Public Comment No. 16-NFPA 13D-2014 [ Section No ]

of 52 9/22/2014 9:20 AM Public Comment No. 16-NFPA 13D-2014 [ Section No. 2.3.3 ] 2.3.3 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM A 53 A53/A53M, Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless, 2010 2012. ASTM A 135 A135/A135M, Standard Specification for Electric-Resistance-Welded Steel Pipe, 2009 (2014). ASTM A 234 A234/A234M, Standard Specification for Piping Fittings of Wrought Carbon Steel and Alloy Steel for Moderate and High Temperature Service, 2010 2013 e1. ASTM A 795 A795/A795M, Standard Specification for Black and Hot-Dipped Zinc-Coated (Galvanized) Welded and Seamless Steel Pipe for Fire Protection Use, 2008 2013. ASTM B 32 B32, Standard Specification for Solder Metal, 2008. ASTM B 43 B43, Standard Specification for Seamless Red Brass Pipe, 2009. ASTM B 75 B75/B75M, Standard Specification for Seamless Copper Tube, 2002 2011. ASTM B 88 B88, Standard Specification for Seamless Copper Water Tube, 2009. ASTM B 251 B251, Standard Specification for General Requirements for Wrought Seamless Copper and Copper-Alloy Tube, 2010. ASTM B 813 B813, Standard Specification for Liquid and Paste Fluxes for Soldering Applications of Copper and Copper-Alloy Tube, 2010. ASTM B 828 B828, Standard Practice for Making Capillary Joints by Soldering of Copper and Copper Alloy Tube and Fittings, 2002 (2010). ASTM F 437 F437, Standard Specification for Threaded Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 80, 2009. ASTM F 438 F438, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 40, 2009. ASTM F 439 F439, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 80, 2009 2013. ASTM F 442 F442/F442M, Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe (SDR-PR), 2009 2013 e1. ASTM F 876 F876, Standard Specification for Crosslinked Polyethylene (PEX) Tubing, 2011 2013a. Statement of Problem and Substantiation for Public Comment standards date updates Related Item First Revision No. 1-NFPA 13D-2013 [Section No. 8.3.3] Submitter Information Verification Submitter Full Name: Marcelo Hirschler Organization: GBH International Street Address: City: State: Zip: Submittal Date: Sun Apr 27 17:34:28 EDT 2014

of 52 9/22/2014 9:20 AM Committee Statement Committee Action: Rejected but see related SR Resolution: SR-1-NFPA 13D-2014 Statement: standards date updates

of 52 9/22/2014 9:20 AM Public Comment No. 29-NFPA 13D-2014 [ Section No. 2.3.3 ] 2.3.3 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM A 53/A 53M, Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless, 2010 2012. ASTM A 135/A 135M, Standard Specification for Electric-Resistance-Welded Steel Pipe, 2009. ASTM A 234/A234M, Standard Specification for Piping Fittings of Wrought Carbon Steel and Alloy Steel for Moderate and High Temperature Service, 2010 2013e1. ASTM A 795/A 795M, Standard Specification for Black and Hot-Dipped Zinc-Coated (Galvanized) Welded and Seamless Steel Pipe for Fire Protection Use, 2008. ASTM B 32, Standard Specification for Solder Metal, 2008 2013. ASTM B 43, Standard Specification for Seamless Red Brass Pipe, 2009. ASTM B 75, Standard Specification for Seamless Copper Tube, 2002 2011. ASTM B 88, Standard Specification for Seamless Copper Water Tube, 2009. ASTM B 251, Standard Specification for General Requirements for Wrought Seamless Copper and Copper-Alloy Tube, 2010. ASTM B 813, Standard Specification for Liquid and Paste Fluxes for Soldering Applications of Copper and Copper-Alloy Tube, 2010. ASTM B 828, Standard Practice for Making Capillary Joints by Soldering of Copper and Copper Alloy Tube and Fittings, 2002 02(2010). ASTM F 437, Standard Specification for Threaded Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 80, 2009. ASTM F 438, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 40, 2009. ASTM F 439, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 80, 2009 2013. ASTM F 442, Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe (SDR-PR), 2009 2013e1. ASTM F 876, Standard Specification for Crosslinked Polyethylene (PEX) Tubing, 2011 2013a. Statement of Problem and Substantiation for Public Comment Update year dates for standards Related Item First Revision No. 1-NFPA 13D-2013 [Section No. 8.3.3] Submitter Information Verification Submitter Full Name: Steve Mawn Organization: ASTM International Street Address: City: State: Zip: Submittal Date: Thu May 15 14:58:00 EDT 2014 Committee Statement

of 52 9/22/2014 9:20 AM Committee Action: Rejected but see related SR Resolution: SR-1-NFPA 13D-2014 Statement: standards date updates

of 52 9/22/2014 9:20 AM Public Comment No. 5-NFPA 13D-2014 [ Section No. 3.3.11.8 ] 3.3.11.8 Sprinkler System. For fire protection purposes, A system that consists of an integrated system network of underground and overhead piping designed in accordance with fire protection engineering standards. The installation includes one or more automatic water supplies that includes a water supply source, a water control valve, a waterflow alarm, and a drain and is commonly activated by heat from a fire, discharging water over the fire area. The portion of the sprinkler system aboveground above ground is a network of specially specifically sized or hydraulically designed piping installed in a building, structure, or area, generally overhead, and to which sprinklers are attached in a systematic pattern. The system is usually commonly activated by heat from a fire and discharges water over the fire area. [ 13 3.3.22] New A.3.3.11.8 A waterflow alarm, although included in this definition, is not a required system component within this standard. Statement of Problem and Substantiation for Public Comment This change would permit consistancy with NFPA13. The additional anex material serves to clarify that the waterflow switch is not a required system component. Related Item Public Input No. 6-NFPA 13D-2012 [Section No. 3.3.11.8] Submitter Information Verification Submitter Full Name: Mark Fessenden Organization: Tyco Fire Protection Products Street Address: City: State: Zip: Submittal Date: Tue Mar 11 12:10:38 EDT 2014 Committee Statement Committee Action: Resolution: Rejected The definition should not be extracted from NFPA 13 since waterflow alarms are not required in NFPA 13D systems. An idenpendent definition of sprinkler system is needed for this standard.

of 52 9/22/2014 9:20 AM Public Comment No. 9-NFPA 13D-2014 [ Section No. 4.5 ]

of 52 9/22/2014 9:20 AM 4.5 * Documentation.

of 52 9/22/2014 9:20 AM Documentation shall be available upon request to ensure adequate water supply, listed devices, and adequate sprinkler coverage have been addressed. 4.5 * Documentation. Documentation shall be available upon request to ensure adequate water supply, listed devices, and adequate sprinkler coverage have been addressed. Working Plans. Working plans shall be drawn to an indicated scale, on sheets of uniform size, with a plan of each floor, and shall show those items from the following list that pertain to the design of the system: (1) Name of owner. (2) Location, including street address. (3) Point of compass. (4) Full height cross section. (5) Ceiling/roof heights and slopes not shown in the full height cross section. (6) Location of partitions, lintels, and doorways. Lintel openings require a cross section view to indicate the area of the opening. (7) Name and label for each area or room. (8) For systems supplied by city mains, location and size of city main in street, and location, size, and type of domestic line, including length to city connection, and water meter location and size. Static and residual hydrants that were used in flow tests shall be shown. The location of the 5 gpm domestic demand shall be indicated. (9) Make, type, model, temperature rating, nominal K-factor, and number of each type of sprinkler, including sprinkler identification number. (10) Pipe type and schedule of wall thickness. (11) Nominal pipe size and cutting lengths of pipe (or center-to-center dimensions). Where typical branch lines prevail, it shall be necessary to size only one typical line. (12) Location and size of riser nipples and drops. (13) Type of fittings and joints. (14) Type and locations of hangers, and methods of securing sprinklers when applicable. (15) Location and size of all valves and drain pipes. (16) Location and size of water gauges. (17) Where the equipment is to be installed as an addition to an existing system, enough of the existing system indicated on the plans to make all conditions clear. (18) A summary of the hydraulics, including the static pressure, residual pressure, and flow of the water supply, the pressure and flow demands at the point of connection to the water supply, and the pressure and flow demands at the bottom of the system riser. (19) Hydraulic reference points shown on the plan that correspond with comparable reference points on the hydraulic calculation sheets. (20) Relative elevations of sprinklers, junction points, and supply or reference points. (21) A graphic representation of the scale used on all plans. (22) Name, address, phone number of the contractor. (23) Where required by the AHJ, documentation of the designer credentials. (24) Indicate by note the minimum rate of water application per sprinkler head, the maximum spacing for each head, and the domestic demand. (25) Information about antifreeze solution used. Indicate the type of antifreeze used, the amount of antifreeze in the system, and information about antifreeze compatibility with the pipe. (26) General notes as required by the AHJ. (27) Edition year of NFPA 13D to which the sprinkler system is designed. (28) Utility plans and/or plumbing plans necessary to show connection from water supply to fire sprinkler system.

of 52 9/22/2014 9:20 AM Statement of Problem and Substantiation for Public Comment The TC states that the material in A.4.5 adequately covers the materials necessary for documentation. We agree with the TC that the information in A.4.5 is truly necessary documentation for a review of a 13D submittal. Being necessary information, it should not be contained in the annex but should be contained in the core text. This requirement is specifically stated in the Manual of Style section 2.3.4.1 The annexes of codes and standards shall be used for advisory text, explanatory material, and supplementary information and shall not be used for mandatory requirements. If the requirements of A.4.5 are truly necessary, and we agree with the TC that they are, then the text clearly has to be mandatory in order for a necessary requirement to be provided by the designer and reviewed by the AHJ. In addition, if necessary information is not provided as part of an initial permit submittal for an AHJ to review the sprinkler design for compliance with NFPA 13D, the TC is basically mandating that the AHJ is going to reject the first submittal of each 13D system because the necessary information for a review has not been submitted. This creates additional time delays and additional costs which is directly counter to the TC s concern that of avoiding unnecessary costs. Related Item Public Input No. 32-NFPA 13D-2013 [Section No. 4.5] Submitter Information Verification Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Street Address: City: State: Zip: Submittal Date: Thu Apr 17 12:59:31 EDT 2014 Committee Statement Committee Action: Resolution: Rejected Items 5, 7, 8, 11, 14, 18 and 19 in this public comment all require documentation of items that are not required by the standard. The items that are included in this comment that are required in the standard should be included on a project by project basis as determined by the AHJ. Requiring working plans for NFPA 13D systems will drive up the cost of the systems and could impact the use and adoption of the standard.

0 of 52 9/22/2014 9:20 AM Public Comment No. 26-NFPA 13D-2014 [ Section No. 5.1.1.1 ] 5.1.1.1 * Where a sprinkler is removed from a fitting or welded outlet, it shall not be reinstalled except as permitted by 5.1.1.1.1. 5.1.1.1.1 * Dry sprinklers shall be permitted to be reinstalled, where they are not removed by applying torque at the point where the sprinkler is attached to the barrel. its listing. Statement of Problem and Substantiation for Public Comment Regarding the change proposed by FR #2, NFPA's Building Code Development Committee believes consideration should at least be given when the sprinkler manufacturer has specified a removal method as is explained in Thomas Deegan s negative vote comments. This makes the provision more succinct. Note that this is related to our Public Comment relocating the Annex material in A5.1.1.1.1 to A5.1.1.1. Related Public Comments for This Document Related Comment Public Comment No. 27-NFPA 13D-2014 [Section No. A.5.1.1.1.1] Public Comment No. 27-NFPA 13D-2014 [Section No. A.5.1.1.1.1] Related Item First Revision No. 2-NFPA 13D-2013 [New Section after 5.1.1] Relationship Submitter Information Verification Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County, Washington Affilliation: NFPA's Building Code Development Committee (BCDC) Street Address: City: State: Zip: Submittal Date: Thu May 15 12:26:56 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-2-NFPA 13D-2014 Statement: The first draft language eliminates the possibility of removing dry sprinklers with a head wrench even if the manufacturer recommends it. At least one manufacturer recommends installing and removing their dry sprinklers with a head wrench. The wording has been modified to allow the use of a head wrench if the manufacturer recommends it.

1 of 52 9/22/2014 9:20 AM Public Comment No. 10-NFPA 13D-2014 [ Section No. 5.1.2.1 ] 5.1.2.1 Tanks, expansion tanks, gauges, pumps, hangers, waterflow detection devices, and valves shall not be required to be listed. Statement of Problem and Substantiation for Public Comment Gauges are not always required but when they are utilized, should not be required to be listed. Related Item First Revision No. 3-NFPA 13D-2013 [Section No. 5.1.2] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Thu Apr 17 13:12:50 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-4-NFPA 13D-2014 Statement: Gauges are not always required but when they are utilized, should not be required to be listed.

2 of 52 9/22/2014 9:20 AM Public Comment No. 7-NFPA 13D-2014 [ New Section after 5.2.3.1 ] 5.2.3.1.1 When pipe differing from those specified in Table 5.2.2 is to be used, it shall be installed behind a thermal barrier of not less than 1/2 inch gypsum board unless specifically listed to be installed without protection. Statement of Problem and Substantiation for Public Comment Don t feel that the committee statement is completely true. Fire officials need to have this additional guidance available in the Standard in order to make it more available than merely being noted in the pipe s listing and manufacturers installation instructions. Related Item Public Input No. 24-NFPA 13D-2013 [Section No. 5.2.3 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Street Address: City: State: Zip: Submittal Date: Mon Apr 07 11:56:22 EDT 2014 Committee Statement Committee Action: Resolution: Rejected The use of specially listed piping materials is permitted by this standard. These products are intended to be installed in accordance with their listing. Any special installation and/or piping protection requirements unique to the product listing should be obtained from the manufacturer's installation instructions and technical manuals and are not intended to be specifically addressed within this standard.

3 of 52 9/22/2014 9:20 AM Public Comment No. 8-NFPA 13D-2014 [ New Section after 5.3 ] 5.3* Underground Pipe. 5.3.1 Type. Any type of pipe or tube acceptable under the applicable plumbing code for underground supply pipe shall be acceptable as an underground supply for a fire sprinkler system when installed between the point of connection and the system riser. 5.3.2 Depth of Cover. 5.3.2.1 Except where specified otherwise by the applicable plumbing code, the top of the pipe shall be buried not less than 1 ft (0.3 m) below the frost line for the locality. In those locations where frost is not a factor, the depth of cover shall be not less than 2½ ft (0.8 m) to prevent mechanical damage. 5.3.2.2 The depth of cover over water pipes shall be determined by the maximum depth of frost penetration in the locality where the pipe is laid. The depth of cover shall be measured from the top of the pipe to finished grade, and due consideration shall always be given to future or final grade and nature of soil. 5.3.3 Protection Against Damage. Unless specified otherwise by the applicable plumbing code, the pipe shall be protected from mechanical and physical damage. Statement of Problem and Substantiation for Public Comment The text comes from NFPA 24. There are many areas in the country that do not have a plumbing code and the text would provide guidance to them. Alos do to the recent harsh winters additional quidance needs to be provided to them. Not all jurisdictions employ a plumbing code. Some adopted plumbing codes don t address these concerns or does not address fire service mains. The proposal addresses the minimum guidelines when not otherwise addressed by the local plumbing code and recognizes a hierarchy that establishes that the local plumbing code takes precedence. Related Item Public Input No. 29-NFPA 13D-2013 [Section No. 5.3] Submitter Information Verification Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Street Address: City: State: Zip: Submittal Date: Mon Apr 07 12:01:02 EDT 2014 Committee Statement Committee Action: Resolution: Rejected The submitter provided no additional technical substantiation for the depth of cover values as they pertain to residential homes. As indicated in the first draft report these requirements would make NFPA 13D more restrictive than NFPA 13R and add significant cost to the system. The submitter is encouraged to provide technical data substantiating these values and submit a PI in the next cycle.

4 of 52 9/22/2014 9:20 AM Public Comment No. 28-NFPA 13D-2014 [ Section No. 5.3 ] 5.3 * Underground Pipe. Any type of pipe or Pipe or tube acceptable under the applicable plumbing code for underground supply pipe shall be acceptable as an underground supply for a fire sprinkler system when installed between the point of connection and the system riser. Statement of Problem and Substantiation for Public Comment NFPA's Building Code Development Committee (BCDC) agrees with the submitter of Public Input #18 that this is editorial. The Technical Committees reason for not developing a First Revision does not make sense. Related Item Public Input No. 18-NFPA 13D-2013 [Section No. 5.3] Submitter Information Verification Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County, Washington Affilliation: NFPA's Building Code Development Committee (BCDC) Street Address: City: State: Zip: Submittal Date: Thu May 15 12:56:34 EDT 2014 Committee Statement Committee Action: Rejected Resolution: The word "any" is helpful to AHJs who are trying to enforce this section.

5 of 52 9/22/2014 9:20 AM Public Comment No. 32-NFPA 13D-2014 [ New Section after 8.2.5.6 ] 8.2.5.7 Small areas created by architectural features such as planter box windows, bay windows, and similar features shall be evaluated as follows: (1) Where no additional floor area is created by the architectural feature, no additional sprinkler protection is required. (2) Where additional floor area is created by an architectural feature, no additional sprinkler protection is required, provided all of the following conditions are met: (a) (b) (c) (d) The floor area shall not exceed 18 ft 2 (1.7 m 2 ). The floor area shall not be greater than 2 ft (0.61 m) in depth at the deepest point of the architectural feature to the plane of the primary wall where measured along the finished floor. The floor shall not be greater than 9 ft (2.7 m) in length where measured along the plane of the primary wall. Measurement from the deepest point of the architectural feature to the sprinkler shall not exceed the maximum listed spacing of the sprinkler. (3) The hydraulic design is not required to consider the area created by the architectural feature. Statement of Problem and Substantiation for Public Comment This language has long been in the annex of NFPA 13D and it is clear that it is the committee's belief that additional floor area created by certain architectural features are not required to have additional sprinkler coverage. As this language is in the annex and not in the enforceable body of the standard, this intent is not consistently applied to such architectural features. Moving this language to the body of the standard would make this longstanding intent of the committee enforceable and clear that additional sprinkler protection is not required in these small areas. As these areas are not required to be included in the hydraulic design area of the systems, these areas are distinct from shadow areas. This language has been included in the body of NFPA 13R and it is not the intent that the requirements of NFPA 13D be more stringent in regards to this issue. Related Public Comments for This Document Related Comment Public Comment No. 31-NFPA 13D-2014 [Section No. A.8.2.5] Related Item First Revision No. 15-NFPA 13D-2013 [Section No. A.8.2.5] Relationship Submitter Information Verification Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Street Address: City: State: Zip: Submittal Date: Fri May 16 15:10:09 EDT 2014 Committee Statement

6 of 52 9/22/2014 9:20 AM Committee Rejected but see related SR Action: Resolution: SR-6-NFPA 13D-2014 Statement: This language has long been in the annex of NFPA 13D and it is clear that additional floor area created by certain architectural features are not required to have additional sprinkler coverage. As this language is in the annex and not in the enforceable body of the standard, this intent is not consistently applied to such architectural features. Moving this language to the body of the standard will make it clear that additional sprinkler protection is not required in these small areas. As these areas are not required to be included in the hydraulic design area of the systems, these areas are distinct from shadow areas

7 of 52 9/22/2014 9:20 AM Public Comment No. 25-NFPA 13D-2014 [ New Section after 8.2.7 ] 8.2.7.1 In closets and compartments enclosed by walls and a door, including those housing mechanical equipment, that are smaller than 400 ft3 (11.3 m3), pendent, upright and sidewall residential sprinklers shall be permitted to be installed within 18 inches of the ceiling to avoid obstructions near the ceiling. Additional Proposed Changes File Name Description Approved Computer_Modeling_of_Closet.pdf Computer modeling of closet with residential sprinklers Statement of Problem and Substantiation for Public Comment Small closets, especially those housing mechanical equipment, frequently contain obstructions that make it difficult to place sprinklers within 12 inches of the ceiling. Allowing residential sprinklers to be located further down would allow adequate sprinkler protection of these small closets while avoiding ceiling level obstructions such as ducts and pipes. Based upon CFAST Computer Fire Model, an analysis was performed comparing the performance of sprinklers located 6 inches down from a ceiling in a small room to the performance of sprinklers 18 inches down from the ceiling in an even smaller closet. Based upon this analysis it appears that residential sprinklers 18 inches down from the ceiling in a closet up to 400 ft3 react to a fire at least as quickly as residential sprinklers 6 inches down from a ceiling in a small room. Using equivalency concepts, residential sprinklers could be allowed to be installed within 18 inches of the ceiling in small closets. This analysis is included in this public comment. Related Item First Correlating Revision No. 1-NFPA 13D-2013 [Section No. 8.2.7] Submitter Information Verification Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Street Address: City: State: Zip: Submittal Date: Wed May 14 09:50:28 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-5-NFPA 13D-2014 Statement: Small closets, especially those housing mechanical equipment, frequently contain obstructions that make it difficult to place sprinklers within 12 inches of the ceiling. Allowing residential sprinklers to be located further down would allow adequate sprinkler protection of these small closets while avoiding ceiling level obstructions such as ducts and pipes. Based upon CFAST Computer Fire Model, an analysis was performed comparing the performance of sprinklers located 6 inches down from a ceiling in a small room to the performance of sprinklers 18 inches down from the ceiling in an even smaller closet. Based upon this analysis it appears that residential sprinklers 18 inches down from the ceiling in a closet up to 400 ft3 react to a fire at least as quickly as residential sprinklers 6 inches down from a ceiling in a small room. Using equivalency concepts, residential sprinklers could be allowed to be installed within 18 inches of the ceiling in small closets.

Computer Modeling of Closet with Residential Sprinkler 18 Inches from Ceiling This analysis uses the CFAST Computer Fire Model to compare the performance of sprinklers 6 inches down from the ceiling in a small room to the performance of sprinklers 18 inches down from the ceiling in an even smaller closet. Baseline Room: 15 ft x 15 ft x 8 ft 3 sprinkler locations (see Figure 1) o Sprinkler 1 4 ft from south and west walls o Sprinkler 2 Centered between east and west walls, 4 ft from south wall o Sprinkler 3 4 inches from south and east walls All sprinklers 6 inches from ceiling All sprinklers RTI = 50 (metric units) Closet: 7 ft x 7 ft x 8 ft (392 ft 3 ) 3 sprinkler locations (see Figure 2) o Sprinkler 1 2 ft from south and west walls o Sprinkler 2 Centered between east and west walls, 2 ft from south wall o Sprinkler 3 4 inches from south and east walls All sprinklers 18 inches down from ceiling All sprinklers RTI = 50 (metric units) Fire: Fairly slow growing fire Center of the room/closet See Figure 3 1 2 3 1 2 3 Figure 1 Baseline Room Figure 2 Closet 392 ft 3

Figure 3 Heat Release Rate for Fire (Note that the first 600 seconds are the only important parts of the heat release due to sprinkler activation time) Results The following table compares the activation time of the sprinklers in the small room to that of the sprinklers in the even smaller closet: Sprinkler Activation Time in Small Room (Figure 1) Activation Time in Closet (Figure 2) 1 510 seconds 500 seconds 2 530 seconds 500 seconds 3 510 seconds 500 seconds Conclusions Given this fire location and these three sprinkler locations, it would appear that residential sprinklers 18 inches down from the ceiling in a closet up to 400 ft 3 react to a fire at least as quickly as residential sprinklers 6 inches down from a ceiling in a small room. Using equivalency concepts, residential sprinklers could be allowed to be installed within 18 inches of the ceiling in small closets. Prior to making any final determination, other combinations of fire size, fire location, and sprinkler location should be analyzed in the same manner.

Public Comment No. 11-NFPA 13D-2014 [ Section No. 8.2.7 ] 8.2.7 Closets. In all closets and compartments, including those housing mechanical equipment, that are smaller than 400 ft 3 (11.3 m 3 ), a single sprinkler at the highest ceiling space ceiling level shall be sufficient without regard to obstructions or minimum distances to wall. Statement of Problem and Substantiation for Public Comment This change correlates with the language in NFPA 13R. Related Item First Revision No. 26-NFPA 13D-2013 [Section No. 8.2.5.1] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Thu Apr 17 13:41:16 EDT 2014 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-5-NFPA 13D-2014 Statement: Small closets, especially those housing mechanical equipment, frequently contain obstructions that make it difficult to place sprinklers within 12 inches of the ceiling. Allowing residential sprinklers to be located further down would allow adequate sprinkler protection of these small closets while avoiding ceiling level obstructions such as ducts and pipes. Based upon CFAST Computer Fire Model, an analysis was performed comparing the performance of sprinklers located 6 inches down from a ceiling in a small room to the performance of sprinklers 18 inches down from the ceiling in an even smaller closet. Based upon this analysis it appears that residential sprinklers 18 inches down from the ceiling in a closet up to 400 ft3 react to a fire at least as quickly as residential sprinklers 6 inches down from a ceiling in a small room. Using equivalency concepts, residential sprinklers could be allowed to be installed within 18 inches of the ceiling in small closets. 8 of 52 9/22/2014 9:20 AM

9 of 52 9/22/2014 9:20 AM Public Comment No. 12-NFPA 13D-2014 [ Section No. 8.3.3 ] 8.3.3 Sprinklers shall not be required in clothes closets, linen closets, and pantries that meet all of the following conditions: (1) The area of the space does not exceed 24 ft 2 (2.2 m 2 ). (2) The walls and ceilings are surfaced with noncombustible or limited-combustible materials as defined in NFPA 220. Statement of Problem and Substantiation for Public Comment Editorial. Delete the (3) Related Item First Revision No. 1-NFPA 13D-2013 [Section No. 8.3.3] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Thu Apr 17 13:44:24 EDT 2014 Committee Statement Committee Action: Accepted Resolution: SR-8-NFPA 13D-2014 Statement: Editorial. Delete the (3)

0 of 52 9/22/2014 9:20 AM Public Comment No. 23-NFPA 13D-2014 [ Section No. 10.4.3 ]

1 of 52 9/22/2014 9:20 AM 10.4.3 *

2 of 52 9/22/2014 9:20 AM Unless the pipe size is in accordance with the prescriptive pipe sizing method of 10.4.9, pipe shall be sized by hydraulic calculations in accordance with the methods described in NFPA 13, with the manufacturer's listed installation instructions, with 10.4.4, or with the following general method for straight-run systems connected to a city water main of at least 4 in. (102 mm) in diameter: The system flow rate shall be established in accordance with Sections 10.1 and 10.2, and it shall be determined that the flow allowed by the water meter meets or exceeds the system demand and that the total demand flow does not exceed the maximum flow allowed by the piping system components. The water pressure in the street shall be determined. Pipe sizes shall be selected. * Pressure loss for a water meter, if any, shall be determined and deducted The pipes shall be sized using one of the following techniques : Table 10.4.3(a) shall be permitted to be used, even where the sprinkler demand flow exceeds the meter's rated continuous flow. Higher pressure losses specified by the manufacturer shall be used in place of those specified in Table 10.4.3(a). Lower pressure losses shall be permitted to be used where supporting data are provided by the meter manufacturer. Pressure loss for elevation shall be deducted as follows: (1) Building height above street (ft) 0.433 = pressure loss (psi) (2) Building height above street (m) 0.098 = pressure loss (bar) * Pressure losses from the city main to the inside control valve shall be deducted by multiplying the pressure loss associated with the pipe material by the total length(s) of pipe in feet (meters). Pressure loss for piping within the building shall be deducted by multiplying the pressure loss associated with the pipe material by the total length(s) of pipe in feet (meters). Pressure loss for valves and fittings shall be deducted as follows: (1) The valves and fittings from the control valve to the farthest sprinkler shall be counted. (2) The equivalent length for each valve and fitting as shown in Table 10.4.3(b), Table 10.4.3(c), or Table 10.4.3(d) or Table 10.4.3(e) shall be determined and the values added to obtain the total equivalent length for each pipe size. (3) The equivalent length for each size shall be multiplied by the pressure loss associated with the pipe material and the values totaled. In multilevel buildings, the steps in 10.4.3 (1) through 10.4.3 (8) shall be repeated to size piping for each floor. If the remaining pressure is less than the operating pressure established by the testing laboratory for the sprinkler being used, the sprinkler system shall be redesigned. If the remaining pressure is higher than required, smaller piping shall be permitted to be used where justified by calculations. The remaining piping shall be sized the same as the piping up to and including the farthest sprinkler unless smaller pipe sizes are justified by calculations. Table 10.4.3(a) Pressure Losses in psi in Water Meters Meter Size (in.) Flow (gpm) 18 or less 23 26 31 39 52 5 8 9 14 18 26 38 * 3 4 7 11 14 22 35 * 1 2 3 3 4 6 10 1 1 2 1 1 2 2 4 7 2 1 1 1 1 2 3 For SI units, 1 gpm = 3.785 L/min; 1 in. = 25.4 mm; 1 psi = 0.0689 bar. *Above maximum rated flow of commonly available meters. Table 10.4.3(b) Equivalent Length in Feet of Fittings and Valves for Schedule 40 Steel Pipe Diameter

3 of 52 9/22/2014 9:20 AM (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 1 1 2 2 5 2 0 12 28 15 4 5 1 1 4 1 3 2 6 2 0 15 35 18 5 7 1 1 2 2 4 2 8 3 0 18 43 22 6 9 2 2 5 3 10 3 1 24 57 28 7 11 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.3(c) Equivalent Length in Feet of Fittings and Valves for Type K Copper Tube Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 3 4 0 1 0 3 1 0 7 14 7 2 0 1 1 2 2 6 2 0 14 33 18 5 6 1 1 4 1 3 2 5 2 0 14 32 16 5 6 1 1 2 2 4 2 8 3 0 18 43 22 6 9 2 2 6 3 12 4 1 28 66 33 8 13 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.3(d) Equivalent Length in Feet of Fittings and Valves for Type L Copper Tube Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 3 4 0 2 0 4 1 0 8 18 10 3 0 1 1 3 3 7 2 0 16 38 20 5 7 1 1 4 1 3 2 6 2 0 15 35 18 5 7 1 1 2 2 4 2 9 3 0 20 47 24 7 10 2 2 6 4 12 4 1 30 71 35 9 14 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.3(e) Equivalent Length in Feet of Fittings and Valves for Type M Copper Tube Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 3 4 0 2 0 4 1 0 10 21 11 3 0 1 2 3 3 8 3 0 19 43 23 6 8 1 1 4 1 3 2 7 2 0 16 38 20 5 8 1 1 2 2 5 2 9 3 0 21 50 26 7 11 2 3 7 4 13 5 1 32 75 37 9 14 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. (1) The simplified calculation method of 10.4.4, which can only be used for connections to a city water main of at least 4 inches (102mm) in diameter. (2) The prescritive pipe sizing method of 10.4.9. (3) The hydraulic calculation procedure for NFPA 13. (4) The manufacturers listed intallation instructions. Statement of Problem and Substantiation for Public Comment Section 10.4.3, as written is confusing and not "user friendly". This public comment seeks to simplify and clarify the acceptable methods for sizing sprinkler pipes for NFPA 13D systems. This comment's does not change the existing requirements of this section, but instead changes the requirements from paragraph form to a list form for ease of interpretation. The 12 step general method originally included in section 10.4.3 has been retained but renumbered as section 10.4.4. Related Public Comments for This Document Related Comment Public Comment No. 19-NFPA 13D-2014 [Section No. 10.4.4] Related Item First Revision No. 13-NFPA 13D-2013 [Section No. 10.4.3] Relationship Submitter Information Verification Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Street Address: City:

4 of 52 9/22/2014 9:20 AM State: Zip: Submittal Date: Mon May 12 15:06:08 EDT 2014 Committee Statement Committee Accepted Action: Resolution: SR-9-NFPA 13D-2014 Statement: Section 10.4.3, as written is confusing and not "user friendly". This revision seeks to simplify and clarify the acceptable methods for sizing sprinkler pipes for NFPA 13D systems. This comment's does not change the existing requirements of this section, but instead changes the requirements from paragraph form to a list form for ease of interpretation. The 12 step general method originally included in section 10.4.3 has been retained but renumbered as section 10.4.4.

5 of 52 9/22/2014 9:20 AM Public Comment No. 19-NFPA 13D-2014 [ Section No. 10.4.4 ]

6 of 52 9/22/2014 9:20 AM 10.4.4 Smaller pipe sizes than those determined by 10.4.3 shall be permitted where justified by calculations for systems connected to city water mains of at least 4 in. (102 mm) in diameter. * General Pipe Sizing Method The following is the general pipe sizing method for straight-run systems connected to a city water main of at least 4 in. (102 mm) in diameter as per 10.4.3 (1):

7 of 52 9/22/2014 9:20 AM (1) The system flow rate shall be established in accordance with Sections 10.1 and 10.2, and it shall be determined that the flow allowed by the water meter meets or exceeds the system demand and that the total demand flow does not exceed the maximum flow allowed by the piping system components. (2) The water pressure in the street shall be determined. (3) Pipe sizes shall be selected. (4) *Pressure loss for a water meter, if any, shall be determined and deducted using one of the following: (5) Table 10.4.4(a) shall be permitted to be used, even where the sprinkler demand flow exceeds the meter's rated continuous flow. (6) Higher pressure losses specified by the manufacturer shall be used in place of those specified in Table 10.4.4(a). (7) Lower pressure losses shall be permitted to be used where supporting data are provided by the meter manufacturer. (8) Pressure loss for elevation shall be deducted as follows: (9) Building height above street (ft) 0.433 = pressure loss (psi) (10) Building height above street (m) 0.098 = pressure loss (bar) (11) *Pressure losses from the city main to the inside control valve shall be deducted by multiplying the pressure loss associated with the pipe material by the total length(s) of pipe in feet (meters). (12) Pressure loss for piping within the building shall be deducted by multiplying the pressure loss associated with the pipe material by the total length(s) of pipe in feet (meters). (13) Pressure loss for valves and fittings shall be deducted as follows: (14) The valves and fittings from the control valve to the farthest sprinkler shall be counted. (15) The equivalent length for each valve and fitting as shown in Table 10.4.4(b), Table 10.4.4(c), or Table 10.4.4(d) or Table 10.4.4(e) shall be determined and the values added to obtain the total equivalent length for each pipe size. (16) The equivalent length for each size shall be multiplied by the pressure loss associated with the pipe material and the values totaled. (17) In multilevel buildings, the steps in 10.4.4(1) through 10.4.4(8) shall be repeated to size piping for each floor. (18) If the remaining pressure is less than the operating pressure established by the testing laboratory for the sprinkler being used, the sprinkler system shall be redesigned. (19) If the remaining pressure is higher than required, smaller piping shall be permitted to be used where justified by calculations. (20) The remaining piping shall be sized the same as the piping up to and including the farthest sprinkler unless smaller pipe sizes are justified by calculations. Table 10.4.4(a) Pressure Losses in psi in Water Meters Meter Size (in.) Flow (gpm) 18 or less 23 26 31 39 52 5 8 9 14 18 26 38 * 3 4 7 11 14 22 35 * 1 2 3 3 4 6 10 1 1 2 1 1 2 2 4 7 2 1 1 1 1 2 3 For SI units, 1 gpm = 3.785 L/min; 1 in. = 25.4 mm; 1 psi = 0.0689 bar.

8 of 52 9/22/2014 9:20 AM *Above maximum rated flow of commonly available meters. Table 10.4.4(b) Equivalent Length in Feet of Fittings and Valves for Schedule 40 Steel Pipe Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 1 1 2 2 5 2 0 12 28 15 4 5 1 1 4 1 3 2 6 2 0 15 35 18 5 7 1 1 2 2 4 2 8 3 0 18 43 22 6 9 2 2 5 3 10 3 1 24 57 28 7 11 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.4(c) Equivalent Length in Feet of Fittings and Valves for Type K Copper Tube Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long-. Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 3 4 0 1 0 3 1 0 7 14 7 2 0 1 1 2 2 6 2 0 14 33 18 5 6 1 1 4 1 3 2 5 2 0 14 32 16 5 6 1 1 2 2 4 2 8 3 0 18 43 22 6 9 2 2 6 3 12 4 1 28 66 33 8 13 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.4(d) Equivalent Length in Feet of Fittings and Valves for Type L Copper Tube Diameter (in.) 45 Degree Elbow 90 Degree Elbow Long- Radius Elbow Tee or Cross (flow turned 90 degrees) Tee or Cross (flow straight through) Gate Valve Angle Valve Globe Valve Globe Y Pattern Valve Cock Valve Check Valve 3 4 0 2 0 4 1 0 8 18 10 3 0 1 1 3 3 7 2 0 16 38 20 5 7 1 1 4 1 3 2 6 2 0 15 35 18 5 7 1 1 2 2 4 2 9 3 0 20 47 24 7 10 2 2 6 4 12 4 1 30 71 35 9 14 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Table 10.4.4(e) Equivalent Length in Feet of Fittings and Valves for Type M Copper Tube 45 90 Long- Tee or Tee or Gate Globe Cock

9 of 52 9/22/2014 9:20 AM Diameter (in.) Degree Elbow Degree Elbow Radius Elbow Cross (flow turned 90 degrees) Cross (flow straight through) Valve Angle Valve Globe Valve Y Pattern Valve Valve Check Valve 3 4 0 2 0 4 1 0 10 21 11 3 0 1 2 3 3 8 3 0 19 43 23 6 8 1 1 4 1 3 2 7 2 0 16 38 20 5 8 1 1 2 2 5 2 9 3 0 21 50 26 7 11 2 3 7 4 13 5 1 32 75 37 9 14 For SI units, 1 in. = 25.4 mm; 1 ft = 0.3048 m. Statement of Problem and Substantiation for Public Comment The general method of pipe sizing has been moved from section 10.4.3 to 10..4.4 to correlate with Public Comment No. 20. The wording and method itself remains unchanged. Related Public Comments for This Document Related Comment Public Comment No. 21-NFPA 13D-2014 [Section No. A.10.4.3] Public Comment No. 23-NFPA 13D-2014 [Section No. 10.4.3] Related Item First Revision No. 13-NFPA 13D-2013 [Section No. 10.4.3] Relationship Submitter Information Verification Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Street Address: City: State: Zip: Submittal Date: Mon May 12 08:31:25 EDT 2014 Committee Statement Committee Accepted Action: Resolution: SR-15-NFPA 13D-2014 Statement: The general method of pipe sizing has been moved from section 10.4.3 to 10.4.4 to correlate with SR-9. The wording and method itself remains unchanged.

0 of 52 9/22/2014 9:20 AM Public Comment No. 24-NFPA 13D-2014 [ Section No. 12.3.2 ] 12.3.2 Any sprinkler that is operated, damaged, corroded, covered with foreign materials, or showing signs of leakage shall be replaced with a new listed sprinkler having the same performance characteristics as the original equipment. 12.3.2.1 * Where replacing residential sprinklers manufactured prior to 2003 and that are no longer available from the manufacturer and are installed using a design density less than 0.05 gpm/ft 2 (204 mm/min), a residential sprinkler with an equivalent K-factor (± 5%) shall be permitted to be used provided the currently listed coverage area for the replacement sprinkler is not exceeded. Statement of Problem and Substantiation for Public Comment It is preferred to replace existing sprinklers with the same model when it is available so that the systems continue to operate as it was designed. This proposal was developed by the UL/FM/NFSA Standards Review Committee. Related Item First Revision No. 23-NFPA 13D-2013 [Section No. 12.3.2] Submitter Information Verification Submitter Full Name: Victoria Valentine Organization: National Fire Sprinkler Assoc Affilliation: UL/FM/NFSA Standards Review Committee Street Address: City: State: Zip: Submittal Date: Wed May 14 09:42:39 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 13D-2014 Statement: It is preferred to replace existing sprinklers with the same model when it is available so that the systems continue to operate as it was designed.

1 of 52 9/22/2014 9:20 AM Public Comment No. 1-NFPA 13D-2014 [ Section No. 12.3.2.1 ] 12.3.2.1 * Where replacing residential sprinklers manufactured prior to 2003 and installed using a design density less than 0.05 gpm/ft 2 (204 mm/min), a residential sprinkler with an equivalent K-factor (± 5%) shall be permitted to be used provided the currently listed coverage area for the replacement sprinkler is not exceeded require replacement and the same model of residential sprinkler is no longer available, replacement residential sprinklers shall either have a consistent hydraulic demand with the original residential sprinklers or calculations shall be provided to demonstrate that system supply meets the demand of the replacement sprinklers. Statement of Problem and Substantiation for Public Comment The proposed language would allow the use of replacement sprinklers with hydraulic demands that may exceed the available system supply. If an equivalent replacement sprinkler is not available, then calculations should be performed that prove the system can support the replacement residential sprinklers. Related Item First Revision No. 23-NFPA 13D-2013 [Section No. 12.3.2] Submitter Information Verification Submitter Full Name: Mark Fessenden Organization: Tyco Fire Protection Products Street Address: City: State: Zip: Submittal Date: Tue Mar 11 10:56:57 EDT 2014 Committee Statement Committee Action: Resolution: Rejected Requiring recalculation to new flows and pressures would be burdensome and may in some instances would require systems to be replace.

2 of 52 9/22/2014 9:20 AM Public Comment No. 13-NFPA 13D-2014 [ Section No. 12.3.2.1 ] 12.3.2.1 * Where replacing residential sprinklers manufactured prior to 2003 and, installed using a design density less than 0.05 gpm/ft 2 (204 mm/min), a and that are no longer available from the manufacturer, a residential sprinkler with an equivalent K-factor (± 5%) shall be permitted to be used provided the currently listed coverage area for the replacement sprinkler is not exceeded. Statement of Problem and Substantiation for Public Comment The first option should be to use the manufacturer's replacement sprinkler when it is available. Related Item First Revision No. 23-NFPA 13D-2013 [Section No. 12.3.2] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Thu Apr 17 13:48:45 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 13D-2014 Statement: It is preferred to replace existing sprinklers with the same model when it is available so that the systems continue to operate as it was designed.

3 of 52 9/22/2014 9:20 AM Public Comment No. 17-NFPA 13D-2014 [ Section No. 12.3.2.1 ] 12.3.2.1 * Where replacing residential sprinklers manufactured prior to 2003 and installed using a design density less than 0.05 gpm/ft 2 (204 mm/min), and that are no longer available from the manufacturer, a residential sprinkler with an equivalent K-factor (± 5%) shall be permitted to be used provided the currently listed coverage area for the replacement sprinkler is not exceeded. Statement of Problem and Substantiation for Public Comment This section would allow residential sprinklers installed to a design density of less then 0.05 gpm/ft2 to be replaced with a replacement sprinkler with an equivalent k-factor. As stated in A.12.3.2.1, the flow and pressure available to the replacement sprinkler might be less than its current flow and pressure requirement. If the sprinkler to be replaced is still available from the manufacturer, that sprinkler should be used as the replacement to ensure, where possible, that the original criteria continues to be met. Related Item First Revision No. 23-NFPA 13D-2013 [Section No. 12.3.2] Submitter Information Verification Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Affilliation: NFSA E&S Committee Street Address: City: State: Zip: Submittal Date: Thu May 01 10:20:28 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 13D-2014 Statement: It is preferred to replace existing sprinklers with the same model when it is available so that the systems continue to operate as it was designed.