Public Input No. 79-NFPA [ Section No. 1.1 ] Additional Proposed Changes. Statement of Problem and Substantiation for Public Input

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

2 of 80 7/22/2015 2:42 PM Public Input No. 41-NFPA [ Section No ] Membrane Hangar. The flexible structural fabric or film that supports the imposed loads and transmits them to the supporting structure. The membrane carries only tension or shear in the plane of the membrane. Definition is for "membrane", not "membrane hangar". Submitter Full Name: LIANE OZMUN Organization: FRANKFURT-SHORT-BRUZA Submittal Date: Tue Jul 02 18:32:05 EDT 2013 Resolution: FR-12-NFPA Statement: The definition has been modified to better represent the term.

3 of 80 7/22/2015 2:42 PM Public Input No. 78-NFPA [ New Section after ] Foam Concentrate. For the purpose of determining the concentrate percentage, the definition of Foam Concentrate shall be also mean any substitutes for actual foam producing liquids, such as substituting AFFF with plain or colored water. Additional Proposed Changes File Name nfpapublicinputform_-_kaare_holm_nofoam_systems_section_ pdf Description Approved Cover Sheet NFPA 412 recently adopted the concept of input based testing as an optional alternative to output based testing (such as the refractometer test for determining the concentrate percentage produced by the proportioner). The proposed new definition above would effectively allow the AHJ the same privilege under this revised NFPA 409. Input based testing simply defines that you can determine the concentrate percentage from the proportioner by measuring the flowrates of both water and foam concentrate being put into the proportioner, and this concentrate proportion will by natural logic be the same as the foam/water solution coming out of the proportioner (which is what is currently being sampled and then analyzed with a refractometer to determine the concentrate percentage). As is well known and accepted, the proportioner does not need to be adjusted when changing from one type of foam concentrate to another, because it will mix any foam concentrate liquid to the same percentage. Likewise, it will mix plain or colored water to the same proportion as well. Therefore, it is possible to test the proportioner by replacing foam concentrate with plain or colored water. Testing with colored water instead of AFFF for that purpose will eliminate significant clean-up cost and associated environmental issues, and in doing so it would be more acceptable for the AHJ to test more frequently. This approach is already demonstrated by the Navy, and accepted broadly by the DoD, and new installations (foam systems in hangers) are in construction with requirements of being able to test with colored water instead of with AFFF concentrate. The basic principle being used is to simultaneously measure the water-pipe s and the concentrate-pipe s flow-rates with external flow meters, before they enter the proportioner, and used math to calculate the concentrate percentage. It would be in the interest of this standard to allow the AHJ to perform parts of the testing with water, while still being in full compliance with the NFPA 409. The proposed change is simply an added tool/approach, which does not take away from anyone who wishes to test as has been done in the past. The proposed change also does not modify the requirement to test with actual foam for any other purpose, as required in the standard, other than for testing the proportioner s performance. Submitter Full Name: KAARE HOLM Organization: NOFOAM SYSTEMS, EGE Submittal Date: Fri Jul 12 08:22:02 EDT 2013 Resolution: The appropriate definition of "foam concentrate" is found in NFPA 11.

4 of 80 7/22/2015 2:42 PM Public Input No. 88-NFPA [ New Section after ] 3.3.x Foam Generators. Foam generators mix air with foam solution to deliver expanded foam to a fire or risk area. Low-expansion generators deliver expanded foam with an expansion ratios approximately 4 to 10:1. High-expansion generators deliver expanded foam with an expansion ratios approximately 500 to 1200:1. High expansion generators can be fan-driven or use air-induction to introduce air to the foam solution. Outside-air high-expansion generators use air from outside the fire compartment. Inside-air high-expansion generators use air from inside the fire compartment. Additional Proposed Changes File Name NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Description Approved Cover Sheet Definition of the foam generator types is suggested as helpful. Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound. Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types. Note: Supporting material is available for review at NFPA Headquarters. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:29:18 EDT 2013 Resolution: The appropriate definitions for these terms are found in NFPA 11.

5 of 80 7/22/2015 2:42 PM Public Input No. 80-NFPA [ New Section after ] Fixed water or foam-water systems shall be permitted to be used in lieu of the passive fire resistance separations detailed in 5.2.1, 5.2.2, & provided they are automatically operated, installed on both sides of the wall, and designed in accordance with 5.6, and other NFPA standards as appropriate. Additional Proposed Changes File Name NFPA_409_5.2_Internal_Separations.docx Description Approved Cover Sheet NFPA 409 has long allowed active fire separation, in its requirement to protect steel columns without passive fire rated covering by spraying water on them. This proposal is an extension of that principle. It is intended that this would allow the installation of sprinklers in low rise offices, workshops, etc. adjoining hangars as a substitute for fire rated walls, doors and shutters. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 08:57:41 EDT 2013 Resolution: Section 5.6 applies to columns, but is not appropriate for walls. References to "other NFPA standards" is not specific enough.

6 of 80 7/22/2015 2:42 PM Public Input No. 42-NFPA [ Section No ] * Landing gear pits, ducts, and tunnels tunnels which are located below floor level shall be designed on the premise that flammable liquids and vapor will be present at all times. Materials, unless they do not connect to the hangar floor or the classified area above the floor. Materials and equipment shall be impervious to liquids and shall be fire resistant or noncombustible. This paragraph before modification appears to apply to open landing pits and ducts and tunnels which connect to the hangar floor or classified area. As written, it also could apply to a tunnel below the hangar floor that does not have openings into the hangar or hangar floor, but only sealed piping or conduit which enters the hangar from the tunnel. It could also apply to a duct which passes below the hangar slab, but does not communicate with the hangar floor. The modification limits the classified area to the landing gear pits, ducts and tunnels which communicate with the hangar classified areas. Submitter Full Name: LIANE OZMUN Organization: FRANKFURT-SHORT-BRUZA Submittal Date: Tue Jul 02 18:37:47 EDT 2013 Resolution: There is concern that the areas in and around a hangar will be contaminated with hydrocarbon liquids and vapors over time. These contaminates could create a classified atmosphere in tunnels that are located under the hangar, although the tunnels are not directly connected to the hangar floor. Tunnels outside the scope of 409 are not included in the requirements of

7 of 80 7/22/2015 2:42 PM Public Input No. 81-NFPA [ Section No ] * Floor trench drainage systems shall be provided to restrict the spread of fuel in order to reduce the fire and explosion hazards from fuel spillage, and prevent fire spread to aircraft down-slope from a burning fuel spill. Additional Proposed Changes File Name NFPA_409_5.11.2_Hangar_Floor_Trench_Drainage.docx Description Approved Cover Sheet The need for these changes is self evident. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 08:59:24 EDT 2013 Resolution: Provided substantiation is inadequate.

8 of 80 7/22/2015 2:42 PM Public Input No. 49-NFPA [ Section No ] * Trench drainage systems in aircraft storage or servicing areas shall be designed and constructed so that they have a capacity large enough to prevent buildup of flammable liquids and water over the drain inlet when all fire protection systems and 125 percent of the sum of all closed head automatic sprinkler systems, hose streams allowances and hand hose streams are discharging at the design rate. The discharge of low level foam systems, foam-water deluge sprinklers systems, and supplementary foam systems are excluded from the required drainage capacity. This section is a remnant unchanged over the years from older editions of the standard when plain water deluge systems were permitted and the concept was to flush fuel off the floor. Since foam agents blanket and secure spilled fuel, this requirement offers little benefit while imposing a high cost burden. This drainage makes little sense in high expansion foam applications when much of the liquid is bound up in bubbles. 125% is intended to provide a reasonable safety factor in removing plain water from the sprinkler system which will tend to flow beneath the foam. Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:04:41 EDT 2013 Resolution: The proposal does not address the true water flow that could be expected.

9 of 80 7/22/2015 2:42 PM Public Input No. 82-NFPA [ Section No ] Oil separators and flame traps shall be provided for the trench drainage systems serving all aircraft storage and servicing areas. These separators shall be permitted to serve each hangar trench drainage system or a group of hangar trench drainage systems or be installed as part of a general airport trench drainage system. Additional Proposed Changes File Name NFPA_409_5.11.2_Hangar_Floor_Trench_Drainage.docx Description Approved Cover Sheet The need for these changes is self evident. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:01:04 EDT 2013 Resolution: "Flame trap" is not a recognized term. The substantiation was inadequate to explain the submitter's intent.

10 0 of 80 7/22/2015 2:42 PM Public Input No. 30-NFPA [ Section No ] In aircraft storage and servicing areas, no heating, ventilating, and air-conditioning equipment employing an open flame or glowing element shall be installed, other than as provided for in Open flame shall mean burners that utilize combustion air from within the aircraft storage and servicing area. Equipment with sealed burners and ducted combustion air shall be permitted to be installed within the aircraft the aircraft storage and servicing area. Use of term "open flame" needs clarification. The HVAC industry defines this as a visible flame or a flame that pulls air from within the space the the equipment is installed. Submitter Full Name: STEPHEN TAMANKO Organization: Bascon Inc. Submittal Date: Tue Mar 05 13:07:21 EST 2013 Resolution: The current wording would not necessarily prohibit the use of sealed burners and ducted combustion air that do not comply with The definition of an open flame device should be interpreted in accordance with standard HVAC industry practices.

11 1 of 80 7/22/2015 2:42 PM Public Input No. 31-NFPA [ Section No [Excluding any Sub-Sections] ] In aircraft storage and servicing areas, heating, ventilating, and air-conditioning systems employing recirculation of air within aircraft storage and servicing areas with open flame or glowing element shall have return air openings not less than 3 m (10 ft) above the floor and in addition must be in accordance with Supply air openings shall not be installed in the floor and shall be at least 152 mm (6 in.) from the floor measured to the bottom of the opening. The way this is written, no air rotation type heaters can be utilized including but not limited to hot water coil type. Submitter Full Name: STEPHEN TAMANKO Organization: Bascon, Inc. Submittal Date: Tue Mar 05 14:05:22 EST 2013 Resolution: The requirement is concerned with more than just ignition sources. One additional concern is the redistribution of flammable vapors that might be at the floor level to other areas within the hangar.

12 2 of 80 7/22/2015 2:42 PM Public Input No. 24-NFPA [ Section No ] * Aircraft storage and servicing areas, shall be provided with grounding facilities for removal and control of static electrical accumulations on aircraft while aircraft are stored or undergoing servicing in a hangar shall be permitted in accordance with and Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment. Submitter Full Name: Donald Cook Organization: Shelby County Department of De Submittal Date: Thu Feb 28 15:46:30 EST 2013 Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply with NFPA 410 or other standards for aircraft maintenance operations. Whether and how the grounding facilities are used is not within the scope of NFPA 409.

13 3 of 80 7/22/2015 2:42 PM Public Input No. 28-NFPA [ Section No ] Floor-grounding receptacles shall be provided permitted and where installed shall be either grounded through individual driven electrodes or electrically bonded together in a grid system and the entire system grounded to underground metal piping, such as cold water piping, or driven electrodes. Where driven electrodes are used, they shall consist of 15.9 mm ( 5?8 in.) diameter or larger metal rods driven at least 1.5 m (5 ft) into the ground. Floor-grounding receptacles shall be designed to minimize the tripping hazard. Aircraft owners have objected to enforcement of this provision of NFPA 409 and indicate grounding of their aircraft is potentially harmful to aircraft electronics. This revision allows the designer to work with aircraft owner and appropriately protect their investment. Submitter Full Name: Donald Cook Organization: Shelby County Department of De Submittal Date: Thu Feb 28 16:22:32 EST 2013 Resolution: The provision of grounding facilities is necessary in order to provide the capability to comply with NFPA 410 or other standards for aircraft maintenance operations. Whether and how the grounding facilities are used is not within the scope of NFPA 409.

14 4 of 80 7/22/2015 2:42 PM Public Input No. 83-NFPA [ Section No ] Draft curtains shall be required in Group I hangars where heat actuated fire detection devices are located below the roof. Additional Proposed Changes File Name NFPA_409_5.17_Draft_Curtains.docx Description Approved Cover Sheet Draft curtains are designed to collect and concentrate hot air and fire gasses to increase the speed at which thermal devices respond. When other types of fire detection are used draft curtains do not assist fire protection, and are not economically justified. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:02:57 EDT 2013 Resolution: The requirement for draft curtains to be installed in all Group I hangars is based on testing that showed that the draft curtains substantially improved the response of the closed-head sprinkler system.

15 5 of 80 7/22/2015 2:42 PM Public Input No. 51-NFPA [ New Section after ] new Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11, except that foam system piping shall not be required to be galvanized. NFPA 11 (2010 edition) states "Galvanized pipe shall be used." While this requirement maybe useful for tanks farms it is inappropriate for foam systems inside hangars. Galvanized piping is generally incompatible with the foams. It contributes nothing to system corrosion resistance and may be harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentially releasing flakes of zinc which may clog orifices. FM Global and others are eliminating requirements for galvanized piping. Related Public Comments for This Document Related Comment Public Input No. 52-NFPA [New Section after 7.1] Public Input No. 53-NFPA [Section No ] Public Input No. 54-NFPA [Section No ] Public Input No. 55-NFPA [Section No ] Relationship Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:23:04 EDT 2013 Resolution: FR-13-NFPA Statement: NFPA 11 (2010 edition) states "Galvanized pipe shall be used." While this requirement may be useful for tank farms, it is inappropriate for foam systems inside hangars. Galvanized piping is generally incompatible with the foams. It contributes nothing to system corrosion resistance and may be harmful when the zinc coating deteriorates causing galvanic cell corrosion and potentially releasing flakes of zinc which may clog orifices.

16 6 of 80 7/22/2015 2:42 PM Public Input No. 47-NFPA [ Section No ] The protection of aircraft storage and servicing areas for Group I aircraft hangars shall be in accordance with any one of the following: (1) A foam-water deluge system, as specified in In addition, supplementary protection systems as specified in shall be provided in hangars housing single aircraft having wing areas greater than 279 m 2 (3000 ft 2 ). (2) A combination of automatic sprinkler protection in accordance with and an automatic low-level low-expansion foam system in accordance with (3) A combination of automatic sprinkler protection in accordance with and an automatic low-level high-expansion foam system in accordance with (4) A combination of automatic sprinkler protection in accordance with and a fuel containment floor system in accordance with 6.2.X The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection. Submitter Full Name: TRISTAN MACKINTOSH Organization: Fireless Flooring Submittal Date: Fri Jul 05 11:33:36 EDT 2013 Resolution: The fuel containment floor system technology has not been fully tested.

17 7 of 80 7/22/2015 2:42 PM Public Input No. 56-NFPA [ Section No ] In aircraft storage and servicing areas, the protection area as projected on the floor shall be limited to 12 m 2 (130 ft 2 ). The maximum distance between sprinklers either on branch lines or between branch lines shall be 3.7 m (12 ft). In buildings with storage bays 7.6 m (25 ft) wide, a distance of 3.8 m (12 ft 6 in.) shall be permitted. Allow NFPA 13 to set parameters for spacing along and between branchlines. Note this section is also referenced by also and (3)(c). Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:41:23 EDT 2013 Resolution: The existing requirements were justified during the previous revision cycle (see Proposal 18 and Comment 5). There is inadequate justification to revise this section as suggested at this time.

18 8 of 80 7/22/2015 2:42 PM Public Input No. 54-NFPA [ Section No ] Each supplementary protection system shall be designed, installed, and maintained in accordance with NFPA 11. Delete as redundant with proposed new to apply to all foam systems: "Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11, except that foam system piping shall not be required to be galvanized." See PI 51. Related Public Comments for This Document Related Comment Public Input No. 51-NFPA [New Section after 6.1.1] Relationship Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:32:14 EDT 2013 Resolution: FR-14-NFPA Statement: Delete as redundant with new (FR 13) to apply to all foam systems.

19 ] Public Input No. 84-NFPA [ Sections , , , , Sections , , , , Supplementary high - expansion foam systems shall utilize surfactants as the foaming ingredient and shall be designed for local application. comply with * These systems shall be designed to discharge at a rate to cover the protected area to a depth of at least 0.9 m (3 ft) within 1 minute Discharge rates shall take into consideration the sprinkler breakdown factor required in (2) of NFPA 11. except that they shall be designed for local or portable application including all parts of the hangar floor beneath an aircraft s wings when parked in the hangar. This shall allow additional foam as necessary to maintain the application density over all alternative wing locations The foam generators shall be located at the ceiling or on exterior walls in such a way that only air from outside the aircraft storage and servicing area can be used for foam generation. Roof vents shall be located to avoid recirculation of combustion products into the air inlets of the foam generators * Generators shall be powered by reliable water-driven or electric motors. Electric power reliability for generators shall be in accordance with electric fire pump requirements of NFPA 20 2 Supplementary high expansion foam system generators may be fixed or portable as necessary to facilitate aircraft movement and types, and shall be supported by work procedures to ensure they are used when aircraft with wing areas above 279 m 2 are parked in the hangar. Additional Proposed Changes File Name NFPA_409_ _ _Rationalisation.docx Description Approved Cover Sheet and largely repeat each other and this proposed arrangement reduces this duplication Guidance of high-expansion foam local delivery The term low level is not defined and following the inference that outside-air high-expansion generators should be mounted in hangar walls, not practicable for Group I hangars which have with only two or three exterior walls. Due to the slow horizontal spread of Hi-Ex the use of wall mounted generators should be discouraged changed to be used defining all types of Hi-Ex generation changed to be consistent with the requirement to follow NFPA 11 calculation methodology Expanded to allow zoning of large systems Changed to better describe the requirements of general area coverage and supplementary systems & 6 Changed to allow inside-air generators Minimum quality statement for inside-air generators Inside-air generators offer several advantages over fan driven and outside-air types, the main advantages being :- They have no moving parts thus require less maintenance 9 of 80 7/22/2015 2:42 PM

20 0 of 80 7/22/2015 2:42 PM They are light weight reducing hangar roof loads They are better able to withstand fire conditions before use. They cost less than fan driven generators and deliver a more fluid foam blanket which improves the horizontal spread velocity, offering quicker fire suppression. They offer significant economies in water and foam consumption and discharges into the environment Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:04:57 EDT 2013 Resolution: The proposed text would radically change the intent of the low-level foam system without adequate justification. Adequate technical data has not been provided to support the use of inside air. The foam application rate does not need to match NFPA 11. Low-level foam systems ( ) do not have the same performance criteria as supplementary foam systems ( ), as these protection options are used in different protection schemes. The committee has formed a task group to study the issue of zoning of the low-level foam systems. Portable foam generators would not meet the minimum reliability and suppression time that is required for aircraft hangars. Inadequate substantiation was provided to remove the requirement to use surfactants.

21 1 of 80 7/22/2015 2:42 PM Public Input No. 74-NFPA [ Section No ] Discharge rates shall take into consideration the sprinkler breakdown factor required in (2) of NFPA 11 using the total actual discharge from the number of sprinklers expected to operate in L/min (gpm). Additional Proposed Changes File Name nfpa409_pi_kasiski_ pdf Description Approved Cover Sheet The revised wording provides clarity on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection. Submitter Full Name: Robert Kasiski Organization: FM Global Submittal Date: Thu Jul 11 13:28:18 EDT 2013 Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

22 Public Input No. 89-NFPA [ Sections , ] Sections , The Outside-air foam generators shall be located at the ceiling or on exterior walls in such a way that only air from outside the aircraft storage and servicing area can be used for foam generation. Roof vents shall be located to avoid recirculation of combustion products into the air inlets of the foam generators * Generators Outside-air generators shall be powered by reliable water-driven or electric motors. Electric power reliability for generators shall be in accordance with electric fire pump requirements of NFPA Inside-air generators shall be listed and shall be oriented and located in accordance with the manufacturer's approvals in respect to air inlet clearance and direction of discharge. Additional Proposed Changes File Name NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Description Approved Cover Sheet Definition of the foam generator types is suggested as helpful. Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound. Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types. Note: Supporting material is available for review at NFPA Headquarters. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:31:26 EDT 2013 Resolution: Adequate technical data has not been provided to support the use of inside air. 2 of 80 7/22/2015 2:42 PM

23 3 of 80 7/22/2015 2:42 PM Public Input No. 4-NFPA [ Section No ] * Foam Generators shall be powered by reliable water-driven or electric motors. Electric power reliability for generators foam generators shall be in accordance with electric fire pump requirements of NFPA 20. Clarifies that the section is specifically addressing foam generators. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Thu Aug 16 11:27:16 EDT 2012 Resolution: FR-17-NFPA Statement: Clarifies that the section is specifically addressing foam generators.

24 4 of 80 7/22/2015 2:42 PM Public Input No. 35-NFPA [ Section No ] The design Regardless of the ceiling slope, the design density of water from sprinkler systems shall be a minimum of 6.9 L/min/m 2 (0.17 gpm/ft 2 ) over any 1394 m 2 (15,000 ft 2 ) area, including the hydraulically most demanding area as defined in NFPA 13. There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies. Other occupancies need to clarify whether their density/area criteria applies to sloped roof/ceilings. It is our understanding that the criteria in NFPA 409 was developed to be used regardless of the shape or slope of the roof/ceiling. The hanger rules have been sufficiently used to protect barrel shaped roofs that have a slope much greater than 2 in 12. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area. NFPA 409 needs to definitively state that the 30% increase does not apply. We have chosen to do this by inserting the phase, "regardless of the ceiling slope", which should clarify the situation sufficiently. Submitter Full Name: Kenneth Isman Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Submittal Date: Sat Jun 29 13:11:06 EDT 2013 Resolution: FR-15-NFPA Statement: There is a great deal of confusion regarding the rules of NFPA 13 and the 30% increase to the design area for buildings with a ceiling/roof slope of more than 2 in 12. As far as NFPA 13 is concerned, this 30% increase only applies to light, ordinary and extra hazard situations (it is in Chapter 11, which only applies to those hazard classifications). But many people try to apply it to other occupancies. The safety factors involved in the criteria in NFPA 409 allow the discharge criteria in this document to adequately protect sloped roof/ceilings without the 30% increase in the design area. The committee also clarified that the increase for preaction systems also does not apply to NFPA 409.

25 5 of 80 7/22/2015 2:42 PM Public Input No. 55-NFPA [ Section No ] Each low-level foam protection system shall be designed, installed, and maintained in accordance with NFPA 11. Delete as redundant with proposed new to apply to all foam systems: "Each foam protection system shall be designed, installed, and maintained in accordance with NFPA 11, except that foam system piping shall not be required to be galvanized." See PI 51. Related Public Comments for This Document Related Comment Public Input No. 51-NFPA [New Section after 6.1.1] Relationship Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:38:54 EDT 2013 Resolution: FR-39-NFPA Statement: Delete as redundant with new (FR 13) to apply to all foam systems.

26 Public Input No. 85-NFPA [ Section No ] Low-Level High-Expansion Foam Systems Low High - level high- expansion foam systems shall be designed and installed in accordance with requirements for local application systems of NFPA The minimum application rate shall be a minimum of 0.9 m 3 /min/m 2 (3 ft 3 /min/ft 2 ) determined for a flammable liquids hazard using the calculation method of NFPA 11, Section The discharge rate of the system shall be based on the application rate multiplied by the entire aircraft storage and servicing zone floor area. The application total discharge rate shall include the sprinkler breakdown factor specified in (2) of NFPA 11. rate, unless there are no sprinklers or low expansion deluge nozzles above. Zones shall be the larger of 2500 m 2 (27,000 ft 2 ), or the area assigned to a single aircraft. The design shall allow for the worst case number of wall openings to have foam spilling out to form a wedge outside. Openings shall include hangar doors, workshop hatches, boundaries between zones, etc. unless there is a wall or barrier able to contain the foam. The foam angle of repose used for these calculations shall be determined by testing and confirmed during commissioning The high-expansion foam generators shall be arranged to achieve initial foam coverage in the expected aircraft parking potential fuel spill area Foam Outside-air foam generators shall be supplied with air from outside the aircraft storage and servicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inlets of the foam generators * Foam Outside-air generators shall be powered by reliable water-driven or electric motors. Electric power reliability for foam generators shall be consistent in accordance with electric fire pump requirements specified in Chapters 6 and 7 of NFPA Inside-air generators shall be listed and shall be oriented and located in accordance with the manufacturer s approvals in respect to air inlet clearance and direction of discharge. Additional Proposed Changes File Name NFPA_409_ _ _Rationalisation.docx Description Approved Cover Sheet and largely repeat each other and this proposed arrangement reduces this duplication Guidance of high-expansion foam local delivery The term low level is not defined and following the inference that outside-air high-expansion generators should be mounted in hangar walls, not practicable for Group I hangars which have with only two or three exterior walls. Due to the slow horizontal spread of Hi-Ex the use of wall mounted generators should be discouraged changed to be used defining all types of Hi-Ex generation changed to be consistent with the requirement to follow NFPA 11 calculation methodology Expanded to allow zoning of large systems Changed to better describe the requirements of general area coverage and supplementary systems & 6 Changed to allow inside-air generators Minimum quality statement for inside-air generators Inside-air generators offer several advantages over fan driven and outside-air types, the main advantages being :- They have no moving parts thus require less maintenance 6 of 80 7/22/2015 2:42 PM

27 7 of 80 7/22/2015 2:42 PM They are light weight reducing hangar roof loads They are better able to withstand fire conditions before use. They cost less than fan driven generators and deliver a more fluid foam blanket which improves the horizontal spread velocity, offering quicker fire suppression. They offer significant economies in water and foam consumption and discharges into the environment Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:07:13 EDT 2013 Resolution: The proposed text would radically change the intent of the low-level foam system without adequate justification. Adequate technical data has not been provided to support the use of inside air. The foam application rate does not need to match NFPA 11. Low-level foam systems ( ) do not have the same performance criteria as supplementary foam systems ( ), as these protection options are used in different protection schemes. The committee has formed a task group to study the issue of zoning of the low-level foam systems. Portable foam generators would not meet the minimum reliability and suppression time that is required for aircraft hangars. Inadequate substantiation was provided to remove the requirement to use surfactants.

28 8 of 80 7/22/2015 2:42 PM Public Input No. 75-NFPA [ Section No ] The discharge rate of the system shall be based on the application rate multiplied by the entire aircraft storage and servicing floor area. The application total discharge rate shall include the sprinkler breakdown factor specified in (2) of NFPA 11 using the total actual discharge from the number of sprinklers expected to operate in L/min (gpm). Additional Proposed Changes File Name nfpa409_pi_kasiski_ pdf Description Approved Cover Sheet The revised wording provides clartiy on how to properly design a high expansion foam system compensating for breakdown of the foam blanket by using the actual discharge from the sprinkler system. If the design discharge from a sprinkler is used the total rate of discharge from the generator may be incorrect and impact the performance of providing adequate fire protection. Submitter Full Name: Robert Kasiski Organization: FM Global Submittal Date: Thu Jul 11 13:31:14 EDT 2013 Resolution: There are sufficient safety factors in the existing design criteria to address this concern.

29 9 of 80 7/22/2015 2:42 PM Public Input No. 60-NFPA [ Section No ] Foam generators shall be supplied with air from outside the or inside the aircraft storage and servicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inlets of the foam generators. area in accordance with the provisions of 6.9 of NFPA 11. In past NFPA 409 TC meetings inside air test data was presented by Ansul which demonstrated compliance with NFPA and for high expansion foam produced with inside air. At the time the TC rejected the proposal to allow inside air with some members citing life safety concerns. However there is no compelling reason to believe that life safety is more at risk in an aircraft hangar than in a flammable liquids warehouse with aisles of rack storage. Therefore it is recommended that the TC accept this proposal which will allow HEF systems to be implemented more reliably by eliminating roof penetrations and dampers. Related Public Comments for This Document Related Comment Public Input No. 61-NFPA [Section No ] Public Input No. 62-NFPA [Section No ] Relationship Submitter Full Name: Michael Aaron Organization: The RJA Group, Inc. Submittal Date: Sun Jul 07 17:59:25 EDT 2013 Resolution: Adequate technical data has not been provided to support the use of inside air.

30 Public Input No. 90-NFPA [ Sections , ] Sections , Foam Outside-air foam generators shall be supplied with air from outside the aircraft storage and servicing area. Roof vents shall be located to avoid recirculation of combustion products into the air inlets of the foam generators * Foam Outside-air generators shall be powered by reliable water-driven or electric motors. Electric power reliability for foam generators shall be consistent with electric fire pump requirements specified in Chapters 6 and 7 of NFPA Inside-air generators shall be listed and shall be oriented and located in accordance with the manufacturer s approvals in respect to air inlet clearance and direction of discharge, Additional Proposed Changes File Name NFPA_409_Inside_or_Outside_Air_Foam_Generators.docx Description Approved Cover Sheet Definition of the foam generator types is suggested as helpful. Inside air foam generators may fan driven or air inducing type. Given the normally large size and high ceilings of aircraft hangars, the use of flame detectors and the requirements of NFPA 409 and NFPA 11 for rapid fire suppression, it is most likely that there will be no significant smoke or toxic products of combustion captured by the Hi-Ex generators during a discharge in a hangar. It is not prohibited by either NFPA 409 or NFPA 11 to stop the foam discharge automatically when the fire is suppressed, in fact it is advisable to do so because when the foam concentrate runs out a continuing discharge of water will collapse the Hi-Ex blanket formed during the foam discharge. This has the added benefit of stopping the blanket building to above head height, which is likely to place evacuees in danger, not from toxic gasses in the foam but from disorientation and diminished sight and sound. Tests such as the VROM test (copy of test report attached) on the Skum HG-25 illustrate air-induction types of generator, which owe much of their fire resistance and operability to the fact they use no moving parts. Their simplicity offers economy and design flexibility not possible with fan-driven types. Note: Supporting material is available for review at NFPA Headquarters. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L Submittal Date: Fri Jul 12 09:36:12 EDT 2013 Resolution: Adequate technical data has not been provided to support the use of inside air. 0 of 80 7/22/2015 2:42 PM

31 Public Input No. 86-NFPA [ Section No ] * Foam Concentrate Supply. The friction losses in piping carrying foam concentrate shall be calculated using the Darcy formula, also known as the Fanning formula * The quantities of low-expansion foam concentrate, either protein foam, fluoroprotein, or AFFF, shall be large enough for a 10-minute foam discharge based on the supply calculation in and NFPA * The quantity of high-expansion foam concentrate shall be large enough for a minute discharge at the water flow rate based on the supply calculation method required in of NFPA A reserve supply of foam concentrate of compatible type for the system shall be directly connected to the system and immediately available. The reserve supply shall be in the same quantity as the main supply. To prevent accidental depletion of this reserve supply, it shall be available to the system only by intentional manual operation Control valves, foam concentrate liquid storage tanks, concentrate pumps, controllers, and bypass balancing equipment shall be located outside the aircraft storage and service area Where possible all foam systems within a hangar should use the same foam type, in terms of foam concentrate compatibility and expansion ratio. Differing types shall only be permitted where the combination is endorsed by the foam manufacturer(s) To prevent unnecessary sprinkler breakdown, low-expansion foam shall not be applied above high-expansion foam unless the low-expansion foam is released under control of heat detectors and the high-expansion foam by flame detectors. Additional Proposed Changes File Name NFPA_409_6.2.6_Foam_Concentrate_Supply.docx Description Approved Cover Sheet Protein foam is no longer manufactured, and Lo-Ex foam types do not include FFFP, this level of detail does not seem necessary NFPA 409 requires compliance with NFPA 11, which requires 2x 15 minute supplies. The calculation method in is only part of the necessary calculation, and NFPA 11 offers a better calculation method Since the formulation of high-expansion foam concentrate is significantly different to all other types of foam, it is unlikely that any manufacturer would endorse Lo-Ex and Hi-Ex in combination It is necessary for Group I hangars (6.1.1 (1)) for aircraft with wing areas over 279 m2 to allow AFFF deluge with Hi-Ex supplementary protection. Given that flame detectors are used to initiate the supplementary Hi-Ex protection, if the heat detectors at roof level operate it can be assumed the Hi-Ex system has failed, one or more aircraft within the hangar will be severely damaged, and the high level system will provide protection to the hangar roof structure. Note: Supporting material is available for review at NFPA Headquarters. Submitter Full Name: RICHARD GILLESPIE Organization: FIRE ENGR SOLUTIONS P/L 1 of 80 7/22/2015 2:42 PM

32 2 of 80 7/22/2015 2:42 PM Submittal Date: Fri Jul 12 09:11:32 EDT 2013 Resolution: Fluoroprotein is still available. There is inadequate substantiation to increase the supply duration. See FR 55 ( ) regarding changes to the requirements for a reserve foam supply. The standard does not necessitate the use of low-expansion foam below high-expansion foam in a single hangar.

33 3 of 80 7/22/2015 2:42 PM Public Input No. 45-NFPA [ New Section after ] 6.2.X Fuel Containment Floor System. 6.2.X.1 Hangars protected in accordance with 6.1.1(4) shall be protected with a fuel containment floor system. 6.2.X.2 The fuel containment floor system shall be designed to achieve (1) containment of aviation fuel spilled out of aircrafts within the storage and service area and prevent the fuel from being (re)ignited. (2) Suppression of burning aviation fuel spilled out of aircrafts within the storage and service area. 6.2.X.3 System floor size 6.2.X.3.1 In aircraft storage and servicing areas where the aircraft parking area is fixed, a fuel containment floor system shall be installed directly underneath the aircraft s fuel tanks in accordance with 6.2.X X.3.2 The fuel containment floor system shall cover the floor from the perimeter of the aircraft s fuel tanks and all area within. 6.2.X The fuel containment floor system shall consist of a single continuous floor per each aircraft. 6.2.X.3.2 In aircraft storage and servicing areas where the aircraft parking area is flexible, a fuel containment floor system shall cover the entire area where an aircraft can potential be parked in accordance with 6.2.X X.3.3 The edge of the fuel containment floor system should be a minimum of 6m. (18 ft.) in horizontal distance from the perimeter of the fuel tanks. 6.2.X.4 Activated water sprinklers as per shall not affect the performance of the fuel containment floor system. The drainage capacity of the system shall include the maximum amount of water deployed by the overhead sprinkler system. 6.2.X.5 Fuel removal 6.2.X.5.1 The system shall have an integrated flush capability to flush out contained fuel. The flush system shall be discharged into the trench drain system in accordance with X.5.2 In case of existing aircraft storage and service areas where (1) the trench drain layout is not practically located in relation to the fuel containment floor system, (2) or the concrete floor slab does not have sufficient pitch, a suction system may be installed to remove liquids from the system into the nearest trench drain or directly to a safe outside location in accordance with The Fuel Containment Floor System can be an alternative to the current accepted foam based fire suppression systems, that for certain hangars can be a better suited solution in terms of fire protection. Submitter Full Name: TRISTAN MACKINTOSH Organization: Fireless Flooring Submittal Date: Fri Jul 05 11:23:31 EDT 2013