Public Input No. 4-NFPA [ Section No. 4.2 ] Statement of Problem and Substantiation for Public Input. Submitter Information Verification

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Public Input No. 4-NFPA 214-2013 [ Section No. 4.2 ] 4.2 * Fire Risk Analysis. A fire risk analysis shall be conducted. The following are some of the factors that shall be considered in determining the extent and method of fire protection required for induced-draft and natural-draft watercooling towers: (1) Importance to continuity of operation (2) * Size and construction of tower (3) Type of tower (4) Location of tower (5) Water supply (6) Value of tower (7) Climate (8) * Water delivery time (9) Environment (10) Rooftop towers (11) Limited access (12) Materials of construction (see Section 4.1 ) (1) The language within 4.2* describes methods used to determine the extent and method of fire protection features, therefore should be moved out of Chapter 4 which covers the Location of Water-Cooling towers to Chapter 5, Fire Protection. A PI has been submitted to add to 5.1.3. Submittal Date: Thu Sep 26 09:08:17 EDT 2013 Resolution: The committee agrees that this requirement does not belong under the chapter "Location of Water- Cooling Towers". Please see FR-15 changing the title of Chapter 4 to "General Requirements" making the document more consistent with typical NFPA format.

Public Input No. 6-NFPA 214-2013 [ Section No. 4.4 ] 4.4 Combustible Surfaces with Fixed Protection. Towers with combustible exterior surfaces that are provided with fixed exposure protection in accordance with 5.2.10 shall be permitted to be located closer than 100 ft (30.5 m) from but no closer than 75 ft (22.8 m) from the hazards listed in Section 4.3. 4.4 as written does not define a minimum distance. The 75 ft minimum now allows for a defensible space for both buildings as well as an area that could be used for additional exposure protection by firefighters. The type of occupancies defined in section 4.3 (new 4.2) has extreme fire risks and should be respected as such. If located too close, the occupancies as defined in 4.3 (1) may cause accidental activation of the exposure protection system, not to mention that the fixed exposure protection system on a tower located next to an occupancy listed in 4.3 (2) would be useless if that building should go. Submittal Date: Thu Sep 26 09:14:42 EDT 2013 Resolution: The committee finds no technical basis for the 75-foot requirement. The committee also noted that distance is a criteria in the fire risk analysis in Section 4.2.

Public Input No. 13-NFPA 214-2013 [ Section No. 5.1.1 ] 5.1.1 * Types of Suppression Systems. If the fire risk analysis results in Section 4.2, or the conditions of Section 4.7 exist, requiring a fire protection system, one of the following general types of systems shall be used: (1) Open-head deluge system (2) Closed-head dry-pipe system (3) Wet-pipe automatic sprinkler system (4) (5) Closed-head preaction system Without open heads, it s not a deluge type system. Without Closed head, it can t be a dry system or a preaction system. Recommendation uses conventional wording. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Fri Nov 08 07:46:10 EST 2013 Resolution: FR-2-NFPA 214-2014 Statement: The committee agrees in principle. For simplicity, it is cleaner to reference the requirements contained in Section 5.2.2 rather than restating the types of sprinkler systems. The title of the section is also being changed to be consistent with the rest of the document.

Public Input No. 14-NFPA 214-2013 [ Section No. 5.1.2 [Excluding any Sub-Sections] ] A complete plan showing piping arrangement, location of sprinklers, fixed detectors, and operating equipment such as valves and deluge valves, together with hydraulic calculations, water requirements, and water supply information, shall be submitted to approved by the authority having jurisdiction for approval before jurisdiction before installation. Merely submitting plans is not the requirement that needs to be achieved. The goal is to obtain approval of the plans prior to the installation. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Fri Nov 08 07:48:10 EST 2013 Resolution: The current wording is consistent with NFPA 13 Section 23.1.1.

Public Input No. 5-NFPA 214-2013 [ New Section after 5.1.2.3 ] 5.1.3* Fire Risk Analysis. A fire risk analysis shall be conducted. The following are some of the factors that shall be considered in determining the extent and method of fire protection required for induced-draft and natural-draft water-cooling towers. (1) Importance to continuity of operation (2) *Size, materials and construction of tower (3) Type of tower (4) Location of tower (5) Water Supply (6) Value of tower (7) Climate (8) *Water delivery time (9) Environment (10) Rooftop towers (11) Limited access (12) Materials of construction The language within 4.2* describes methods used to determine the extent and method of fire protection features, therefore should be moved out of Chapter 4 which covers the Location of Water-Cooling towers to Chapter 5, Fire Protection. This text text was moved and modified from 4.2. Related Public Inputs for This Document Related Input Public Input No. 4-NFPA 214-2013 [Section No. 4.2] Relationship Submittal Date: Thu Sep 26 09:10:35 EDT 2013 Resolution: The committee has decided to leave the text in Section 4.2 and change the title of Chapter 4, and believes that changing the text doesn't provide additional clarification of the section.

Public Input No. 8-NFPA 214-2013 [ New Section after 5.4 ] Hose house. Where required by the AHJ, a Hose house and standard Hose house equipment in accordance with NFPA 24 shall be provided at each hydrant required by section 5.4. A.5.4 is referenced when seeking clarification on hydrants. It is within A.5.4 that Hose houses are mentioned and has enough specifics that warrants it be addressed separately. Submittal Date: Thu Sep 26 09:20:26 EDT 2013 Resolution: Hose houses are covered in other standards. A.5.4 refers users to NFPA 24 for more information.

Public Input No. 7-NFPA 214-2013 [ Section No. 5.4 ] 5.4 * Hydrant Protection. Hydrant protection capable of providing the minimum fire flow as specified in 5.6.3 is required. Such Hydrants shall not be located less than 40 ft (12.2 m) from towers towers and not greater than 200 ft (60. 9 m) of all parts of towers having combustible construction. 1) The content of A.5.4 has more than just explanatory material and should be included within the body of the standard. 2) The item of Hose houses has specifics and should have its own section. 3) The current standard states that hydrants shall be no closer than 40 ft (12.2 m) to buildings while the annex allows it to be on top of it. Submittal Date: Thu Sep 26 09:18:29 EDT 2013 Resolution: Hydrant protection is covered in other standards. A.5.4 refers users to NFPA 24 for more information.

Public Input No. 9-NFPA 214-2013 [ Section No. 5.5 [Excluding any Sub-Sections] ] Towers with any combustible construction located on a building 50 ft (15.3 m) or more in height shall be provided with Class III standpipe protection with hose connections within 200 within 100 ft(61 m) of 30.5m) of all parts of the tower. 1) NFPA 14, 4.6.2 allows for a maximum of 100 ft (30.5 m) of 1-1/2 inch hose for Class III standpipes. 2) If allowed to be kept at 200 ft (60.9 m), firefighters will need to add/ extend hose lines while working on buildings. And if doing so on buildings greater than 50 ft (15.2 m), they would more than likely be working within confined areas such as stairways and catwalks. Submittal Date: Thu Sep 26 09:21:51 EDT 2013 Resolution: This section is not intended to address hose requirements.

Public Input No. 10-NFPA 214-2013 [ Section No. 8.7.1 ] 8.7.1 Access to the tops of water-cooling towers for fire fighting and maintenance shall be provided by an approved stairway or ladder. The existing firefighting access language in 8.7.1 is not applicable in section 8, Maintenance. Access for firefighting is not a maintenance issue and therefore should stand alone. A new Chapter 9 is being proposed to address that. Submittal Date: Thu Sep 26 09:23:17 EDT 2013 Resolution: The committee resolved this issue by changing the title of Chapter 8 to "Operating Features, Maintenance, and Access" (See FR-16)

0 Public Input No. 11-NFPA 214-2013 [ New Section after 8.10 ] Chapter 9 Fire Fighter Access 9.1 Firefighter access to the tops of water-cooling towers shall be provided by an approved stairway or ladder. 9.2 Towers in excess of 120 ft (36.6 m) in any dimension shall be provided with not less than two approved means of firefighter access remote from each other. 9.3 Access can also be used for maintenance purposes. Firefighter access language was not applicable in Section 8, Maintenance. The content was extracted from section 8.7.2 and moved out of the maintenance section to here. Also, added the word approved. Related Public Inputs for This Document Related Input Public Input No. 10-NFPA 214-2013 [Section No. 8.7.1] Relationship Submittal Date: Thu Sep 26 09:24:41 EDT 2013 Resolution: The committee resolved this issue by changing the title of Chapter 8 to "Operating Features, Maintenance, and Access".

1 Public Input No. 12-NFPA 214-2013 [ Section No. A.5.4 ] A.5.4 Hydrant protection should be provided within 200 ft (61 m) of all parts of towers having combustible construction and located on the ground or on buildings less than 50 ft (15.3 m) in height. A hose house and standard hose house equipment should be provided at each hydrant. (See NFPA 24 for further details.) The content within A.5.4 would now be within the body of the standard. Related Public Inputs for This Document Related Input Public Input No. 6-NFPA 214-2013 [Section No. 4.4] Public Input No. 8-NFPA 214-2013 [New Section after 5.4] Relationship Submittal Date: Thu Sep 26 09:26:40 EDT 2013 Resolution: The committee believes this material should remain in the Annex.