Public Comment No. 20-NFPA [ Section No ] Statement of Problem and Substantiation for Public Comment Related Item

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1 of 27 9/2/2014 9:27 AM Public Comment No. 20-NFPA [ Section No ] ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM A 234/A 234M, Specification for Piping Fittings of Wrought Carbon Steel and Alloy Steel for Moderate and Elevated Temperatures, e1. ASTM A 53/A 53M Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless, ASTM A 135/A135M Standard Specification for Electric-Resistance- Welded Steel Pipe, (2014). ASTM A 795/A 795M Standard Specification for Black and Hot-Dipped Zinc-Coated (Galvanized)Welded and Seamless Steel Pipe for Fire Protection Use, ASTM B 16.5 Cast Bronze Threaded Fittings, 1985.?? ASTM B 43 Specification for Seamless Red Brass Pipe, ASTM B 75, Specification for Seamless Copper Tube, ASTM B 88, Specification for Seamless Copper Water Tube, ASTM B 251, Requirements for Wrought Seamless Copper and Copper-Alloy Tube, IEEE/ASTM-SI-10, Standard for Use of the International System of Units (SI): The Modern Metric System, Statement of Problem and Substantiation for Public Comment Update year dates Related Item First Revision No. 20-NFPA [Chapter A] Submitter Information Verification Submitter Full Name: Steve Mawn Organization: ASTM International Street Address: City: State: Zip: Submittal Date: Thu May 15 15:14:23 EDT 2014 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-19-NFPA Statement: Update year dates. The deleted standard is an ASME Standard, not an ASTM Standard.

2 of 27 9/2/2014 9:27 AM Public Comment No. 16-NFPA [ Section No ] Publications. American Water Works Association, 6666 West Quincy Avenue, Denver, CO C104, Cement Mortar Lining for Ductile Iron Pipe and Fittings for Water, C105, Polyethylene Encasement for Ductile Iron Pipe Systems, C110, Ductile Iron and Gray Iron Fittings, C111, Rubber-Gasket Joints for Ductile Iron Pressure Pipe and Fittings, C115, Flanged Ductile Iron Pipe with Ductile Iron or Gray Iron Threaded Flanges, C116, Protective Fusion-Bonded Epoxy Coatings for the Interior and Exterior Surfaces of Ductile-Iron and Gray-Iron Fittings for Water Supply Service, C150, Thickness Design of Ductile Iron Pipe, C151, Ductile Iron Pipe, Centrifugally Cast for Water, C153, Ductile-Iron Compact Fittings for Water Service, C200, Steel Water Pipe 6 in. and Larger, C203, Coal-Tar Protective Coatings and Linings for Steel Water Pipelines Enamel and Tape Hot Applied, C205, Cement-Mortar Protective Lining and Coating for Steel Water Pipe 4 in. and Larger Shop Applied, C206, Field Welding of Steel Water Pipe, C207, Steel Pipe Flanges for Waterworks Service Sizes 4 in. Through 144 in., C208, Dimensions for Fabricated Steel Water Pipe Fittings, C300, Reinforced Concrete Pressure Pipe, Steel-Cylinder Type, C301, Prestressed Concrete Pressure Pipe, Steel-Cylinder Type, C302, Reinforced Concrete Pressure Pipe, Non-Cylinder Type, C303, Reinforced Concrete Pressure Pipe, Steel-Cylinder Type, Pretensioned, C400, Standard for Asbestos-Cement Distribution Pipe, 4 in. Through 16 in. (100 mm through 400 mm), for Water Distribution Systems, C600, Standard for the Installation of Ductile Iron Water Mains and Their Appurtenances, C602, Cement-Mortar Lining of Water Pipe Lines 4 in. and Larger in Place, C603, Standard for the Installation of Asbestos-Cement Pressure Pipe, C900, Polyvinyl Chloride (PVC) Pressure Pipe, 4 in. Through 12 in., for Water Distribution, C905, Standard for Polyvinyl Chloride (PVC) Pressure Pipe and Fabricated Fittings, 14 in. Through 48 in. (350 mm Through 1200 mm), C906, Polyethylene (PE) Pressure Pipe and Fittings, 4 in. (100 mm) Through 63 in. (1575 mm) for Water Distribution, C909, Molecularly Oriented Polyvinyl Chloride (PVCO) Pressure Pipe, 4 in. through 24 in. (100 mm through 600 mm), for Water, Wastewater, and Reclaimed Water Service2010 M11, A Guide for Steel Pipe Design and Installation, 4th edition, Statement of Problem and Substantiation for Public Comment Reference is made to the statement of problem and substantiation of Public Comment No. 2-NFPA Related Public Comments for This Document Related Comment Public Comment No. 2-NFPA [Section No ] Related Item First Revision No. 19-NFPA [Chapter 10] Relationship Concordance Submitter Information Verification Submitter Full Name: Ariel Carp Organization: On my behalf Affilliation: On my behalf Street Address:

3 of 27 9/2/2014 9:27 AM City: State: Zip: Submittal Date: Wed May 07 19:08:28 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-3-NFPA Statement: Reference is made to the statement of problem and substantiation of Public Comment No. 2-NFPA

4 of 27 9/2/2014 9:27 AM Public Comment No. 15-NFPA [ Chapter 5 ] Chapter 5 Water Supplies

5 of 27 9/2/2014 9:27 AM 5.1* Connection to Waterworks Systems A connection to a reliable waterworks system shall be an acceptable water supply source * The volume and pressure of a public water supply shall be determined from waterflow test data or other approved method. 5.2 Size of Fire Mains Private Fire Service Mains. Hydraulic calculations shall show that the main is able to supply the total demand at the appropriate pressure for systems with multiple hydrants Mains Not Supplying Hydrants. For mains that do not supply hydrants, pipe sizes less than 6 in. (152 mm) nominal size shall be permitted to be used subject to the following restrictions: (1) The main shall supply only the following types of systems: (a) (b) (c) (d) (e) Automatic sprinkler systems Open sprinkler systems Water spray fixed systems Foam systems Standpipe systems (2) Hydraulic calculations shall show that the main is able to supply the total demand at the appropriate pressure. (3) Systems that are not hydraulically calculated shall have a main at least as large as the riser. 5.3 Pressure-Regulating Devices and Meters Pressure-regulating valves shall not be used Pressure-regulating valves shall be permitted to be used when acceptable to the AHJ Where meters are required they shall be listed. 5.4* Connection from Waterworks Systems The requirements of the public health AHJ shall be determined and followed Where a backflow prevention device is installed to guard against possible cross-contamination of the public water system, it shall be listed for fire protection service * Where a check valve or alarm check valve is permitted by the AHJ in lieu of a backflow preventer, it shall be listed for fire protection service. 5.5 Connections to Public Water Systems. Connections to public water systems shall be arranged to be isolated by one of the methods permitted in * Pumps. Fire pump units installed in accordance with NFPA 20and connected to a water supply source complying with Sections5.5, 5.7, or 5.8 shall use an acceptable water supply source. 5.7 Tanks. Tanks shall be installed in accordance with NFPA Penstocks, Rivers, Lakes, or Reservoirs. Water supply connections from penstocks, rivers, lakes, or reservoirs shall be designed to avoid mud and sediment and shall be provided with approved, double, removable screens or approved strainers installed in an approved manner. 5.9* Remote Fire Department Connections General. Where the AHJ requires a remote fire department connection for systems requiring one by another standard, a fire department connection shall be provided as described in Section Fire department connections shall be permitted to be omitted where approved by the AHJ Fire department connections shall be of an approved type Fire department connections shall be equipped with approved plugs or caps that are secured and arranged for easy removal by fire departments Fire department connections shall be protected where subject to mechanical damage Couplings.

6 of 27 9/2/2014 9:27 AM The fire department connection(s) shall use an NH internal threaded swivel fitting(s) with an NH standard thread(s.), except as permitted by and At least one of the connections shall be the 2.5 to 7.5 NH standard thread specified in NFPA Where local fire department connections use threads that do not conform to NFPA 1963, the AHJ shall designate the thread to be used Non-threaded couplings shall be permitted where required by the AHJ. Non-threaded couplings shall be listed for use as permitted in Valves A listed check valve shall be installed in the piping from each fire department connection Control valves shall not be installed in the piping from the fire department connection to the fire service main * Control valves shall be permitted in the system piping downstream of the fire department connection piping Drainage The pipe between the check valve and the outside hose coupling shall be equipped with an approved automatic drain valve The automatic drain valve shall be installed in a location that permits inspection and testing as required by NFPA 25 and reduces the likelihood of freezing The automatic drip shall be permitted to be buried where permitted by the AHJ Where the automatic drip is buried as allowed by , the outlet shall discharge into a bed of crushed stone or pea gravel An automatic drain valve is permitted to be omitted from areas where the piping is not subject to freezing The automatic drip shall be permitted to be buried where permitted by the AHJ Location and Signage * Remote fire department connections shall be located at the nearest point of fire department apparatus accessibility or at a location approved by the AHJ * Remote fire department connections shall be located and arranged so that hose lines can be attached to the inlets without interference * Each remote fire department connection shall be designated by a sign as follows: (1) The sign shall have raised or engraved letters at least 1 in. (25.4 mm) in height on a plate or fitting. (2) * The sign shall indicate the type of system for which the connection is intended Where the system demand pressure exceeds 150 psi (10.3 bar), a sign located at the fire department connection shall indicate the required inlet pressure Where a remote fire department connection only supplies a portion(s) of the building, a sign shall be attached to indicate the portion(s) of the building supplied Remote fire department connections shall not be connected on the suction side of fire pumps Where a remote fire department connection services multiple buildings, structures, or locations, a sign shall be provided indicating the buildings, structures, or locations served. Statement of Problem and Substantiation for Public Comment CC NOTE: The following CC Note No. 2 appeared in the First Draft Report as First Revision No. 15. The PRI TC should look at sections and to determine if these sections are redundant. Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification

7 of 27 9/2/2014 9:27 AM Submitter Full Name: CC on AUT-AAC Organization: CC on Automatic Sprinkler Systems Street Address: City: State: Zip: Submittal Date: Tue Apr 29 13:32:47 EDT 2014 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-4-NFPA Statement: This language is being deleted because it is already in Section

8 of 27 9/2/2014 9:27 AM Public Comment No. 18-NFPA [ New Section after ] * Where a waterflow test was conducted, the volume and pressure available for use for a fire protection system shall be determined from the following formula: P = (P 1 - P 2 )(Q/Q 1 ) 1.85 P The pressure P shall be what is considered available from the water supply to use for a fire protection system that will be calculated for a given flow demand of Q The flow Q shall be demand flow of the fire protection system that will be used to calculate the available pressure from the water supply (P) * The variable P shall be the residual pressure measured during the waterflow test while the flow Q was discharging from 1 1 the water supply reduced by the specifying engineer or the water utility for daily and seasonal fluctuations. The reduction shall not be based on 100 year droughts or other extreme conditions * The variable P shall be the static pressure measured during the waterflow test reduced by the specifying engineer or the 2 water utility for daily and seasonal fluctuations. The reduction shall not be based on 100 year droughts or other extreme conditions The variable Q shall be the flow associated with P * Where the specifying engineer or the water utility does not provide the value for P 1 and P 2, see * Where a waterflow test has been conducted and the specifying engineer or the water authority does not provide a value for P and P, the value of for P and P shall be calculated by taking the static pressure and residual pressure results from the flow test and reducing them by 5%. Additional Proposed Changes File Name Description Approved Water_Supply_Adjustment_Proposal-E_S-24.pdf whole proposal with figures and equations Statement of Problem and Substantiation for Public Comment This is one of a series of proposals to make the adjustment to the data from a waterflow test required instead of recommended. If the adjustment is not required, contractors that do the right thing and adjust the data from tests are at a disadvantage from contractors that don't make any adjustment. It is fundamentally wrong to not make an adjustment to the data due to daily and seasonal fluctuations. This proposal makes a simple and easy to understand adjustment that is standardized so that there is no argument over what is supposed to happen. It is the intent to have this be the only adjustment. If the water utility has already performed the adjustment, or if the AHJ has already mandated a safety margin or safety factor to the waterflow data obtained from the test, this adjustment would not apply. Related Item Public Input No. 56-NFPA [New Section after 5.1.2] Committee Input No. 2-NFPA [New Section after 5.1.2] 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: Thu May 08 18:01:38 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-17-NFPA Statement: The NFPA 13 technical committees have been discussing the need for adjusting waterflow data for several revision cycles. This revision aims to make the adjustment to the data from a waterflow test required instead of recommended. If the adjustment is not required, contractors that do the right thing and adjust the data from tests are at a disadvantage from contractors that don't make any adjustment. It is fundamentally wrong to not make an adjustment to the data due to daily and seasonal fluctuations.

9 of 27 9/2/2014 9:27 AM This makes makes a simple and easy to understand adjustment that is standardized so that there is no argument over what is supposed to happen. It is the intent to have this be the only adjustment. If the water utility has already performed the adjustment, or if the AHJ has already mandated a safety margin or safety factor to the waterflow data obtained from the test, this adjustment would not apply.

10 NFSA Comment to NFPA 13 on Waterflow Test Adjustments 1) Delete A A An adjustment to the waterflow test data to account for the following should be made, as appropriate: (1) Daily and seasonal fluctuations (2) Possible interruption by flood or ice conditions (3) Large simultaneous industrial use (4) Future demand on the water supply system (5) Other conditions that could affect the water supply 2) Insert a new and annex notes as follows: 5.1.3* Where a waterflow test was conducted, the volume and pressure available for use for a fire protection system shall be determined from the following formula: 1.85 Q 1 2 P Q 1 ( P P ) 2 P = The pressure P shall be what is considered available from the water supply to use for a fire protection system that will be calculated for a given flow demand of Q The flow Q shall be demand flow of the fire protection system that will be used to calculate the available pressure from the water supply (P) * The variable P 1 shall be the residual pressure measured during the waterflow test while the flow Q 1 was discharging from the water supply reduced by the specifying engineer or the water utility for daily and seasonal fluctuations. The reduction shall not be based on 100 year droughts or other extreme conditions * The variable P 2 shall be the static pressure measured during the waterflow test reduced by the specifying engineer or the water utility for daily and seasonal fluctuations. The reduction shall not be based on 100 year droughts or other extreme conditions The variable Q 1 shall be the flow associated with P * Where the specifying engineer or the water utility does not provide the value for P 1 and P 2, see * Where a waterflow test has been conducted and the specifying engineer or the water authority does not provide a value for P 1 and P 2, the value of for P 1 and P 2 shall be calculated by

11 taking the static pressure and residual pressure results from the flow test and reducing them by 5%. A Consider the following example. A waterflow test is conducted at a location where a city water main is going to be tapped for a new sprinkler system. During the test, the static pressure is measured at 70 psi, the residual pressure is measured at 50 psi while 1300 gpm was discharging from a nearby hydrant. The water utility is contacted and they indicate that a reasonable low static pressure accounting for typical daily and seasonal fluctuations in this area is 55 psi and that a reasonable low residual pressure accounting for typical daily and seasonal fluctuations in this area at a flow of 1300 gpm is 35 psi. The equation that describes the water supply available for a fire sprinkler system would be: P = Q ( 35 55) + 55 There are two ways to use this formula. One would be to assume two different values for Q, calculate P and then draw a graph on log 1.85 paper. Any fire sprinkler system demand falling on or below the line on this graph would be acceptable in accordance with NFPA 13 to work with this water supply. In this case, the two easiest flows to pick for Q would be 0 and 1300 gpm. When Q = 0, P is simply 55 psi. When Q = 1300 gpm, P = 35 psi. These two points can be plotted on log 1.85 paper as shown in Figure A The second way to use this formula would be to calculate the fire protection system and determine the flow necessary to make the system work. Plug this flow into the formula above and see what the available pressure from the water supply will be at that flow. For example, if a sprinkler system connected to this water supply had a demand of 580 gpm, the available pressure from the water supply would be: P = ( 35 55) + 55 P = (-20)(0.225) + 55 P = 50.5 psi So, as long as the sprinkler system has a pressure demand less than or equal to 50.5 psi, it will work with this water supply.

12 Figure A Available Water Supply Curve for Example in Section A A The purpose of the adjustment required by this section is to take into account reasonable fluctuations that occur on a daily and seasonal basis, but not to burden the building owner with extreme conditions. During an extreme condition such as a water main break or a severe drought, the impaired system provisions of NFPA 25 can be employed to mitigate the circumstances of the extreme condition. The intent of this section is to apply the adjustment to the raw data obtained by the flow test and not to apply adjustments to values that have already been adjusted by water utilities. If a water utility has already provided flow and pressure data for use in the design of fire protection systems that already includes adjustments for daily and seasonal water usage, there is no need to make any additional adjustments to this data. A See annex note A A Water utilities are the entities that know their own supplies the best and know what appropriate adjustments need to be made to flow test data to provide reasonable fire protection. In the potential situation where the water utility will not make a definitive statement with regard to an adjustment, the fire protection engineer is the person that would need to make a statement with respect to adjustments to the raw data from a flow test. Due to the judgment involved in making such a decision, the licensing laws in most states within the United States would require the fire protection engineer to make this determination rather than the fire protection system contractor. It is expected that the engineer would make these statements in the specifications provided to the fire protection system contractor. In the absence of any information from any authority on the subject, section provides a standardized method of making a decision. A This section provides a standardized method of making a decision regarding the reduction of the results from a waterflow test to determine what pressure and flow are available from a water supply when the specifying engineer and the water utility have not provided adjustment information. An example of how to use this standardized method follows.

13 If a waterflow test is conducted at a location where a city water main is going to be tapped for a new sprinkler system and the static pressure is measured at 70 psi, with the residual pressure measured at 50 psi while 1300 gpm was discharging from a nearby hydrant. If there is no information from the specifying engineer or water utility regarding appropriate adjustments, the value of the static pressure and residual pressure need to be reduced by 5%. The static pressure would be adjusted from 70 psi to 66.5 psi (70 x 0.95 = 66.5). The residual pressure at 1300 gpm would be reduced from 50 psi to 47.5 psi (70 x 0.95 = 47.5). The results would be plotted on log 1.85 graph paper as shown in the lower curve on Figure A and that curve would represent what the fire protection system contractor could use for a fire protection system. Figure A Available Water Supply Curve for Example in Section A

14 0 of 27 9/2/2014 9:27 AM Public Comment No. 3-NFPA [ Section No ] Private Fire Service Mains. Hydraulic calculations shall show that the main is able to supply the total demand at the appropriate pressure for systems with multiple hydrants. Statement of Problem and Substantiation for Public Comment The current wording appears to infer that pressures and flow are not material for single fire hydrant installations. A 6" line may be completely insufficient to supply a single hydrant at the end of a long dead end with a high fire flow condition. The PC removes the multiple hydrant constraint. Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification Submitter Full Name: Anthony Apfelbeck Organization: Altamonte Springs Building/Fire Safety Division Street Address: City: State: Zip: Submittal Date: Thu Feb 20 21:04:49 EST 2014 Committee Statement Committee Accepted Action: Resolution: SR-16-NFPA Statement: The current wording appears to infer that pressures and flow are not material for single fire hydrant installations. A 6" line may be completely insufficient to supply a single hydrant at the end of a long dead end with a high fire flow condition. The PC removes the multiple hydrant constraint.

15 1 of 27 9/2/2014 9:27 AM Public Comment No. 6-NFPA [ Section No ] Where meters are required they shall be listed for fire protection. Statement of Problem and Substantiation for Public Comment It is important to indicate the listing needs to be for fire protection. Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:06:56 EDT 2014 Committee Statement Committee Accepted Action: Resolution: SR-6-NFPA Statement: It is important to indicate the listing needs to be for fire protection. The word "service" was added to the proposed language in PC-6 for consistency with the remainder of the standard.

16 2 of 27 9/2/2014 9:27 AM Public Comment No. 13-NFPA [ Section No ] Non-threaded couplings shall be permitted where required by the AHJ Non-threaded couplings shall be listed for use as permitted in Additional Proposed Changes File Name LGK_NFPA_ _Comment_ pdf Description Approved PC Form Statement of Problem and Substantiation for Public Comment Editorial. The two separate provisions should be written in two separate sections. Additionally, as written in the First Draft Report, the second sentence of Section is referring to its own section number. Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification Submitter Full Name: Larry Keeping Organization: Professional Loss Control Street Address: City: State: Zip: Submittal Date: Thu Apr 24 13:50:51 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-7-NFPA Statement: The two separate provisions should be written in two separate sections. Additionally, as written in the First Draft Report, the second sentence of Section is referring to its own section number.

17 3 of 27 9/2/2014 9:27 AM Public Comment No. 7-NFPA [ Section No ] Non-threaded couplings shall be permitted where required by the AHJ Non-threaded couplings shall be listed for use as permitted in Statement of Problem and Substantiation for Public Comment Manual of Style Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:10:00 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-7-NFPA Statement: The two separate provisions should be written in two separate sections. Additionally, as written in the First Draft Report, the second sentence of Section is referring to its own section number.

18 4 of 27 9/2/2014 9:27 AM Public Comment No. 14-NFPA [ Sections , , ] Sections , , The automatic drain valve shall be installed in a location that permits inspection and testing as required by NFPA 25 and reduces the likelihood of freezing The automatic drip shall be permitted to be buried where permitted by the AHJ Where the automatic drip is buried as allowed by , the outlet shall discharge into a bed of crushed stone or pea gravel An automatic drain valve is permitted to be omitted from areas where the piping is not subject to freezing The automatic drip shall be permitted to be buried where permitted by the AHJ. Additional Proposed Changes File Name LGK_NFPA_ _Comment_ pdf Description Approved PC Form Statement of Problem and Substantiation for Public Comment Neither PI No. 19 nor PI No.45 requested the text for It appears to be a typographic error and it is redundant to the text proposed for , so it should be deleted. Regarding and , this proposed text that would allow an automatic drain (ball drip) to be buried is contrary to the leading requirement to make it accessible, as required by NFPA 25. If it is buried, it cannot be accessed. There is no reason to bury an automatic drain. Its function is to catch leakage from the Fire Department Connection s check valve if subject to freezing. Since NFPA 13 in Section requires that the check valve must be installed in an accessible location, it cannot be buried. As per NFPA 13, A check valves should be made accessible accessible for maintenance. This can be accomplished by a valve pit or any means that renders the valve accessible. Therefore, there is no reason to allow the corresponding ball drip to be buried. Further a ball drip is not required unless the FDC piping is subject to freezing, and buried FDC piping would not be subject to freezing unless it was buried at too shallow a depth. So again, there is no reason to bury the automatic drain/ball drip. Thus, and should also be deleted. Related Item Public Input No. 18-NFPA [New Section after ] Public Input No. 19-NFPA [Section No ] Public Input No. 45-NFPA [Section No ] Submitter Information Verification Submitter Full Name: Larry Keeping Organization: Professional Loss Control Street Address: City: State: Zip: Submittal Date: Thu Apr 24 13:53:03 EDT 2014 Committee Statement Committee Rejected Action: Resolution: Many AHJ's require that fire department connections (FDC) are remote. NFPA suggests that the check valve for the FDC be located as close to the connection to the system as possible. This could leave long sections of underground piping with no pressure. This piping could get cut and one will not know about it until an NFPA 25 inspection is performed or the fire department pumps into the connection. Many AHJ's want water brought as close to the FDC as possible to avoid this situation. By requiring access to the ball drip, this could require a vault or deep meter box costing hundreds of dollars. This new section gives the AHJ an allowance to require the automatic drip close to the FDC and still have water on the underground piping for supervision Almost all the fire department connection plates indicating the connection type (autosprinkler, standpipe or both) are bought directly from the fire department connection manufacturers. Engraving these with the required inlet pressure is impractical. Also, since the sign referred to requires one inch high letters, it could be construed that the pressure information should also be the same size. In the fire sprinkler business, when a higher pressure requirement must be posted, we have custom made signs produced and placed on or at the FDC.

19 5 of 27 9/2/2014 9:27 AM Public Comment No. 8-NFPA [ Section No ] The automatic drip shall be permitted to be buried where permitted by the AHJ. Statement of Problem and Substantiation for Public Comment This language is already in Section Related Item First Revision No. 15-NFPA [Chapter 5] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:13:09 EDT 2014 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-4-NFPA Statement: This language is being deleted because it is already in Section

20 6 of 27 9/2/2014 9:27 AM Public Comment No. 9-NFPA [ Section No ] A valve in accordance with Section 6.1shall be installed in each pipeline from each water supply Control valves shall not be installed in the piping from the fire department connection to the point it connects to the fire service main Control valves shall be permitted in the system piping downstream of the fire department connection. Statement of Problem and Substantiation for Public Comment Modified the wording to indicate that the valve downstream of the FDC can only be in system piping. Related Item Public Input No. 88-NFPA [Section No ] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:19:36 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-8-NFPA Statement: Modified the wording to indicate that the valve downstream of the FDC can only be in system piping.

21 7 of 27 9/2/2014 9:27 AM Public Comment No. 2-NFPA [ Section No ]

22 8 of 27 9/2/2014 9:27 AM Listing.

23 9 of 27 9/2/2014 9:27 AM Piping manufactured in accordance with Table shall be permitted to be used.. Table Manufacturing Standards for Underground Pipe Materials and Dimensions Ductile Iron Cement Mortar Lining for Ductile Iron Pipe and Fittings for Water Polyethylene Encasement for Ductile Iron Pipe Systems Rubber-Gasket Joints for Ductile Iron Pressure Pipe and Fittings Flanged Ductile Iron Pipe with Ductile Iron or Gray Iron Threaded Flanges Thickness Design of Ductile Iron Pipe Ductile Iron Pipe, Centrifugally Cast for Water Standard for the Installation of Ductile Iron Water Mains and Their Appurtenances Steel Steel Water Pipe 6 in. and Larger Coal-Tar Protective Coatings and Linings for Steel Water Pipelines Enamel and Tape Hot Applied Cement-Mortar Protective Lining and Coating for Steel Water Pipe 4 in. and Larger Shop Applied Field Welding of Steel Water Pipe Steel Pipe Flanges for Waterworks Service Sizes 4 in. Through 144 in. Dimensions for Fabricated Steel Water Pipe Fittings A Guide for Steel Pipe Design and Installation Concrete Reinforced Concrete Pressure Pipe, Steel-Cylinder Type Prestressed Concrete Pressure Pipe, Steel-Cylinder Type Reinforced Concrete Pressure Pipe, Non-Cylinder Type Reinforced Concrete Pressure Pipe, Steel-Cylinder Type, Pretensioned Standard for Asbestos-Cement Distribution Pipe, 4 in. Through 16 in., for Water Distribution Systems Cement-Mortar Lining of Water Pipe Lines 4 in. and Larger in Place Plastic Polyvinyl Chloride (PVC) Pressure Pipe, 4 in. Through 12 in., for Water Distribution Polyvinyl Chloride (PVC) Pressure Pipe, 14 in. Through 48 in., for Water Distribution Polyethylene (PE) Pressure Pipe and Fittings, 4 in. (100 mm) Through 63 in. (1575 mm) for Water Distribution Molecularly Oriented Polyvinyl Chloride (PVCO) 4 in. Through 12 in. (100 mm Through 600 mm) for Water Distribution Brass Specification for Seamless Red Brass Pipe Standard C104 C105 C111 C115 C150 C151 C600 C200 C203 C205 C206 C207 C208 M11 C300 C301 C302 C303 C400 C602 C900 C905 C906 C909 ASTM B 43 Copper

24 0 of 27 9/2/2014 9:27 AM Materials and Dimensions Specification for Seamless Copper Tube Specification for Seamless Copper Water Tube Requirements for Wrought Seamless Copper and Copper-Alloy Tube Standard ASTM B 75 ASTM B 88 ASTM B 251 Statement of Problem and Substantiation for Public Comment Same change is proposed for NFPA See Public Comment No. 222-NFPA Reference is made to First Revision No. 19-NFPA [Chapter 10]. First Revision No. 19-NFPA [Chapter 10] says that to select pipe for underground service there is the ability to use the Table (former Table ), the ability to use pipe specifically listed for underground use, and the allowance to use steel pipe between the FDC (Fire Department Connection) and the check valve. This statement is according NFPA Also the First Revision No. 19-NFPA [Chapter 10] says that the steel piping references were removed from the Table since steel pipe is required to be listed except for the FDC line. This statement is not according NFPA According to NFPA : - Steel pipe is not required to be listed except for general underground service. - Steel pipe is required to be listed except for the FDC line and except for not general underground service. According to NFPA , not listed steel can be used for an underground pipe main, when that pipe main is used only for fire service. The paragraph of NFPA says: Steel piping shall not be used for general underground service unless specifically listed for such service. A general service refers to a pipe main that it is used for fire service and also for purposes other than fire service. Not general service refers to a pipe main that it is used only for fire service and it is not used for other purposes. Steel piping can be used for general underground service if it is listed. If it is not listed, it can not be used for general underground service. If the service of the pipe main is not general, if it is for fire service only (e.g. it is not used for purposes other than fire service), then steel can be used. For fire service only: - if steel is listed, the proper condition of listing provides the ability to use it. - if steel is not listed, steel can be used (again: for fire service only) because its inclusion in the Table provides the ability to use it. If steel is removed from the Table , the ability to use not listed steel for fire service only, also is removed. Removing steel from Table implies that steel pipe will be required to be listed in order to be used for underground fire service. This is not a current requirement of NFPA Removing steel from Table implies a change to the NFPA Currently there is the ability to use not listed steel for underground fire service only, but as a consequence of the proposal shown in First Revision No. 19-NFPA [Chapter 10], there will not be anymore the ability to use not listed steel for underground fire service. This is a change to the NFPA The statement included in the First Revision No. 19-NFPA [Chapter 10] : The steel piping references were removed from the table since steel pipe is required to be listed other than in the FDC line, is not according NFPA As NFPA Annotated explains: Accordingly, steel pipe can no longer be installed for general underground service, unless it is specially listed for the purpose. (bold letters included on purpose). NFPA Annotated also says: At this time, no such listings are available. This is also true today. UL and FM does not have steel pipe listed for underground use. There is no expectation that UL and/or FM will list the steel for underground use in the future. To live the ability to use steel for underground use, only if it is listed, introduces a constraint that it will be very difficult or impossible to surmount, and practically converts the steel for underground use in something unreal. To keep questioned the steel for underground use brings the existent firewater piping underground installations into question as well as other pipe underground installations that are made of steel. It is requested to keep the steel in the Table in order to prevent doing a change whose current substantiation cause and effect that it is seems to not be foreseen in the First Revision No. 19-NFPA [Chapter 10]: steel pipe will not be able to be installed anymore for any underground service. Related Public Comments for This Document Related Comment Public Comment No. 16-NFPA [Section No ] Related Item First Revision No. 19-NFPA [Chapter 10] Relationship Submitter Information Verification

25 1 of 27 9/2/2014 9:27 AM Submitter Full Name: Ariel Carp Organization: On my behalf Affilliation: On my behalf Street Address: City: State: Zip: Submittal Date: Wed Feb 19 16:51:47 EST 2014 Committee Statement Committee Action: Resolution: Rejected The document has required steel piping for general underground service to be listed for the last few editions. If steel piping is to be used, the manufacturers installations instructions would need to be followed. Including the proposed data in the table does not add any value since the installation guidelines will cover all essential installation practices. Table sufficiently addresses the allowance for the steel piping to be used in the fire department connection piping.

26 2 of 27 9/2/2014 9:27 AM Public Comment No. 10-NFPA [ Section No ] Approved fittings shall be permitted to be used. Statement of Problem and Substantiation for Public Comment There are available fittings on the market that are listed or are in accordance with Table This section allows practically anything as long as it is approved. Related Item Public Input No. 39-NFPA [Section No. 10.2] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:38:45 EDT 2014 Committee Statement Committee Accepted Action: Resolution: SR-9-NFPA Statement: There are available fittings on the market that are listed or are in accordance with Table This section allows practically anything as long as it is approved.

27 3 of 27 9/2/2014 9:27 AM Public Comment No. 11-NFPA [ Section No ] Heat tracing not listed for underground use shall be permitted when piping is installed in accordance with Statement of Problem and Substantiation for Public Comment I believe this is the correct section to reference. Related Item First Revision No. 19-NFPA [Chapter 10] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Fri Apr 18 16:44:48 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-10-NFPA Statement: I believe this is the correct section to reference.

28 4 of 27 9/2/2014 9:27 AM Public Comment No. 12-NFPA [ Section No ] * The requirement of 10 of shall not preclude the bonding of the underground piping to the lightning protection grounding system as required by NFPA 780 in those cases where lightning protection is provided for the structure. Additional Proposed Changes File Name LGK_NFPA_ _Comment_ pdf Description Approved PC Form Statement of Problem and Substantiation for Public Comment Editorial correction. The reference was not revised during the Chapter 10 rewrite. Related Item First Revision No. 19-NFPA [Chapter 10] Submitter Information Verification Submitter Full Name: Larry Keeping Organization: Professional Loss Control Street Address: City: State: Zip: Submittal Date: Thu Apr 24 13:48:46 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-11-NFPA Statement: Editorial correction. The reference was not revised during the Chapter 10 rewrite.

29 5 of 27 9/2/2014 9:27 AM Public Comment No. 19-NFPA [ New Section after A ] A Consider the following example. A waterflow test is conducted at a location where a city water main is going to be tapped for a new sprinkler system. During the test, the static pressure is measured at 70 psi, the residual pressure is measured at 50 psi while 1300 gpm was discharging from a nearby hydrant. The water utility is contacted and they indicate that a reasonable low static pressure accounting for typical daily and seasonal fluctuations in this area is 55 psi and that a reasonable low residual pressure accounting for typical daily and seasonal fluctuations in this area at a flow of 1300 gpm is 35 psi. The equation that describes the water supply available for a fire sprinkler system would be: There are two ways to use this formula. One would be to assume two different values for Q, calculate P and then draw a graph on log 1.85 paper. Any fire sprinkler system demand falling on or below the line on this graph would be acceptable in accordance with NFPA 13 to work with this water supply. In this case, the two easiest flows to pick for Q would be 0 and 1300 gpm. When Q = 0, P is simply 55 psi. When Q = 1300 gpm, P = 35 psi. These two points can be plotted on log 1.85 paper as shown in Figure A The second way to use this formula would be to calculate the fire protection system and determine the flow necessary to make the system work. Plug this flow into the formula above and see what the available pressure from the water supply will be at that flow. For example, if a sprinkler system connected to this water supply had a demand of 580 gpm, the available pressure from the water supply would be: P = (-20)(0.225) 55 P = 50.5 psi So, as long as the sprinkler system has a pressure demand less than or equal to 50.5 psi, it will work with this water supply. Figure A Available Water Supply Curve for Example in Section A A The purpose of the adjustment required by this section is to take into account reasonable fluctuations that occur on a daily and seasonal basis, but not to burden the building owner with extreme conditions. During an extreme condition such as a water main break or a severe drought, the impaired system provisions of NFPA 25 can be employed to mitigate the circumstances of the extreme condition. The intent of this section is to apply the adjustment to the raw data obtained by the flow test and not to apply adjustments to values that have already been adjusted by water utilities. If a water utility has already provided flow and pressure data for use in the design of fire protection systems that already includes adjustments for daily and seasonal water usage, there is no need to make any additional adjustments to this data. A See annex note A A Water utilities are the entities that know their own supplies the best and know what appropriate adjustments need to be made to flow test data to provide reasonable fire protection. In the potential situation where the water utility will not make a definitive statement with regard to an adjustment, the fire protection engineer is the person that would need to make a statement with respect to adjustments to the raw data from a flow test. Due to the judgment involved in making such a decision, the licensing laws in most states within the United States would require the fire protection engineer to make this determination rather than the fire protection system contractor. It is expected that the engineer would make these statements in the specifications provided to the fire protection system contractor. In the absence of any information from any authority on the subject, section provides a standardized method of making a decision. A This section provides a standardized method of making a decision regarding the reduction of the results from a waterflow test to determine what pressure and flow are available from a water supply when the specifying engineer and the water utility have not provided adjustment information. An example of how to use this standardized method follows. If a waterflow test is conducted at a location where a city water main is going to be tapped for a new sprinkler system and the static pressure is measured at 70 psi, with the residual pressure measured at 50 psi while 1300 gpm was discharging from a nearby hydrant. If there is no information from the specifying engineer or water utility regarding appropriate adjustments, the value of the static pressure and residual pressure need to be reduced by 5%. The static pressure would be adjusted from 70 psi to 66.5 psi (70 x 0.95 = 66.5). The residual pressure at 1300 gpm would be reduced from 50 psi to 47.5 psi (70 x 0.95 = 47.5). The results would be plotted on log 1.85 graph paper as shown in the lower curve on Figure A and that curve would represent what the fire protection system contractor could use for a fire protection system. Figure A Available Water Supply Curve for Example in Section A Additional Proposed Changes File Name Description Approved Water_Supply_Adjustment_Proposal-E_S-24.pdf Whole comment with equations and figures

30 6 of 27 9/2/2014 9:27 AM Statement of Problem and Substantiation for Public Comment This is one of a series of proposals to make the adjustment to the data from a waterflow test required instead of recommended. If the adjustment is not required, contractors that do the right thing and adjust the data from tests are at a disadvantage from contractors that don't make any adjustment. It is fundamentally wrong to not make an adjustment to the data due to daily and seasonal fluctuations. This proposal makes a simple and easy to understand adjustment that is standardized so that there is no argument over what is supposed to happen. It is the intent to have this be the only adjustment. If the water utility has already performed the adjustment, or if the AHJ has already mandated a safety margin or safety factor to the waterflow data obtained from the test, this adjustment would not apply. Related Item Public Input No. 56-NFPA [New Section after 5.1.2] Committee Input No. 2-NFPA [New Section after 5.1.2] 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: Thu May 08 18:15:01 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-17-NFPA Statement: The NFPA 13 technical committees have been discussing the need for adjusting waterflow data for several revision cycles. This revision aims to make the adjustment to the data from a waterflow test required instead of recommended. If the adjustment is not required, contractors that do the right thing and adjust the data from tests are at a disadvantage from contractors that don't make any adjustment. It is fundamentally wrong to not make an adjustment to the data due to daily and seasonal fluctuations. This makes makes a simple and easy to understand adjustment that is standardized so that there is no argument over what is supposed to happen. It is the intent to have this be the only adjustment. If the water utility has already performed the adjustment, or if the AHJ has already mandated a safety margin or safety factor to the waterflow data obtained from the test, this adjustment would not apply.

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