Report on Comments A2006 Copyright, NFPA NFPA 20 Report of the Committee on

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1 Report of the Committee on James J. Koral, General Motors, NY [U] (Alt. to Thomas R. Boccetti) Fire Pumps Timothy J. LaRose, Hughes Associates, Incorporated, RI [SE] (Alt. to Lawrence J. Wenzel) John D. Jensen, Chair Gary Lauer, ITT A-C Fire Pump Systems, IL [M] Fire Protection Consultant, UT [SE] (Alt. to Hansford Stewart) Charles W. McKnight, Bechtel National Incorporated, WA [U] Frank L. Moore, Secretary (Alt. to Garry W. Yaffe) Moore Pump and Equipment, Incorporated, MS [IM] J. Scott Mitchell, American Fire Sprinkler Association, TX [IM] (Alt. to Alan A. Dorini) (Alt. to Bill M. Harvey) Michael R. Moran, State of Delaware, DE [E] (Alt. to R. T. Leicht) Jay Reddy, R-B Pump, Incorporated, GA [M] (Alt. to Darrell A. Snyder) William F. Stelter, Master Control Systems, Incorporated, IL [M] (Alt. to Richard Schneider) David M. Whitfield, S-P-D Incorporated, IL [M] (Voting Alt. to IFPA Rep.) Shay Pei Wu, Schirmer Engineering Corporation, MD [I] (Alt. to Gayle Pennel) Thomas R. Boccetti, The DuPont Company, DE [U] Rep. NFPA Industrial Fire Protection Section Pat D. Brock, Oklahoma State University, OK [SE] Hugh D. Castles, Entergy Services, Incorporated, LA [U] Rep. Edison Electric Institute Phillip A. Davis, Allianz Global Risks, IL [I] Alan A. Dorini, Gulfstream Pump & Equipment, Incorporated, FL [IM] George W. Flach, George W. Flach Consultant, Incorporated, LA [SE] Dana R. Haagensen, Massachusetts Office of the Fire Marshal, MA [E] Bill M. Harvey, Harvey & Associates, Incorporated, SC [IM] Rep. American Fire Sprinkler Association Hatem Ezzat Kheir, Kheir Group, Egypt [IM] Timothy S. Killion, Peerless Pump Company, IN [M] John R. Kovacik, Underwriters Laboratories Incorporated, IL [RT] R. T. Leicht, State of Delaware, DE [E] Rep. International Fire Marshals Association Stephen A. Mezsick, Eli Lilly and Company, IN [U] Rep. American Chemistry Council David S. Mowrer, HSB Professional Loss Control, TN [I] Gayle Pennel, Schirmer Engineering Corporation, IL [I] Jeffrey R. Roberts, GE Insurance Solutions, MS [I] Matthew Roy, S.A. Armstrong, Limited, Canada [M] Richard Schneider, Joslyn Clark Controls, SC [M] Rep. National Electrical Manufacturers Association Darrell A. Snyder, Patterson Pump Company, GA [M] Rep. Hydraulic Institute Hansford Stewart, ITT A-C Fire Pump Systems, IL [M] Terry L. Victor, Tyco/SimplexGrinnell, MD [IM] Rep. National Fire Sprinkler Association Lawrence J. Wenzel, Hughes Associates, Incorporated, CT [SE] John Whitney, Clarke Fire Protection Products, Incorporated, OH [M] Rep. Engine Manufacturers Association Garry W. Yaffe, US Department of Energy, SC [U] Alternates Kerry M. Bell, Underwriters Laboratories Incorporated, IL [RT] (Alt. to John R. Kovacik) Tim Fernholtz, Sterling Fluid Systems-Peerless Pump, CA [M] (Alt. to Timothy S. Killion) Brandon W. Frakes, GE Insurance Solutions, NC [I] (Alt. to Jeffrey R. Roberts) David B. Fuller, FM Global, MA [I] (Voting Alt. to FM Rep.) Kenneth E. Isman, National Fire Sprinkler Association, NY [IM] (Alt. to Terry L. Victor) Nonvoting Edward D. Leedy, Naperville, IL (Member Emeritus) James W. Nolan, James W. Nolan Company, IL Staff Liaison: David R. Hague Committee Scope: This Committee shall have primary responsibility for documents on the selection and installation of stationary pumps supplying water or special additives including but not limited to foam concentrates for private fire protection, including suction piping, valves and auxiliary equipment, electric drive and control equipment, and internal combustion engine drive and control equipment. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. This portion of the Technical Committee Report of the Committee on Fire Pumps is presented for adoption. This Report on Comments was prepared by the Technical Committee on Fire Pumps, and documents its action on the comments received on its Report on Proposals on NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2003 edition, as published in the Report on Proposals for the 2006 June Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Fire Pumps, which consists of 27 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 20-

2 (D) Controller Connected to Alternate Source. Where two sources of 20-1 Log #CC3 Final Action: Accept power are supplied to meet the requirements of 9.2.4, this alarm circuit (Entire Document) signal shall indicate whenever the alternate source is the source supplying Submitter: Technical Committee on Fire Pumps Comment on Proposal No: Recommendation: Modify the following sections: 3.3 General Definitions (NEW) Fire Pump Alarm. A supervisory signal indicating an abnormal condition requiring immediate attention * Signal. An indicator of status. A A response to signals is expected within two hours * Devices in Suction Piping. (3) Suitable devices shall be permitted to be installed in the suction supply piping or stored water supply and arranged to activate a n alarm signal if the pump suction pressure or water level falls below a predetermined minimum. 5.23* Alarms. Other Signals. When required by other sections of this standard, alarms signals shall call attention to improper conditions in the fire pump equipment. A.5.23 In addition to those conditions that require alarm signals for pump controllers and engines, there are other conditions for which such alarms signals might be recommended, depending upon local conditions. Some of these supervisory alarm conditions are as follows: (1) Low pump room temperature (2) Relief valve discharge (3) Flowmeter left on, bypassing the pump (4) Water level in suction supply below normal (5) Water level in suction supply near depletion (6) Diesel fuel supply below normal (reference Proposal ) (7) Steam pressure below normal Such additional alarms signals can be incorporated into the trouble alarms signals already provided on the controller, or they can be independent Accessory devices, including Fire Pump alarm monitoring and signaling means, are included where necessary to ensure the minimum performance of the aforementioned equipment * Single Phase. A The alarms signal should incorporate local visible indication and contacts for remote indication. The alarms signal can be incorporated as part of the power available indication and loss of phase signal [see and (B)] Sensors shall be permitted to prevent a three-phase motor from starting under single-phase condition Such sensors shall not cause disconnection of the motor if it is running at the time of single-phase occurrence Such sensors shall be monitored to provide a local visible alarms signal in the event of malfunction of the sensors * Alarm and Signal Devices on Controller. A The pilot lamp for alarm and signal service should have operating voltage less than the rated voltage of the lamp to ensure long operating life. When necessary, a suitable resistor or potential transformer should be used to reduce the voltage for operating the lamp * Fire Pump Alarm and Signal Devices Remote from Controller. A Where unusual conditions exist whereby pump operation is not certain, a failed-to-operate Fire Pump alarm is recommended. In order to supervise the power source for the Fire Pump alarm circuit, the controller can be arranged to start upon failure of the supervised alarm circuit power Where the pump room is not constantly attended, audible or visible alarms signals powered by a source not exceeding 125 V shall be provided at a point of constant attendance These Fire Pump alarms and signals shall indicate the information in (A) through (D). (A) Pump or Motor Running. The alarm signal shall actuate whenever the controller has operated into a motor-running condition. This alarm signal circuit shall be energized by a separate reliable supervised power source or from the pump motor power, reduced to not more than 125 V. (B) Loss of Phase. (1) The Fire Pump alarm shall actuate whenever The loss of any phase at the line terminals of the motor contactor shall be monitored is lost. (2) All phases shall be monitored. Such monitoring shall detect loss of phase whether the motor is running or at rest. (3) When power is supplied from multiple power sources, monitoring of each power source for phase loss shall be permitted at any point electrically upstream of the line terminals of the contactor, provided all sources are monitored. (C) Phase Reversal. (See ) This Fire Pump alarm circuit shall be energized by a separate reliable supervised power source or from the pump motor power, reduced to not more than 125 V. The Fire Pump alarm shall actuate whenever the 3-phase power at the line terminals of the motor contactor is reversed. power to the controller. This alarm signal circuit shall be energized by a separate reliable, supervised power source, reduced to not more than 125 V Controller Alarm Contacts for Remote Indication. Controllers shall be equipped with contacts (open or closed) to operate circuits for the conditions in (A) through (C) and when a controller is equipped with a transfer switch in accordance with (D) Alarm and Signal Devices Indicators on Controller Specifications for controllers rated in excess of 600 V differ from those in A visible indicator shall be provided to indicate that power is available The current supply for the visible indicator shall come from the secondary of the control circuit transformer through resistors, if found necessary, or from a small-capacity stepdown transformer, which shall reduce the control transformer secondary voltage to that required for the visible indicator If the visible indicator is a pilot lamp, it shall be accessible for replacement Accessory devices, such as Fire Pump alarm monitoring and signaling means, are included where necessary to ensure minimum performance of the aforementioned equipment Alarm and Signal Devices Indicators on Controller All visible indicators alarms shall be plainly visible * Visible indication shall be provided to indicate that the controller is in the automatic position. If the visible indicator is a pilot lamp, it shall be accessible for replacement. A It is recommended that the pilot lamp for alarm and signal service have operating voltage less than the rated voltage of the lamp to ensure long operating life. When necessary, a suitable resistor should be used to reduce the voltage for operating the lamp Separate visible indicators and a common audible Fire Pump alarm capable of being heard while the engine is running and operable in all positions of the main switch except the off position shall be provided to immediately indicate trouble caused by the following conditions: (1) Critically low oil pressure in the lubrication system. The controller shall provide means for testing the position of the pressure switch contacts without causing trouble Fire Pump alarms. (2) High engine jacket coolant temperature. (3) Failure of engine to start automatically. (4) Shutdown from overspeed Separate visible indicators and a common audible signal capable of being heard while the engine is running and operable in all positions of the main switch except the off position shall be provided to immediately indicate the following conditions: (1) Battery failure or missing battery. Each controller shall be provided with a separate visible indicator for each battery. (2) Battery charger failure. Each controller shall be provided with a separate visible indicator for battery charger failure and shall not require the audible alarm signal for battery charger failure. (3) Low air or hydraulic pressure. Where air or hydraulic starting is provided (see and ), each pressure tank shall provide to the controller separate visible indicators to indicate low pressure. (4) System overpressure, for engines equipped with pressure limiting controls, to actuate at 115 percent of total rated head (pressure). (5) ECM selector switch in alternate ECM position (for engines with ECM controls only). (6) Fuel injection malfunction (for engines with ECM only). (7) Low fuel level. Alarm Signal at two-thirds tank capacity. [NOTE: Renumber following text accordingly for new section above.] No audible alarm signal silencing switch, other than the controller main switch, shall be permitted for the conditions reflected alarms required in and Exception: A separate alarm silence switch shall be used for the low fuel level indication in (7) Alarm and Signal Devices Remote from Controller Where the pump room is not constantly attended, audible or visible alarms and signals powered by a source other than the engine starting batteries and not exceeding 125 V shall be provided at a point of constant attendance These alarms The remote panel shall indicate the following: (1) The engine is running (separate signal). (2) The controller main switch has been turned to the off or manual position (separate signal). (3)* Trouble on the controller or engine (separate or common signals). (See , and ) A (3) The following trouble signals should be monitored remotely from the controller: (1) A common signal can be used for the following trouble indications: the items in (1) through (7) and loss of output of battery charger on the load side of the dc overcurrent protective device. 20-2

3 (2) If there is no other way to supervise loss of power, the controller can be equipped with a power failure circuit, which should be time delayed to start the engine upon loss of current output of the battery charger Controller Alarm Contacts for Remote Indication. Controllers shall be equipped with open or closed contacts to operate circuits for the conditions covered in Starting Equipment Arrangement. The requirements for starting equipment arrangement shall be as follows: (4) In the event that the engine does not start after completion of its attempt-to-start cycle, the controller shall stop all further cranking and operate a visible indicator and audible Fire Pump alarm on the controller * Automatic Shutdown After Automatic Start. The requirements for automatic shutdown after automatic start shall be as follows: (2) When the engine overspeed shutdown device operates, the controller shall remove power from the engine running devices, prevent further cranking, energize the overspeed Fire Pump alarm, and lock out until manually reset Air-Starting Engine Controllers Alarm and Signal Indicators Devices on Controller A visible indicator(s) shall be provided to indicate that the controller is in the automatic position The visible indicator shall be accessible for replacement Separate visible indicators and a common audible Fire Pump alarms shall be provided to indicate trouble caused by the following conditions: (1) Critically low oil pressure in the lubrication system. The controller shall provide means for testing the position of the pressure switch contacts without causing trouble Fire Pump alarms. (2) High engine jacket coolant temperature. (3) Failure of engine to start automatically. (4) Shutdown from overspeed Separate visible indicators and a common audible signal shall be provided to indicate trouble caused by the following conditions : (1) Low air pressure. The air supply container shall be provided with a separate visible indicator to indicate low air pressure. (2) Low fuel level. Alarm Signal at two-thirds tank capacity. (5) Schematic electrical drawings of controller, transfer switch, and Fire Pump control alarm panels Substantiation: There was no agreement with regards to the terms alarm and signal. This comment addresses the intent of numerous comments that were made relating to these terms. Committee Meeting Action: Accept Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HAAGENSEN, D.: The term alarm signal is traditionally reserved for a signal that is generated as a result of a fire, and requires that the fire department respond in emergency mode. The term fire pump alarm is confusing and such signals will erroneously be connected to fire alarm panels as an alarm signal. No one participating in the Task Group thought that any fire pump controller signal should be treated as a fire alarm signal. I am worried that firefighters responding to or returning from a fire pump alarm signal could suffer needless casualties. Comment on Affirmative: CASTLES, H.: I had a problem with the substantiation statement specifically no agreement part. My comment is to revise the substantiation statement for Comment 20-1 as follows: Although there was discussion regarding the use of the term signal, agreement was achieved. There were various conflicting positions on the use of the term alarm making consensus difficult. This comment addresses the intent of numerous comments that were made relating to these terms. WENZEL, L.: I understand that the task group did a great deal of work gyrating the intent of the proposal and the resulting comment. I agree that this proposal/comment is a step in the right direction, but feel that more work needs to be done. As a member of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property (NFPA 72), I intend to bring the definition of Alarm to that committee, for clarification within that document, as a foundation for standardization of the term. It will still be confusing to the user of both documents, and I feel that we have moved some of the way to correct the situation, but there has to be better consistency, in my opinion. [NOTE: Renumber following text accordingly for new section above.] No audible alarm signal silencing switch or valve, other than 20-2 Log #11 Final Action: Accept in Principle in Part the controller main switch or valve, shall be permitted for the conditions (2.3.5) reflected alarms in Additional Fire Pump Alarms and signals Where audible alarms signals for the additional conditions listed in A.5.23 are incorporated with the engine Fire Pump alarms specified in , a silencing switch or valve for the additional A.5.23 audible alarms signals shall be provided at the controller The circuit shall be arranged so that the audible alarm signal will be activated if the silencing switch or valve is in the silent position when the supervised conditions are normal Alarms for Remote Indication. Controllers shall be equipped to operate circuits for remote indication of the conditions covered in , , and Starting Equipment Arrangement. The requirements for starting equipment arrangement shall be as follows: (2) In the event that the engine does not start after completion of its attempt-to-start cycle, the controller shall stop all further cranking and operate the audible and visible Fire Pump alarms Simulated Conditions. Both local and remote signals and Fire Pump alarm conditions shall be simulated to demonstrate satisfactory operation * Electronic Fuel Management (ECM). For engines with electronic fuel management (ECM) control systems, a function test of both the primary and alternate ECM shall be conducted. A To verify the operation of the alternate ECM, with the motor stopped, move the ECM selector switch to the alternate ECM position. Repositioning of this should cause an alarm a signal on the fire pump controller. Start the engine; it should operate normally with all functions. Shut engine down, switch back to the primary ECM, and restart the engine briefly to verify that correct switchback has been accomplished. To verify the operation of the redundant sensor, with the engine running, disconnect the wires from the primary sensor. There should be Submitter: John D. Jensen, Fire Protection Consultant Comment on Proposal No: 20-2 Recommendation: Reconsider inclusion of this design reference in the standard by Creating a new Annex D that includes the complete text of the document. A reference should be included in Chapter 9 to Annex A as 9.1.3* and then to the new Annex D which would be the NEMA Publication ICS ` Substantiation: This document is an important design document in sizing and arranging of the electrical system that feeds the fire pump installation and should be included to provide design guidance for the engineers designing the electrical system required by electric motor driven fire pumps in Part Propose a new Section to read as follows: Design * All electrical control equipment design shall comply with NFPA 70, National Electrical Code, Article 695, and other applicable documents. A All electrical control equipment design should also follow the guidelines within NEMA Publication ICS Committee Statement: Meets the intent of the submitter. Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: KHEIR, H.: I think the intent of the submitter is to include the NEMA publication ICS as new Annex D, which I think will be valuable information, especially for international user. Also I think we need to change ICS to ICS , as 2004 is the one existing now. no change in the engine operation. Reconnect the wires to the sensor. Next, disconnect the wires from the redundant sensor. There should be no change in the engine operation. Reconnect the wires to the sensor. Repeat 20-3 Log #8 Final Action: Reject this process for all primary and redundant sensors on the engines. Note: If (Chapter 3 Definitions (GOT)) desired, the disconnecting and reconnecting of wires to the sensors can be done while the engine is not running, then starting the engine after each disconnection and reconnection of the wires to verify engine operation The manual shall contain the following: (1) A detailed explanation of the operation of the component (2) Instructions for routine maintenance (3) Detailed instructions concerning repairs (4) Parts list and parts identification Submitter: Thomas P. Hammerberg, Bruce Fraser, Shane M. Clary, Automatic Fire Alarm Association Comment on Proposal No: 20-3 Recommendation: Accept in Part, Proposal Accept the preferred and secondary definitions for Signal. Substantiation: The Technical Committee appears to have rejected Proposal 20-3 in total, due to their feelings regarding the definition for 20-3

4 Relief Valve. No negative votes or statements were directed towards Committee Statement: Committee feels this is a fire pump issue. Signal. In addition NFPA 20 is applied independently of NFPA 1 in many circumstances. Committee Statement: Task Group Recommendation: Task group does not feel that a secondary definition is required Log #12 Final Action: Reject (Chapter 3) Submitter: John D. Jensen, Fire Protection Consultant Comment on Proposal No: 20-3 Recommendation: Reconsider the definitions and use the secondary definition for relief valves from the NFPA glossary of terms along with the definitions for Alarm and Signal. Substantiation: There has been a need for these terms to be defined in NFPA 20 to eliminate the confusion. While those outside of the day to day fire protection design field may have other preferred definitions this is the fire protection field and the terms should reflect the common language that is used in this field. Committee Statement: Task Group Recommendation: Task group does not feel that a secondary definition is required Log #CC1 Final Action: Accept ( Fault Tolerant External Control Circuit, On-Site Power Production Facility, On-Site Standby Generator) Submitter: Technical Committee on Fire Pumps Comment on Proposal No: 20-3 Recommendation: Revise definitions to coordinate with NFPA as follows: Fault Tolerant External Control Circuit. Those control circuits either entering and/ or leaving the fire pump controller enclosure, which if broken, disconnected, or shorted will not prevent the controller from starting the fire pump from all other internal or external means and may cause the controller to start the pump under these conditions On-Site Power Production Facility. A power production facility that is on site, that is tthe normal supply of electric power for the site, and that is expected to be constantly producing power On-Site Standby Generator. A facility producing electric power generator that is on site and that serves as an the alternate supply of electrical power. It differs from an on-site power production facility in that it is not constantly producing power. Substantiation: Coordinates definitions with Article 695 of the NEC. Committee Meeting Action: Accept 20-6 Log #3 Final Action: Accept (5.7.3) Submitter: Richard Dick Schneider, Joslyn Clark Controls, Inc. Comment on Proposal No: Recommendation: Reference in should be instead of Substantiation: pertains to common drivers for positive displacement pumps pertains to dedicated drivers pertains to maximum pressure for centrifugal pumps. Committee Meeting Action: Accept 20-7 Log #22 Final Action: Reject ( ) Submitter: David Stringfield, University of Minnesota Comment on Proposal No: Recommendation: Delete new text. Substantiation: I would think fire pump room housekeeping is a NFPA 1 issue. Why couldn t a boiler that heats the pump room and tank be acceptable, especially if it is electric? Log #39 Final Action: Accept in Principle ( ) Submitter: James Everitt, Western Regional Fire Code Development Committee Comment on Proposal No: Recommendation: Revise to read: Emergency lighting shall be provided by fixed or portable battery-operated lights, including flashlights. Substantiation: Emergency lights need to be provided. Flashlights or other portable means of illumination may not be present when the power goes out as someone may have taken them or the batteries are dead. See Committee Action and Statement on Proposal Committee Statement: Committee action at ROP meets the intent of this comment Log #36 Final Action: Reject ( ) Submitter: Kenneth E. Isman, National Fire Sprinkler Association Comment on Proposal No: Recommendation: Revise text as follows: Where pipe is installed aboveground, the pipe shall be one of the following: a) Steel b) Listed for fire protection service and installed in accordance with NFPA 24 Chapter 12 Aboveground Pipe and Fittings c) Connections to underground suction and underground discharge pipe shall be permitted. Substantiation: The committee s statement was not completely responsive to the proposal. One of the big problems in pump houses and pump rooms is the transition piece from the underground to the steel. The piece needs to be above the pump room/house floor for the connection to be made, but the lined ductile iron (or other underground material) is then aboveground and many AHJ s want this short piece of pipe to be buried or covered since NFPA 20 requires all aboveground pipe to be steel. NFPA 24 covers the use of aboveground mains with a whole chapter. If this equipment is acceptable to be used for a fire main, why is it not acceptable to be used as suction pipe? Committee Statement: The substantiation submitted is inaccurate. Current wording of already allows for the above ground connection to underground suction and underground discharge piping and reflects the committee s intention Log #1 Final Action: Reject ( ) Submitter: Technical Committee on Standpipes Comment on Proposal No: Recommendation: Revise Section to read: No ppressure regulating devices control valves shall be installed in the discharge pipe except as permitted in this accordance with the appropriate system installation standard. Substantiation: Pressure control valves may be needed in some system configurations. This comment will coordinate the application for pressure control valves between NFPA 14, 20 and 25. Committee Statement: See Committee Action and Statement on (Log #40). Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HAAGENSEN, D.: If other NFPA fire protection system installation standards permit the installation of a master pressure-regulating device, the installation would be made more reliable by permitting the device to be located in the discharge of the fire pump so that the pressure-regulating device can be exercised and tested during routine fire pump testing.

5 Explanation of Negative: Log #40 Final Action: Accept in Principle KHEIR, H.: I need to ask again the committee members to reconsider ( ) moving from APR to Reject, the technical committee of NFPA 20 spent Submitter: Kenneth E. Isman, National Fire Sprinkler Association Comment on Proposal No: Recommendation: Accept proposal Substantiation: No justification has even been given by the committee that substantiates any prohibition against pressure reducing valves. Other fire protection committees are convinced of the reliability and safety of these valves. For the committee to know that they are being used in other positions and then prohibit them in the discharge piping does not make sense. If they are going to be installed, the best location is in the discharge piping so that they will be exercised each time the pump is flow-tested and so that the pump test header can be used to also test the pressure reducing valve. If the valve is installed downstream of the discharge piping, it will need some additional test header to be tested and maintained correctly. This just adds needless cost to the system. During committee discussion, the concern seemed to be over single pressure reducing valves. Our proposal would not have allowed a single pressure reducing valve. It would only have allowed two pressure reducing valves in parallel, which would have increased reliability over the single valve installation. A Task Group of several NFPA committees met recently to discuss the use of pressure reducing valves throughout the NFPA standards. The conclusion of this task group was that pressure reducing valves are reliable and can be used safely on fire protection systems. After this Task Group meeting, the NFPA Standpipe committee met and discussed the use of master pressure reducing valves on standpipe systems to control large zones. This committee concluded that mast pressure reducing devices could be used, but wanted to take care of the situation where failure of the device in an open position might occur. They required two devices to be installed in series to prevent this from becoming a problem. The NFPA 20 committee could do something similar. To continue to prohibit the use of a listed and reliable device without any technical substantiation is a restraint of trade and may become a significant legal problem for the NFPA. Add new text to read: A It is not the intent to restrict the use of pressure reducing valves down stream of the discharge isolation valve for the purpose of meeting the requirements of Section Committee Statement: The reliability of these pressure reducing valves in fire protection application has not been established and design options are available to avoid the use of these valves. If installed as a master pressure reducing valve downstream of the fire pump, the valve represents a single point of failure that could impair the entire system. Committee members have experienced several failures of pilot operated valves. While the current experience can not be analyzed statistically, it does point out the need to establish the reliability of the valves before encouraging their use. It may be theoretically possible to improve reliability by using multiple pressure reducing valves, however, the valves may fail either open or closed. Valves in parallel are required to reduce the possibility of depriving the fire protection system of water in case a valve failed shut. However installing valves in parallel increases the possibility of over pressurizing the system from a valve failing open. Valves in series are required to reduce the possibility of over pressurizing the system if a valve failed open. However installing valves in series increases the possibility of depriving the fire protection system of water in case a valve failed shut. In addition failure of multiple valves cannot be statistically treated as independent events, because the valves are in a similar environment and the most likely causes of failure are environmentally related. Pressure reducing valves also have a limited operating flow range, which results in the need to install smaller valve(s) in parallel with the main pressure reducing valve. Low flow rates in larger valves may result in wide swings in discharge pressure. A manual bypass could be installed to allow bypassing the pressure reducing valve in the event the valve failed closed, however, this is likely to result in over-pressurization. Emergency manual operation of a normally closed bypass in the event the pressure reducing valve failed closed during a fire may be acceptable if it results in a nominal overpressurization, however, a catastrophic failure is likely if it results in a severe over-pressurization. A severe over-pressurization is likely if the situation involves pressure reducing valves for multiple vertical zones supplied from a single pump. If used in a vertical zone application, overpressurization and failure in a low zone could deprive a higher zone of water. Unlike pressure reducing valves used on individual hose valves or floors whose failure still allows use of hose valves from other floors, the failure of a master pressure reducing valve impairs the entire system. Ballot Results: Affirmative: 24 Negative: 2 years, and years rejecting to include this type of valves in the code. This statement was clear. Actually till 1996 edition, NFPA included in the formal interpretation attachment F.I. 83-6A, the technical committee was clear not to accept the pressure regulating valve, also it was clear that the committee against including this in the code section, and rejected 20-10, Log #1. In Log #40, the Substantiation was clear about the problem we feel about this kind of valves, I clearly indicated actual field problems, which many came with more information, and agreement about the operation of the fire pumps, with direct effect on jockey pump, with change of failure during fire case, we not even indicated how to solve the problems will result of this type of valve. To say the Annex is not code, so there is no responsibility for use, but we need to consider that it is still explanatory material from the committee, and in international market it can be bad use, we not speaking here about the legalities, but about risk life, even NFPA 24, still not in full acceptance of pressure regulating valve (please refer to 5.3.1, No pressureregulating valve shall be used in the water supply, except by special permission of the authority having jurisdiction.) In our discussion I indicated distance which I tested in the field many times to reduce the effect of such valve on the operation of fire pumps, this was rejected, without indication or field tests which show the safe distance. I hope the submitter will provide field reports indicating the right distance for fitting the pressure regulating valve, before we even consider putting this statement as Annex material. Members of the technical committee need to understand that international users, consultants, and authorities look for NFPA document with respect, both as a code, and Annex materials. ROY, M.: Recommend that the Committee Reject the Comment. Substantiation: The Fire Pump Technical Committee s position on the reliability of pressure reducing valves is based on prior experience in application of these valves in standby or intermittent service. My experience with these valves is that their reliability is subject to many sitespecific conditions such as water quality, maintenance procedures, valve design, and proper application (arrangement and setting). Further evidence in fire protection applications of master pressure reducing valves suggests that these valves do fail with some frequency when applied in standpipe systems. The results of such application have been multimillion dollar property losses and the loss of life. The One Meridian Plaza fire in Philadelphia and First Interstate Bank Tower fire in Los Angeles are two such cases. These failures are documented in both NFPA and FEMA reports which should be reviewed by the submitter. As a final note on evidence and experience, the submitter of the original proposal provided no experimental evidence of reliability of these valves in this application. In order to make important changes to fire protection codes and standards, the burden of evidence is on the submitter, not on the committee reviewing the proposals to provide otherwise. Regarding the restraint of trade comment, all committee members must consider commercial issues and fair business practices in regulating or restricting the use of products. The restriction or prohibition of pressure reducing valves on standpipe systems is one such example where the committee must decide what the trade offs are between the cost of a fire protection system and the resulting property damage and loss of life. Fire protection is a business, but it is most importantly a duty and obligation to the public. I cannot in good conscience support compromising public safety and the safety of those in the fire services by supporting the committee action to recognize the application of master pressure reducing valves. Comment on Affirmative: HAAGENSEN, D.: It is interesting to note that the Committee voted to Accept in Principal. This would mean that the recommendation of Proposal has been accepted, in addition to the Committee adding the language that appears in the Committee Action of this Comment. If only the text that appears in the Committee Action of this Comment is added, and not that in the recommendation of Proposal 20-39, the Committee would have Rejected this Comment to signal that it entirely disagrees with the intent of the submitter. ISMAN, K.: With respect to Comment 20-11, we agree with the committee s action, but are concerned with the committee statement, which at times is in conflict with the committee action. Ultimately, we believe that if the committee is going to allow pressure reducing devices in the supply pipe to a fire protection system, they should also allow them in the discharge piping of the pump so that they can be tested. The Fire Pump Committee is allowing a device to be installed in a position where it is least likely to be tested and prohibiting the device from being installed in the position where it is most likely to be tested. Since the performance is the same except for the testing implications, we think the committee is actually decreasing the reliability of the pump installation. 20-5

6 Determination of effective pump performance shall be Log #24 Final Action: Accept in Principle documented by engineering calculations and tests. (5.23) Committee Statement: Meets the intent of the submitter. Submitter: David Stringfield, University of Minnesota Comment on Proposal No: Recommendation: Change committee action to accept. Substantiation: I agree that the term alarms is incorrect. By rejecting Proposal , the committee did not answer the proposal. The standard should acknowledge it takes a fire alarm system or remote annunciator to get fire pump issues to a constantly attended location. See Committee Comment 20-1 ( Log #CC3). Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HAAGENSEN, D.: This establishes a double standard within NFPA 20, whereby the fire protection system designer can design for suctions supplying less than the 150 percent rated capacity of the fire pump through the use of an inherently less reliable break tank arrangement. The standard does not currently permit the design of the fire pump suction to consider less than 150 percent pump rated capacity. Committee Statement: See Committee Comment 20-1 ( Log #CC3). Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HAAGENSEN, D.: See my Explanation of Negative on Comment Log #5 Final Action: Accept in Principle ( , , and ) Submitter: Gayle Pennel, Schirmer Engineering Corporation Comment on Proposal No: Recommendation: Modify , , and as follows: Install dual automatic refill lines, each capable of refilling the tank at a minimum rate of 150 percent of the fire pump(s) capacity shall be provided If available supplies do not permit refilling the tank at a minimum rate of 150 percent of the rated pump capacity, each refill lines shall be capable of refilling the tank at a rate that meets or exceeds 110 percent of the maximum fire protection system design flow and pressure requirements A manual tank fill bypass designed for and capable of refilling the tank at a minimum rate of 150 percent of the fire pump(s) capacity shall be provided If available supplies do not permit refilling the tank at a minimum rate of 150 percent of the rated pump capacity, the manual fill bypass shall be capable of refilling the tank at a rate that meets or exceeds 110 percent of the maximum fire protection system design flow and pressure requirements Where a backflow prevention device is installed, the final arrangement shall provide effective pump performance with a minimum suction pressure of 0 bar (0 psi) at the gauge at 150 percent of rated capacity If available suction supplies do not permit the flowing of 150 percent of rated pump capacity, the final arrangement of the backflow prevention device shall provide effective pump performance with a minimum suction pressure of 0 bar (0 psi) at the gauge at the maximum allowable discharge. The discharge shall exceed the fire protection system design flow and pressure requirements Determination of effective pump performance shall be documented by engineering calculations and tests. Substantiation: The changes provide consistency with revised which allows the fire pump to operate at less than 150 percent of rated pump capacity if available suction supplies are adequate for the system demand but cannot supply 150 percent of rated pump capacity. Revise text to read: Install dual automatic refill lines, each capable of refilling the tank at a minimum rate of 150% of the fire pump(s) rated capacity shall be provided If available supplies do not permit refilling the tank at a minimum rate of 150 percent of the rated pump capacity each refill line shall be capable of refilling the tank at a rate that meets or exceeds 110% of the maximum fire protection system design flow A manual tank fill bypass designed for and capable of refilling the tank at a minimum rate of 150% of the fire pump(s) capacity shall be provided If available supplies do not permit refilling the tank at a minimum rate of 150% of the rated pump capacity the manual fill bypass shall be capable of refilling the tank at a rate that meets or exceeds 110 percent of the maximum fire protection system design flow Where a backflow prevention device is installed, the final arrangement shall provide effective pump performance with a minimum suction pressure of 0 bar (0 psi) at the gauge at 150 percent of rated capacity If available suction supplies do not permit the flowing of 150 percent of rated pump capacity, the final arrangement of the backflow prevention device shall provide effective pump performance with a minimum suction pressure of 0 bar (0 psi) at the gauge at the maximum allowable discharge. The discharge shall exceed the fire protection system design flow Log #14 Final Action: Reject (6.3.4, ) Submitter: Frank L. Moore, Moore Pump and Equipment, Inc. Comment on Proposal No: Recommendation: Reinsert entire section as printed in 2003 NFPA 20. Substantiation: Serviceability was a major issue on allowing inline pumps into the 1996 NFPA 20. Inline strainers was the option the committee elected to use. This proposal does not address the lifting required for large inline pumps. Committee Statement: Current experience indicates that accessing the impeller on in-line pumps is less difficult than horizontal split case pumps and can be done without disconnecting the electrical connection. Under these circumstances the concern for preventing small objects from entering the impeller is overridden by the concern over the strainer restricting the water supply to the fire pump. Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: DORINI, A.: I agree that service is a problem on large in-line fire pumps. The committee agreed when this was added to the document. Alternate methods given in committee action are fine but I do not think the primary method of serviceability for these type pumps, the strainer should be taken out. Removing the text from the document no longer allows the use of the strainer. It is important and should remain in the document Log #2 Final Action: Reject (8.4.5) Submitter: James Copeland, Federal Express Corp. Comment on Proposal No: Recommendation: Add new text as follows: Fuel tanks supplied by pumps shall be provided with an overflow line, a high-level alarm, and a high-level automatic shutoff. The overflow line shall be continuous piping, without valves or traps, to the source tank or collection system. The capacity of the overflow line shall exceed the delivery capacity of the supply lines to the fuel tank. Substantiation: The NFPA 20 (1998) code does not incorporate NPFA Committee Statement: The referenced Proposal is on the subject of units of measure. It appears this Comment is not applicable to NFPA 20 or new business Log #34 Final Action: Accept in Principle (9.1) Submitter: James S. Nasby, Master Control Systems, Inc. Comment on Proposal No: Recommendation: Consider adding further power supply requirements to main body or to Appendix (Annex A): Such as: Power Source Capacity. [New clauses (9.1.5 thru )] The power supply shall have adequate capacity to start and run the fire pump on a continuous basis The Power supply shall comply with Section The back-up power supply shall comply with and Where more than one source of power is used to supply normal power, each shall comply with and Where more than one source of power is used to supply back-up power, each shall comply with and Substantiation: Field personnel frequently look for additional guidance regarding suitable fire pump power supplies.

7 Also, Committee draft shows 9.3.2* with an asterisk; but, no appendix Add new sections as follows: (annex) material is shown. This material may be suitable for same All power supplies shall have the capacity to run the fire pump on a continuous basis. See Committee Action and Statement on (Log #27), (Log All power supplies shall comply with the voltage drop #28), (Log #29), and (Log #30). requirements of Section 9.4. Committee Statement: Clarifies intent of submitter. Committee Statement: Meets the intent of the submitter Log #35 Final Action: Accept in Principle (9.1) Submitter: James S. Nasby, Master Control Systems, Inc. Comment on Proposal No: Recommendation: Consider adding submitter s (Dana Haagensen) power quality material from proposed clauses thru 9.4 as main body or to Appendix (Annex A). Reword (should vs- shall) and renumber clauses as needed. A re-write as appendix material as follows: A Other Sources. Except for an arrangement described in or 9.3.4, at least one back-up source of power may be required when one or more of the following conditions of the normal source of power exists: (1) The source power plant has experienced any shut downs of longer than 4 continuous hours in the year prior to plan submittal. Note that NFPA 25 begins to require special undertakings (i.e. fire watches) when a water-based fire protection system is taken out of service for longer than 4 hours. If the normal source power plant has been intentionally shut down for longer than 4 hours in the past, it is reasonable to require a back-up source of power. (2) Power outages have been experienced in the area of the protected facility caused by failures in the power grid that were not due to natural disasters or electric grid management failure. Note that this standard does not require that the normal source of power is infallible. NFPA 20 does not intend to require a back-up source of power for every installation using an electric motor driven fire pump. Should the normal source of power fail due to a natural disaster (hurricane) or due to a problem with electric grid management (regional blackout), the fire protection system could be supplied through the fire department connection. However, if the power grid is known to have had problems in the past (i.e. switch failures or animals shorting a substation), it is reasonable to require a back-up source of power. (3) The normal source of power is supplied on-site by overhead conductors outside the protected facility. More and more often, fire departments responding to an incident at the protected facility will not operate aerial apparatus near live overhead power lines, without exception. A back-up source of power is required in case this scenario occurs and the normal source of power must be shut off. Additionally, many utility providers will remove power to the protected facility by physically cutting the overhead conductors. If the normal source of power is provided by overhead conductors, which will not be identified, the utility provider could mistakenly cut the overhead conductor supplying the fire pump. (4) Disconnect switches or overcurrent protection devices are installed in the normal source of power that do not comply with 9.2. Power disconnection and activated overcurrent protection should only occur in the fire pump controller. The provisions of for the disconnect switch and overcurrent protection essentially require disconnection and overcurrent protection to occur in the fire pump controller. If unanticipated disconnect switches or overcurrent protection devices are installed in the normal source of power that do not meet the requirements of 9.2.2, the normal source of power must be considered not reliable and a back-up source of power is necessary. (5) Other conditions that would make the normal source of power be considered not reliable. A (A) A back-up source of power may not be required where a back-up engine driven or back-up steam turbine driven fire pump is installed in accordance with NFPA 20. A (B) A back-up source of power may not be required when acceptable to the authority having jurisdiction. Note that this standard recognizes that prescriptive standards cannot address every possible situation. Thus, the authority having jurisdiction may accept a normal source of power as reliable based on a project specific situation even though the normal source of power does not comply the regular requirements of Section 9.2. A When provided, the back-up source of power shall not be supplied through overhead conductors outside the protected facility. A For fire pump installations using the power supply arrangement of (Old Campus Style Feeder Sources), and having more than one disconnecting means supplied by a single feeder, the overcurrent protection device(s) in each disconnecting means shall be selectively coordinated with any other supply side overcurrent protective device(s) to avoid unnecessary loss of power to other emergency loads. Substantiation: Field personnel frequently look for additional guidance regarding suitable fire pump power supplies Log #38 Final Action: Accept in Principle (9.2.1) Submitter: Jon Nisja, Northcentral Regional Fire Code Development Committee Comment on Proposal No: Recommendation: Add a new section to read: x Phase converters shall not be permitted to be used for fire pump service. Substantiation: Based on the committee statement to the proposal and the negative comment of Mr. Haagensen we have submitted a comment to include the prohibition of the converters to clarify the issue. See Committee Action and Statement on (Log #37). Committee Statement: See Committee Action and Statement on (Log #37) Log #23 Final Action: Reject ( ) Submitter: David Stringfield, University of Minnesota Comment on Proposal No: Recommendation: Modify committee action from reject to accept and delete section. Substantiation: I disagree the fire pump standard can require backup power. Requirements for this belong in the codes (NFPA 101, NFPA 5000, IBC, etc.). not in the standard. The standard should tell how, when a code requires it. Committee Statement: Power supplies are within the scope of NFPA 20 (ref ) Log #31 Final Action: Accept in Principle (9.2.2(3)) Submitter: Dana R. Haagensen, Massachusetts Office of the Fire Marshal Comment on Proposal No: Recommendation: Delete item (3) of 9.2.2: (3) A dedicated feeder connection derived from the service to the fire pump installation. Substantiation: The insertion of this new allowable normal power supply arrangement conflicts with the committee action and first sentence of the committee statement of Proposal If the service also feeds the building power, it is possible to unintentionally disconnect the normal fire pump power. Insert dedicated before service. Committee Statement: Added to Proposal ROP Committee Action 9.2.2(3) Log #28 Final Action: Accept in Principle (9.3) Submitter: Dana R. Haagensen, Massachusetts Office of the Fire Marshal Comment on Proposal No: Recommendation: Add a new subsection to Section 9.3 to read: 9.3.X When provided, the alternate source of power shall not be supplied through overhead conductors outside the protected facility. Substantiation: This important consideration should be made a requirement of the standard. A problem of supplying power to the pump could occur when fire department operations call for removing power from nearby overhead lines, and the alternate source is in use because the unreliable normally supply is also cut-off.

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