standard is permitted to be reduced to a minimum of 6.5 L/min/m2 (0.16

gpm/ft2) of floor area

(2) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,low-level, low-expansion foam system in accordance with Sections 7.3 and 7.4

(3) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,high-expansion foam system in accordance with Sections 7.3 and 7.5

(4) A closed-head foam-water sprinkler system in accordance with Section 7.6

(5) A combination of automatic sprinkler protection in accordance with 7.2 and a fuel containment floorsystem in accordance with 7.X

Statement of Problem and Substantiation for Public Input

The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection.

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Organization: Fireless Flooring

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 05 11:32:36 EDT 2013

Committee Statement

Resolution: The fuel containment floor system technology has not been fully tested.

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Public Input No. 36-NFPA 409-2013 [ Section No. 7.2.5 ]

7.2.5

The Regardless of the ceiling slope, the design density of water from sprinkler systems shall be a

minimum of 6.9 L/min/m 2 (0.17 gpm/ft 2 ) over any 464.5 m 2 (5000 ft 2 ) area, including the hydraulicallymost demanding area as defined in NFPA 13.

Statement of Problem and Substantiation for Public Input

There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies.

Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area.

NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently.

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association

Affilliation: NFSA E&S Committee

Street Address:

City:

State:

Zip:

Submittal Date: Sat Jun 29 13:24:36 EDT 2013

Committee Statement

Resolution: FR-46-NFPA 409-2013

Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the designarea for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which onlyapplies to those hazard classifications). But many people try to apply it to other occupancies. Thesafety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document toadequately protect sloped roof/ceilings without the 30% increase in the design area. The committeealso clarified that the increase for preaction systems also does not apply to NFPA 409.

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Public Input No. 23-NFPA 409-2013 [ Section No. 7.3.3.9 ]

7.3.3.9

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed fire pumpcontroller shall be used.

(2) For electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding22.4 kW (30 horsepower), a listed fire pump controller or listed limited service controller shall beused.

(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited servicecontroller shall be used.

For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.(1) Controllers for foam concentrate pumps shall comply with the requirements of section 6.2.7.9.

Additional Proposed Changes

File Name Description Approved

7.3.3.9.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

Foam pumps feed full service controllers and should be no less than full service controllers. Listed full service controllers are now available in horsepowers down to 1.0 Hp.Note: At one time, full service controllers were not available below 30 Hp.Note: Similar proposals have been submitted to NFPA-11 and NFPA-16.

Submitter Information Verification

Submitter Full Name: James Nasby

Organization: Columbia Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Feb 26 09:05:04 EST 2013

Committee Statement

Resolution: FR-50-NFPA 409-2013

Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancyrequirements throughout this standard.

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Public Input No. 58-NFPA 409-2013 [ Section No. 7.3.3.9 ]

7.3.3.9

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed fullservice fire pump controller shall be used.

(2) For

electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding 22.4 kW(30 horsepower), a listed fire pump controller or listed limited service controller shall be used.

(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited servicecontroller shall be used.

(4) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.

Statement of Problem and Substantiation for Public Input

See proposed change to 6.2.7.10 which is PI 57.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 57-NFPA 409-2013 [Section No. 6.2.7.10]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:48:44 EDT 2013

Committee Statement

Resolution: FR-50-NFPA 409-2013

Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancyrequirements throughout this standard.

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Public Input No. 72-NFPA 409-2013 [ Section No. 7.4.4 ]

7.4.4

The foam system shall use low-level discharge nozzles Where monitor -type discharge nozzlesare used , they shall be provided with individual manual shutoff valves for each nozzle. The dischargenozzles shall be arranged to achieve initial foam coverage in the expected aircraft parking area.

Statement of Problem and Substantiation for Public Input

This comment is to make 7.4.4 read the same as 6.2.5.4.3. There is no reason to restrict low-level low expansion foam systems in Group II hangars to be only monitor nozzles, while allowing other foam delivery systems such as grate nozzles in Group I hangars.

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 08 22:42:14 EDT 2013

Committee Statement

Resolution: FR-21-NFPA 409-2013

Statement: The revision harmonizes 7.4.4 for Group II hangars with 6.2.5.4.3 for Group I hangars.

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Public Input No. 76-NFPA 409-2013 [ Section No. 7.5.4 ]

7.5.4

The discharge rate of the system shall be based on the application rate multiplied by the entireaircraft storage and servicing floor area. The application total discharge rate shall include thesprinkler breakdown factor specified in in 6.12.8. 2.3. 5. 2 (b) of NFPA 11 using the total actualdischarge from the number of sprinklers expected to operate in L/min (gpm) .

Additional Proposed Changes

File Name Description Approved

nfpa409_PI_Kasiski_7-5-4.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

The revised wording provides clartiy on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 11 13:34:07 EDT 2013

Committee Statement

Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

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Public Input No. 61-NFPA 409-2013 [ Section No. 7.5.5 ]

7.5.5

Foam generators shall be supplied with air from outside the or inside the aircraft storage andservicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inletsof the foam generators. area in accordance with the provisions of 6.9 of NFPA 11.

Statement of Problem and Substantiation for Public Input

See proposed revision to 6.2.5.5.5 which is PI 60.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 60-NFPA 409-2013 [Section No. 6.2.5.5.5]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:10:00 EDT 2013

Committee Statement

Resolution: Adequate technical data has not been provided to support the use of inside air.

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Public Input No. 37-NFPA 409-2013 [ Section No. 7.6.2 ]

7.6.2

The Regardless of the celing slope, the minimum discharge density shall be 6.5 L/min/m 2 (0.16 gpm/ft 2 )of foam solution over the entire storage and service area.

Statement of Problem and Substantiation for Public Input

There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies.

Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area.

NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently.

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association

Affilliation: NFSA E&S Committee

Street Address:

City:

State:

Zip:

Submittal Date: Sat Jun 29 13:26:48 EDT 2013

Committee Statement

Resolution: FR-47-NFPA 409-2013

Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the designarea for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which onlyapplies to those hazard classifications). But many people try to apply it to other occupancies. Thesafety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document toadequately protect sloped roof/ceilings without the 30% increase in the design area. The committeealso clarified that the increase for preaction systems also does not apply to NFPA 409.

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Public Input No. 48-NFPA 409-2013 [ New Section after 7.6.7.1 ]

7.X Fuel Containment Floor System.

7.X.1 Hangars protected in accordance with 7.1 (5) shall be protected with a fuel containment floorsystem.

7.X.2 The fuel containment floor system shall be designed to achieve (1) containment of aviationfuel spilled out of aircrafts within the storage and service area and prevent the fuel from being(re)ignited. (2) Suppression of burning aviation fuel spilled out of aircrafts within the storage andservice area.

7.X.3 System floor size

7.X.3.1 In aircraft storage and servicing areas where the aircraft parking area is fixed, a fuelcontainment floor system shall be installed directly underneath the aircraft’s fuel tanks inaccordance with 7.X.3.2

7.X.3.2 The fuel containment floor system shall cover the floor from the perimeter of the aircraft’sfuel tanks and all area within.

7.X.3.2.1 The fuel containment floor system shall consist of a single continuous floor per eachaircraft.

7.X.3.2 In aircraft storage and servicing areas where the aircraft parking area is flexible, a fuelcontainment floor system shall cover the entire area where an aircraft can potential be parked inaccordance with 7.X.3.2

7.X.3.3 The edge of the fuel containment floor system should be a minimum of 6m. (18 ft.) inhorizontal distance from the perimeter of the fuel tanks.

7.X.4 Activated water sprinklers as per 7.2 shall not affect the performance of the fuel containmentfloor system. The drainage capacity of the system shall include the maximum amount of waterdeployed by the overhead sprinkler system.

7.X.5 Fuel removal

7.X.5.1 The system shall have an integrated flush capability to flush out contained fuel. The flushsystem shall be discharged into the trench drain system in accordance with 5.11.2

7.X.5.2 In case of existing aircraft storage and service areas where (1) the trench drain layout isnot practically located in relation to the fuel containment floor system, (2) or the concrete floor slabdoes not have sufficient pitch, a suction system may be installed to remove liquids from thesystem into the nearest trench drain or directly to a safe outside location in accordance with5.11.2.3.

Statement of Problem and Substantiation for Public Input

The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection.

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Organization: Fireless Flooring

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 05 11:34:47 EDT 2013

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Committee Statement

Resolution: The fuel containment floor system technology has not been fully tested.

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Public Input No. 68-NFPA 409-2013 [ New Section after 7.7 ]

proposed new 7.7.5

Listed detection systems (such as optical flame detection) shall be acceptable in lieu of heat detection ifboth approved by the Authority Having Jurisdiction and installed in accordance with NFPA 72.

Statement of Problem and Substantiation for Public Input

See proposed new 6.2.8.1.4 which is PI 67. The purpose of this change is to make it clear than an owner and AHJ may agree to adopt an alternate detection system without requiring two detection systems.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 67-NFPA 409-2013 [New Section after 6.2.8.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:36:09 EDT 2013

Committee Statement

Resolution: FR-52-NFPA 409-2013

Statement: The purpose of this change is to make it clear than an owner and AHJ may agree to adopt analternate detection system without requiring two detection systems.

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Public Input No. 87-NFPA 409-2013 [ Section No. 7.7 ]

7.7 Detection and Actuation Systems.

7.7.1

Detectors for actuating high- or low-expansion foam systems and for actuating preaction sprinklersystems shall be rate-of-rise, fixed-temperature, or rate-compensation type. deluge and sprinklersystems at ceiling or roof height, shall be heat detectors or flame detectors.

Detectors and systems for initiating discharge of expanded foam onto a fuel spill or fire shall be flamedetectors configured to actuate foam discharge in less than 10 seconds. Flame detectors shall be arrangedoptimize detection of fires at floor level below aircraft fuel tanks at planned aircraft parking areas.

The first detector to operate shall signal alarm, but two detectors shall operate before initiating a foamdischarge. Flame detectors shall be aligned to, and provided in sufficient quantity to ensure propercoverage in the event of any single detector being out of service. In multiple zone systems sharing acommon water or foam supplies, the first zone to actuate shall prevent later zones from operating to avoidunnecessary depletion of foam concentrate supplies. Manual controls shall be configured to override thisselection if necessary.

7.7.2

These detectors shall be installed in accordance with NFPA 72 .

7.7.3

Detection systems shall be provided with supervision as required by NFPA 72 .

7.7.4

Manual actuation stations shall be located so that each system can be individually operated from bothinside and outside the aircraft storage and servicing area. The manual stations shall be installed so thatthey are unobstructed, readily accessible, and located in the normal paths of exit from the area.

Additional Proposed Changes

File Name Description Approved

NFPA_409_7.7_Flame_Detectors.docx Cover Sheet

Statement of Problem and Substantiation for Public Input

In high roof buildings like hangars, thermal detection responds fast enough to protect the building structure but too slowly to deliver effective fire protection to high value property within the hangar at low level such as spare parts and aircraft. To meet the fuel spill foam suppression criteria of NFPA 11 fire suppression is required in 2.5 minutes, 30 seconds to start the foam delivery and 2 minutes to generate a foam blanket of adequate depth to submerge the risk. Flame detectors can be, and are often allowed to start hangar foam systems using the provisions of NFPA 409 1.3 & 1.4, however many AHJs are reluctant to deviate from the letter of NFPA codes, and in the past some have simply refused to allow such deviation. Although it is expected that each zone would have 4 flame detectors, where there are two parking areas sharing a hangar doorway, with no convenient flame detector mounting available air-side between the two parking areas it is possible to meet these requirements with 3 flame detectors per parking area.Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: RICHARD GILLESPIE

Organization: FIRE ENGR SOLUTIONS P/L

Street Address:

City:

State:

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Zip:

Submittal Date: Fri Jul 12 09:25:35 EDT 2013

Committee Statement

Resolution: This proposal exceeds the level of safety prescribed by this minimum standard. See FR 52 (7.7.5).

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Public Input No. 66-NFPA 409-2013 [ New Section after 7.7.1 ]

proposed new 7.7.1.1

Where wet-pipe sprinkler systems are provided, detection of sprinkler water flow shall be acceptable as themeans of heat detection.

Statement of Problem and Substantiation for Public Input

See proposed new section 6.2.8.4.1 which is PI 65. This is a clarification of the intent of the standard.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 65-NFPA 409-2013 [New Section after 6.2.8.4]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:29:01 EDT 2013

Committee Statement

Resolution: FR-23-NFPA 409-2013

Statement: The section was revised to harmonize with the requirements in Chapter 6 for Group I hangars.

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Public Input No. 25-NFPA 409-2013 [ Section No. 8.7.1 ]

8.7.1*

Grounding facilities shall be provided for removal and control of static electrical accumulations on aircraftwhile aircraft are stored or are undergoing servicing in a hangar shall be permitted .

Statement of Problem and Substantiation for Public Input

Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment.

Submitter Information Verification

Submitter Full Name: Donald Cook

Organization: Shelby County Department of De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 28 15:57:56 EST 2013

Committee Statement

Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply withNFPA 410 or other standards for aircraft maintenance operations. Whether and how the groundingfacilities are used is not within the scope of NFPA 409.

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Public Input No. 27-NFPA 409-2013 [ Section No. 8.7.2 ]

8.7.2

Floor-grounding receptacles shall be provided permitted and where installed shall be either groundedthrough individual driven electrodes or electrically bonded together in a grid system and the entire systemgrounded to underground metal piping or driven electrodes. Where driven electrodes are used, they shallconsist of 15.9 mm ( 5?8 in.) diameter or larger metal rods driven at least 1.5 m (5 ft) into the ground. Floor-grounding receptacles shall be designed to minimize the tripping hazard.

Statement of Problem and Substantiation for Public Input

Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment.

Submitter Information Verification

Submitter Full Name: Donald Cook

Organization: Shelby County Department of De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 28 16:12:45 EST 2013

Committee Statement

Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply withNFPA 410 or other standards for aircraft maintenance operations. Whether and how the groundingfacilities are used is not within the scope of NFPA 409.

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Public Input No. 26-NFPA 409-2013 [ Sections 9.12.1, 9.12.2 ]

Sections 9.12.1, 9.12.2

9.12.1

Membrane-covered rigid-steel-frame-structure hangars housing other than unfilled aircraft shall beprovided with grounding Grounding facilities for the removal and control of static electrical accumulationson aircraft while aircraft are stored or undergoing servicing in a hangar. membrane-covered rigid-steel-frame-structure hangars housing other than unfilled aircraft shall be permitted.

9.12.2

Floor-grounding receptacles shall be provided. The permitted. Where installed, the receptacles shall beeither grounded through individual driven electrodes or electrically bonded together in a grid system andthe entire system grounded to underground metal piping, such as cold water piping, or driven electrodes.Where driven electrodes are used, they shall consist of 15.9 mm ( 5?8 in.) diameter or larger metal rodsdriven at least 1.5 m (5 ft) into the ground. Floor-grounding receptacles shall be designed to minimize thetripping hazard.

Statement of Problem and Substantiation for Public Input

Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment.

Submitter Information Verification

Submitter Full Name: Donald Cook

Organization: Shelby County Department of De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 28 16:05:13 EST 2013

Committee Statement

Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply withNFPA 410 or other standards for aircraft maintenance operations. Whether and how the groundingfacilities are used is not within the scope of NFPA 409.

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Public Input No. 53-NFPA 409-2013 [ Section No. 9.14.5.3 ]

9.14.5.3

Each protection system shall be designed, installed, and maintained in accordance with NFPA 11 , exceptthat foam system piping shall not be required to be galvanized .

Statement of Problem and Substantiation for Public Input

See proposed new 6.1.6 which is PI 51.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:29:33 EDT 2013

Committee Statement

Resolution: FR-45-NFPA 409-2013

Statement: NFPA 11 (2010 edition) 4.7.2.1 states "Galvanized pipe shall be used." While this requirement may beuseful for tank farms, it is inappropriate for foam systems inside hangars. Galvanized piping isgenerally incompatible with the foams. It contributes nothing to system corrosion resistance and maybe harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentiallyreleasing flakes of zinc which may clog orifices.

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Public Input No. 77-NFPA 409-2013 [ Section No. 9.14.7.5.3 ]

9.14.7.5.3

The discharge rate of the system shall be based on the application rate multiplied by the entire aircraftstorage and servicing floor area. The application total discharge rate shall include the sprinkler breakdownfactor specified in 6.12.8.2. 3. 2 of NFPA 11 using the total actual discharge from the number of sprinklersexpected to operate in L/min (gpm) .

Additional Proposed Changes

File Name Description Approved

nfpa409_PI_Kasiski_9-14-7-5-3.pdf Cover Sheet

Statement of Problem and Substantiation for Public Input

The revised wording provides clartiy on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection.

Submitter Information Verification

Submitter Full Name: Robert Kasiski

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 11 13:35:44 EDT 2013

Committee Statement

Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

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Public Input No. 62-NFPA 409-2013 [ Section No. 9.14.7.5.5 ]

9.14.7.5.5

Foam generators shall be supplied with air from outside outside or inside the aircraft storage andservicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inletsof the foam generators. area in accordance with the provisions of 6.9 of NFPA 11.

Statement of Problem and Substantiation for Public Input

See proposed revision to 6.2.5.5.5 which is PI 60.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 60-NFPA 409-2013 [Section No. 6.2.5.5.5]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:12:35 EDT 2013

Committee Statement

Resolution: Adequate technical data has not been provided to support the use of inside air.

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Public Input No. 59-NFPA 409-2013 [ Section No. 9.14.9.3 ]

9.14.9.3

Controllers for foam concentrate pumps shall be as follows:

(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower), a listed fullservice fire pump controller shall be used.

(2)

(3) For

electric-drive foam concentrate pumps greater than 11kW (15 horsepower) but not exceeding 22.4kW(30 horsepower), a listed fire pump controller or listed limited-service controller shall be used.

(4) For electric-drive foam concentrate pumps less than 11kW (15 horsepower), a listed limited-servicecontroller shall be used.

(5) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.

Statement of Problem and Substantiation for Public Input

See proposed change to 6.2.7.10 which is PI 57.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 57-NFPA 409-2013 [Section No. 6.2.7.10]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:52:50 EDT 2013

Committee Statement

Resolution: FR-51-NFPA 409-2013

Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancyrequirements throughout this standard.

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Public Input No. 64-NFPA 409-2013 [ Section No. 9.14.13.2 ]

9.14.13.2

The total pumping capacity shall be such that maximum demand shall be met with the largest fire pumpout of service. provided using fire pumps of equal capacity. No fewer than two fire pumps shall beprovided.

Statement of Problem and Substantiation for Public Input

See proposed change to 6.2.10.8.2 which is PI 63.

Related Public Comments for This Document

Related Comment Relationship

Public Input No. 63-NFPA 409-2013 [Section No. 6.2.10.8.2]

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:21:28 EDT 2013

Committee Statement

Resolution: FR-54-NFPA 409-2013

Statement: The "largest fire pump out of service" requirement is a level of redundancy not found in any otherNFPA occupancy standard. NFPA 20 takes considerable care in ensuring fire pump reliability. Thisrevision relaxes the requirement for water supply redundancy, but does not allow the hangar to beprotected by only a single fire pump. See also CI 53, which proposes an alternative revision for thissection.

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Public Input No. 39-NFPA 409-2013 [ Section No. 10.2.1 ]

10.2.1

The Regardless of the ceiling slope, the protection of aircraft paint hangars shall be in accordance witheither Chapter 6 or Chapter 7 of this standard, whichever is applicable.

Statement of Problem and Substantiation for Public Input

There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies.

Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area.

NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently.

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association

Affilliation: NFSA E&S Committee

Street Address:

City:

State:

Zip:

Submittal Date: Sat Jun 29 13:32:15 EDT 2013

Committee Statement

Resolution: FR-48-NFPA 409-2013

Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the designarea for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which onlyapplies to those hazard classifications). But many people try to apply it to other occupancies. Thesafety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document toadequately protect sloped roof/ceilings without the 30% increase in the design area. The committeealso clarified that the increase for preaction systems also does not apply to NFPA 409.

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Public Input No. 69-NFPA 409-2013 [ Chapter 11 [Title Only] ]

Final Acceptance Testing and Periodic Inspection and Testing

Proposal is that a new Chapter be created to put all testing requirements for final acceptance and ongoingmaintenance in one place. Centralizing these requirements will give us an opportunity to eliminate commonsources of confusion and make the standard easier to use. Recommend that a Task Group be formed toaccomplish this.

Statement of Problem and Substantiation for Public Input

Centralizing all testing requirements will eliminate common sources of confusion and make the standard easier to use.

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 18:56:24 EDT 2013

Committee Statement

Resolution: CI-60-NFPA 409-2013

Statement: This Committee Input proposes to significantly revise Chapter 11. The committee has formed a taskgroup to better define the inspection and maintenance requirements of fire protection systems inhangars, since many of these systems are not within the scope of NFPA 25. This proposal is providedas a baseline to seek public comment on the subject. The section references in the revised table arebased on the following documents: NFPA 25, 2011 Edition; NFPA 11, 2010 Edition; NFPA 72, 2010Edition; NFPA 80, 2010 Edition; NFPA 90A, 2009 Edition; NFPA 1962, 2008 Edition; NFPA 33, 2007Edition; Air Force Instruction AFI 32-1065, Grounding Systems, October 1998.

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Public Input No. 38-NFPA 409-2013 [ Section No. 12.5.6 [Excluding any Sub-Sections] ]

The Regardless of the ceiling slope, the design density from sprinkler systems shall be a minimum of 6.9

L/min/m2 (0.17 gpm/ft2) over any 464.5 m2 (5000 ft2) area, including the hydraulically most demandingarea as defined in NFPA 13.

Statement of Problem and Substantiation for Public Input

There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies.

Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area.

NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently.

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association

Affilliation: NFSA E&S Committee

Street Address:

City:

State:

Zip:

Submittal Date: Sat Jun 29 13:29:08 EDT 2013

Committee Statement

Resolution: FR-49-NFPA 409-2013

Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the designarea for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which onlyapplies to those hazard classifications). But many people try to apply it to other occupancies. Thesafety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document toadequately protect sloped roof/ceilings without the 30% increase in the design area. The committeealso clarified that the increase for preaction systems also does not apply to NFPA 409.

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Public Input No. 2-NFPA 409-2012 [ Section No. A.3.3.2 ]

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A.3.3.2 Aircraft Hangar.

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For overall height of various transport-type aircraft, see Table A.3.3.2. Offices and similar administrativeareas are not considered part of the hangar when properly separated per 5.2.3, 8.2.3 and 9.2.3.

Table A.3.3.2 Gross Wing Area and Overall Height for Selected Aircraft

Gross Wing Area Overall Height

Aircraft m 2 ft 2 m ft–in.

Airbus A-380* 830.0 8920 24.1 † 79–0

Antonov An-124* 628.0 † 6760 21.0 † 69–2

Lockheed L-500-Galaxy* 576.0 † 6200 19.8 † 65–1

Boeing 747* 541.1 † 5825 19.4 † 63–8

Airbus A-340-500, -600* 437.0 † 4703 16.7 † 54–11

Boeing 777* 427.8 † 4605 18.5 † 60–9

Ilyushin II-96* 391.6 † 4215

DC-10-20, 30* 367.7 † 3958 17.7 † 58–1

Airbus A-340-200, -300, A-330-200, -300* 361.6 † 3892 16.7 † 54–11

DC-10-10* 358.7 † 3861 17.7 † 58–1

Concorde* 358.2 † 3856 12.2 † 40–0

Boeing MD-11* 339.9 † 3648 17.6 † 57–9

Boeing MD-17* 353.0 † 3800 16.8 † 55–1

L-1011* 321.1 † 3456 16.9 † 55–4

Ilyushin II-76* 300.0 † 3229 14.8 † 48–5

Boeing 767* 283.4 † 3050 15.8 † 52–0

Ilyushun IL-62* 281.5 † 3030 12.3 † 40–6

DC-10 MD-10 272.4 2932

DC-8-63, -73 271.9 2927

DC-8-62, -72 271.8 2926

DC-8-61, 71 267.8 2883

Airbus A-300 260.0 † 2799 16.5 † 54–3

Airbus A-310 218.9 † 2357 15.8 † 51–10

Tupolev TU-154 201.5 † 2169 11.4 † 37–4

Boeing 757 185.2 † 1994 13.5 † 44–6

Tupolev TU-204 182.4 † 1963 13.9 † 45–7

Boeing 727-200 157.9 † 1700 10.4 † 34–0

Lockheed L-100J Hercules 162.1 † 1745 11.6 † 38–3

Yakovlev Yak-42 150.0 † 1614 9.3 † 32–3

Boeing 737-600, -700, -800, -900 125.0 † 1345 12.5 † 43–3

Airbus A-318, A-319, A-320, A-321 122.6 † 1319 11.8 † 38–8

Boeing MD 80 112.3 † 1209 9.0 † 29–7

MD 90 9.3 † 30–7

Gulfstream V 105.6 † 1137 7.9 † 25–10

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Gross Wing Area Overall Height

Aircraft m 2 ft 2 m ft–in.

Boeing 737-300, -400, -500 105.4 † 1135 11.1 † 36–6

Tupolev TU-334, TU-354 100.0 † 1076 9.4 † 30–9

BAC 1-11-500 95.8 † 1031 7.5 † 24–6

NAMC YS-11 94.8 † 1020 8.9 † 29–5

Fokker 100, 70 93.5 † 1006 8.5 † 27–10

BAC 1-11-300, -400 93.2 1003 7.5 † 24–6

Boeing 717 93.0 † 1001 8.8 † 29–1

DC-9-30 93.0 † 1001 8.4 † 27–6

Boeing 737-200 91.0 † 980 11.3 † 37–0

Gulfstream IV 88.3 † 950 7.4 † 24–5

DC 9-10 86.8 † 934 8.4 † 27–6

BAe 146, RJX-70, -85, -100 77.3 † 832 8.6 † 28–3

Fokker 50, 60 70.0 † 753 2.7 † 27–3

Canadair RJ-700 68.6 † 738 7.6 † 24–10

Dash 8 Q400 63.0 † 679 7.5 † 24–7

ATR 72 61.0 † 656 7.6 † 25–1

Airtech CN-235 59.1 † 636 8.2 † 26–10

Saab 2000 55.7 † 600 7.7 † 25–4

Canadair RJ-100, -200 54.5 † 587 6.2 † 20–5

ATR 42 42.5 † 586 7.6 † 24–10

Dash 8 Q100, Q200 54.3 † 585 7.5 † 24–7

Embraer ERJ-135, -145 51.1 † 550 6.9 † 22–1

Cessna 750 48.9 † 527 5.8 † 18–11

Cessna 680 47.9 † 516 5.5 † 19–2

Saab 340 41.8 † 450 6.9 † 22–1

Embraer EMB-120 39.4 † 424 6.3 † 20–10

Bell Boeing V-22 39.5 † 382 6.6 † 21–9

Britten-Norman BN2 30.2 † 325 4.2 † 13–8

Cessna 650 28.9 † 312 5.1 † 16–9

Beech 1900 28.8 † 310 4.7 † 15–6

Beech King Air C90 27.3 † 294 4.3 † 14–3

*Aircraft with wing area in excess of 279 m2 (3000 ft2).

†Data from Jane’s All the World's Aircraft.

Statement of Problem and Substantiation for Public Input

Offices separated from aircraft storage and servicing areas should not be held to the strict standard of a hangar

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when fire rated construction is provided. This will allow a two-story office area adjacent to but separated from the hangar. Section 8.1.2 would seem to prohibit this arrangement.

Submitter Information Verification

Submitter Full Name: Doug Hohbein

Organization: Northcentral Fire Code Develop

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 09:53:57 EDT 2012

Committee Statement

Resolution: CI-61-NFPA 409-2013

Statement: This Committee Input proposes to significantly revise the requirements of Chapter 8. There issufficient confusion and uncertainty in the application of the standard to Group III hangars that thisproposal is presented for public review. The concepts of hangar clusters and row hangars tend tocause confusion. In order to simplify this chapter, the committee is considering whether aircraftstorage and servicing areas that are adequately separated by internal or external partitions should beconsidered independently of other nearby spaces and in accordance with the locally adopted buildingcode. See also CI 62 (3.3.9).

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Public Input No. 50-NFPA 409-2013 [ Section No. A.5.11.2.4 ]

A.5.11.2.4

In general, this means that the design has to be adequate to ensure that the liquid level at thecenter of the drain is below the top surface of the drain trench drain inlet grating for grated round,rectangular, and long trench-type inlets or below the floor surface in the case of a slit trench .

Statement of Problem and Substantiation for Public Input

Appendix material was not updated when trench drains were required. This is an editorial correction.

Submitter Information Verification

Submitter Full Name: Michael Aaron

Organization: The RJA Group, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 07 17:16:19 EDT 2013

Committee Statement

Resolution: FR-25-NFPA 409-2013

Statement: The clarification provided by the annex material is no longer needed.

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