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Public Input No. 79-NFPA 409-2013 [ Section No. 1.1 ]
1.1 Scope.
1.1.1
This standard contains the minimum requirements for the proper construction of aircraft hangars and
protection of aircraft hangars from fire.
1.1.2
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
Statement of Problem and Substantiation for Public Input
1.1.1 no change
1.1.2 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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 08:55:24 EDT 2013
Committee Statement
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".
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Public Input No. 41-NFPA 409-2013 [ Section No. 3.3.11 ]
3.3.11 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.
Statement of Problem and Substantiation for Public Input
Definition is for "membrane", not "membrane hangar".
Submitter Information Verification
Submitter Full Name: LIANE OZMUN
Organization:
FRANKFURT-SHORT-BRUZA
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Jul 02 18:32:05 EDT 2013
Committee Statement
Resolution: FR-12-NFPA 409-2013
Statement: The definition has been modified to better represent the term.
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Public Input No. 78-NFPA 409-2013 [ New Section after 3.3.17 ]
3.3.18 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_3-3-18.pdf
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: KAARE HOLM
Organization:
NOFOAM SYSTEMS, EGE
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 08:22:02 EDT 2013
Committee Statement
Resolution: The appropriate definition of "foam concentrate" is found in NFPA 11.
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Public Input No. 88-NFPA 409-2013 [ New Section after 3.3.17 ]
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
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:29:18 EDT 2013
Committee Statement
Resolution: The appropriate definitions for these terms are found in NFPA 11.
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Public Input No. 80-NFPA 409-2013 [ New Section after 5.2.4 ]
5.2.5 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, 5.2.3 & 5.2.4 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
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 08:57:41 EDT 2013
Committee Statement
Resolution: Section 5.6 applies to columns, but is not appropriate for walls. References to "other NFPA
standards" is not specific enough.
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Public Input No. 42-NFPA 409-2013 [ Section No. 5.9.1 ]
5.9.1 *
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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: LIANE OZMUN
Organization:
FRANKFURT-SHORT-BRUZA
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Jul 02 18:37:47 EDT 2013
Committee Statement
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 5.9.1.
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Public Input No. 81-NFPA 409-2013 [ Section No. 5.11.2.2 ]
5.11.2.2 *
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
Statement of Problem and Substantiation for Public Input
The need for these changes is self evident.
Submitter Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 08:59:24 EDT 2013
Committee Statement
Resolution: Provided substantiation is inadequate.
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Public Input No. 49-NFPA 409-2013 [ Section No. 5.11.2.4 ]
5.11.2.4 *
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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:04:41 EDT 2013
Committee Statement
Resolution: The proposal does not address the true water flow that could be expected.
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Public Input No. 82-NFPA 409-2013 [ Section No. 5.11.2.10 ]
5.11.2.10
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
Statement of Problem and Substantiation for Public Input
The need for these changes is self evident.
Submitter Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:01:04 EDT 2013
Committee Statement
Resolution: "Flame trap" is not a recognized term. The substantiation was inadequate to explain the submitter's
intent.
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Public Input No. 30-NFPA 409-2013 [ Section No. 5.12.2 ]
5.12.2
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 5.12.5 . 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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: STEPHEN TAMANKO
Organization:
Bascon Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 05 13:07:21 EST 2013
Committee Statement
Resolution: The current wording would not necessarily prohibit the use of sealed burners and ducted combustion
air that do not comply with 5.12.5. The definition of an open flame device should be interpreted in
accordance with standard HVAC industry practices.
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Public Input No. 31-NFPA 409-2013 [ Section No. 5.12.4 [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
5 .12.5. 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.
Statement of Problem and Substantiation for Public Input
The way this is written, no air rotation type heaters can be utilized including but not limited to hot water coil type.
Submitter Information Verification
Submitter Full Name: STEPHEN TAMANKO
Organization:
Bascon, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 05 14:05:22 EST 2013
Committee Statement
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.
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Public Input No. 24-NFPA 409-2013 [ Section No. 5.15.1 ]
5.15.1*
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 5.15.2 and 5.15.3.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Donald Cook
Organization:
Shelby County Department of De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Feb 28 15:46:30 EST 2013
Committee Statement
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.
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Public Input No. 28-NFPA 409-2013 [ Section No. 5.15.2 ]
5.15.2
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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Donald Cook
Organization:
Shelby County Department of De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Feb 28 16:22:32 EST 2013
Committee Statement
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.
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Public Input No. 83-NFPA 409-2013 [ Section No. 5.17.1 ]
5.17.1
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
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:02:57 EDT 2013
Committee Statement
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.
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Public Input No. 51-NFPA 409-2013 [ New Section after 6.1.1 ]
new 6.1.6
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.
Statement of Problem and Substantiation for Public Input
NFPA 11 (2010 edition) 4.7.2.1 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
Relationship
Public Input No. 52-NFPA 409-2013 [New Section after 7.1]
Public Input No. 53-NFPA 409-2013 [Section No. 9.14.5.3]
Public Input No. 54-NFPA 409-2013 [Section No. 6.2.3.3]
Public Input No. 55-NFPA 409-2013 [Section No. 6.2.5.2]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:23:04 EDT 2013
Committee Statement
Resolution: FR-13-NFPA 409-2013
Statement: NFPA 11 (2010 edition) 4.7.2.1 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.
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Public Input No. 47-NFPA 409-2013 [ Section No. 6.1.1 ]
6.1.1
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 6.2.2. In addition, supplementary protection systems as
specified in 6.2.3 shall be provided in hangars housing single aircraft having wing areas greater than
279 m2 (3000 ft2).
(2) A combination of automatic sprinkler protection in accordance with 6.2.4 and an automatic low-level
low-expansion foam system in accordance with 6.2.5.
(3) A combination of automatic sprinkler protection in accordance with 6.2.4 and an automatic low-level
high-expansion foam system in accordance with 6.2.5.
(4) A combination of automatic sprinkler protection in accordance with 6.2.4 and a fuel containment floor
system in accordance with 6.2.X
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: TRISTAN MACKINTOSH
Organization:
Fireless Flooring
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 05 11:33:36 EDT 2013
Committee Statement
Resolution: The fuel containment floor system technology has not been fully tested.
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Public Input No. 56-NFPA 409-2013 [ Section No. 6.2.2.3 ]
6.2.2.3
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.
Statement of Problem and Substantiation for Public Input
Allow NFPA 13 to set parameters for spacing along and between branchlines. Note this section is also referenced
by also 7.2.3 and 9.14.2(3)(c).
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:41:23 EDT 2013
Committee Statement
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.
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Public Input No. 54-NFPA 409-2013 [ Section No. 6.2.3.3 ]
6.2.3.3
Each supplementary protection system shall be designed, installed, and maintained in accordance with
NFPA 11.
Statement of Problem and Substantiation for Public Input
Delete as redundant with proposed new 6.1.6 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
Relationship
Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:32:14 EDT 2013
Committee Statement
Resolution: FR-14-NFPA 409-2013
Statement: Delete as redundant with new 6.1.6 (FR 13) to apply to all foam systems.
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Public Input No. 84-NFPA 409-2013 [ Sections 6.2.3.5.1, 6.2.3.5.2, 6.2.3.5.3, 6.2.3.5.4,
6.2.3.... ]
Sections 6.2.3.5.1, 6.2.3.5.2, 6.2.3.5.3, 6.2.3.5.4, 6.2.3.5.5
6.2.3.5.1
Supplementary high
expansion foam systems shall
utilize surfactants as the foaming ingredient and shall be designed for local application.
comply with 6.2.
3
5 .5
.2 *
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.
6.2.3.5.3 Discharge rates shall take into consideration the sprinkler breakdown factor required in
6.12.8.2.2(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.
6.2.3.5.
4
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.
6.2.3.5.5 * 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_6.2.3.5_6.2.5.5_Rationalisation.docx
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
6.2.3.5 and 6.2.5.5 largely repeat each other and this proposed arrangement reduces this duplication
6.2.3.5.2 Guidance of high-expansion foam local delivery.
6.2.5.5 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.
6.2.5.5.1 changed to be used defining all types of Hi-Ex generation.
6.2.5.5.2 changed to be consistent with the requirement to follow NFPA 11 calculation methodology.
6.2.5.5.3 Expanded to allow zoning of large systems
6.2.5.5.4 Changed to better describe the requirements of general area coverage and supplementary systems
6.2.5.5.5 & 6 Changed to allow inside-air generators
6.2.5.5.6 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
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•
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:04:57 EDT 2013
Committee Statement
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 (6.2.5.5) do not have the
same performance criteria as supplementary foam systems (6.2.3.5), 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.
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Public Input No. 74-NFPA 409-2013 [ Section No. 6.2.3.5.3 ]
6.2.3.5.3
Discharge rates shall take into consideration the sprinkler breakdown factor required in
6.12.8.2. 3. 2 (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_6-2-3-5-3.pdf
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Robert Kasiski
Organization:
FM Global
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Jul 11 13:28:18 EDT 2013
Committee Statement
Resolution: There are sufficient safety factors in the existing design criteria to address this concern.
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Public Input No. 89-NFPA 409-2013 [ Sections 6.2.3.5.4, 6.2.3.5.5 ]
Sections 6.2.3.5.4, 6.2.3.5.5
6.2.3.5.4
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.
6.2.3.5.5 *
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 20.
6.2.3.5.6 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
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:31:26 EDT 2013
Committee Statement
Resolution: Adequate technical data has not been provided to support the use of inside air.
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Public Input No. 4-NFPA 409-2012 [ Section No. 6.2.3.5.5 ]
6.2.3.5.5 *
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.
Statement of Problem and Substantiation for Public Input
Clarifies that the section is specifically addressing foam generators.
Submitter Information Verification
Submitter Full Name: John Chartier
Organization:
Northeastern Regional Fire Cod
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Aug 16 11:27:16 EDT 2012
Committee Statement
Resolution: FR-17-NFPA 409-2013
Statement: Clarifies that the section is specifically addressing foam generators.
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Public Input No. 35-NFPA 409-2013 [ Section No. 6.2.4.5 ]
6.2.4.5
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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Sat Jun 29 13:11:06 EDT 2013
Committee Statement
Resolution: FR-15-NFPA 409-2013
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.
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Public Input No. 55-NFPA 409-2013 [ Section No. 6.2.5.2 ]
6.2.5.2
Each low-level foam protection system shall be designed, installed, and maintained in accordance with
NFPA 11.
Statement of Problem and Substantiation for Public Input
Delete as redundant with proposed new 6.1.6 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
Relationship
Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:38:54 EDT 2013
Committee Statement
Resolution: FR-39-NFPA 409-2013
Statement: Delete as redundant with new 6.1.6 (FR 13) to apply to all foam systems.
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Public Input No. 85-NFPA 409-2013 [ Section No. 6.2.5.5 ]
6.2.5.5 Low-Level High-Expansion Foam Systems.
6.2.5.5.1
Low High - level high- expansion foam systems shall be designed and installed in accordance with
requirements for local application systems of NFPA 11 6 . 12.4.
6.2.5.5.2
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 6.12 .
6.2.5.5.3
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 6.12.8.2.2(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.
6.2.5.5.4
The high-expansion foam generators shall be arranged to achieve initial foam coverage in the
expected aircraft parking potential fuel spill area.
6.2.5.5.5
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.
6.2.5.5.6 *
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 20.
6.2.5.5.7 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_6.2.3.5_6.2.5.5_Rationalisation.docx
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
6.2.3.5 and 6.2.5.5 largely repeat each other and this proposed arrangement reduces this duplication
6.2.3.5.2 Guidance of high-expansion foam local delivery.
6.2.5.5 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.
6.2.5.5.1 changed to be used defining all types of Hi-Ex generation.
6.2.5.5.2 changed to be consistent with the requirement to follow NFPA 11 calculation methodology.
6.2.5.5.3 Expanded to allow zoning of large systems
6.2.5.5.4 Changed to better describe the requirements of general area coverage and supplementary systems
6.2.5.5.5 & 6 Changed to allow inside-air generators
6.2.5.5.6 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
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•
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:07:13 EDT 2013
Committee Statement
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 (6.2.5.5) do not have the
same performance criteria as supplementary foam systems (6.2.3.5), 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.
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Public Input No. 75-NFPA 409-2013 [ Section No. 6.2.5.5.3 ]
6.2.5.5.3
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 6.12.8.2. 3. 2 (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_6-2-5-5-3.pdf
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Robert Kasiski
Organization:
FM Global
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Jul 11 13:31:14 EDT 2013
Committee Statement
Resolution: There are sufficient safety factors in the existing design criteria to address this concern.
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Public Input No. 60-NFPA 409-2013 [ Section No. 6.2.5.5.5 ]
6.2.5.5.5
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.
Statement of Problem and Substantiation for Public Input
In past NFPA 409 TC meetings inside air test data was presented by Ansul which demonstrated compliance with
NFPA 11 6.9.1 and 6.9.2 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
Relationship
Public Input No. 61-NFPA 409-2013 [Section No. 7.5.5]
Public Input No. 62-NFPA 409-2013 [Section No. 9.14.7.5.5]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:59:25 EDT 2013
Committee Statement
Resolution: Adequate technical data has not been provided to support the use of inside air.
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Public Input No. 90-NFPA 409-2013 [ Sections 6.2.5.5.5, 6.2.5.5.6 ]
Sections 6.2.5.5.5, 6.2.5.5.6
6.2.5.5.5
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.
6.2.5.5.6 *
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 20.
6.2.5.5.7 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
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:36:12 EDT 2013
Committee Statement
Resolution: Adequate technical data has not been provided to support the use of inside air.
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Public Input No. 86-NFPA 409-2013 [ Section No. 6.2.6 ]
6.2.6 *
Foam Concentrate Supply.
The friction losses in piping carrying foam concentrate shall be calculated using the Darcy formula, also
known as the Fanning formula.
6.2.6.1 *
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 6.2.2.4 and NFPA 16 .
6.2.6.2 *
The quantity of high-expansion foam concentrate shall be large enough for a 12 15 -minute
discharge at the water flow rate based on the supply calculation method required in 6.2.2.4 . of
NFPA 11.
6.2.6.3
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.
6.2.6.4
Control valves, foam concentrate liquid storage tanks, concentrate pumps, controllers, and bypass
balancing equipment shall be located outside the aircraft storage and service area.
6.2.6.5 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).
6.2.6.6 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
Statement of Problem and Substantiation for Public Input
6.2.6.1 Protein foam is no longer manufactured, and Lo-Ex foam types do not include FFFP, this level of detail
does not seem necessary.
6.2.6.2 NFPA 409 requires compliance with NFPA 11, which requires 2x 15 minute supplies. The calculation
method in 6.2.2.4 is only part of the necessary calculation, and NFPA 11 offers a better calculation method.
6.2.6.5 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.
6.2.6.6 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 Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
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City:
State:
Zip:
Submittal Date:
Fri Jul 12 09:11:32 EDT 2013
Committee Statement
Resolution: Fluoroprotein is still available. There is inadequate substantiation to increase the supply duration. See
FR 55 (6.2.6.3) 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.
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Public Input No. 45-NFPA 409-2013 [ New Section after 6.2.7.10 ]
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.3.2
6.2.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.3.2.1 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.3.2
6.2.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 6.2.4 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 5.11.2
6.2.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
5.11.2.3.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: TRISTAN MACKINTOSH
Organization:
Fireless Flooring
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 05 11:23:31 EDT 2013
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Committee Statement
Resolution: The fuel containment floor system technology has not been fully tested.
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Public Input No. 29-NFPA 409-2013 [ Section No. 6.2.7.10 ]
6.2.7.10
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower) , a listed electric
foam pump controller shall be used.
(2) For electric-drive foam concentrate pumps not exceeding 22.4kW (30 horsepower), a listed electric
foam pump controller or limited-service foam pump controller shall be used.
(2) For diesel engine–driven foam concentrate pumps, a listed fire pump controller shall be used.
Additional Proposed Changes
File Name
6.2.7.10_1_.pdf
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
Foam pumps feed full service controllers and should be no less than full service controllers. Listed full service
controllers are now available in horsepowers down to 1.0 Hp. Also, Limited Service Controllers are no longer
Listed (Approved) by Factory Mutual.
Note: At one time, full service controllers were not available below 30 Hp.
Note: Similar proposals have been submitted to NFPA-11 and NFPA-16.
Submitter Information Verification
Submitter Full Name: James Nasby
Organization:
Columbia Engineering
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Mar 01 07:48:06 EST 2013
Committee Statement
Resolution: FR-16-NFPA 409-2013
Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancy
requirements throughout this standard.
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Public Input No. 57-NFPA 409-2013 [ Section No. 6.2.7.10 ]
6.2.7.10
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower), a listed full
service electric foam pump controller shall be used.
(2) For
electric-drive foam concentrate pumps not exceeding 22.4kW (30 horsepower), a listed electric foam
pump controller or limited-service foam pump controller shall be used.
(3) For diesel engine–driven foam concentrate pumps, a listed fire pump controller shall be used.
Statement of Problem and Substantiation for Public Input
Limited service fire pump controllers have been recommended for deletion twice by the NFPA 20 TC. Since full
service controllers are available for all pump motor sizes at only a small additional cost, this should be the
minimum requirement. To allow limited service foam pump controllers is inconsistent with the reliability and
redundancy requirements throughout this standard. Also the language in 6.2.7.10 should be identical to 7.3.3.9
and 9.14.9.3.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 58-NFPA 409-2013 [Section No. 7.3.3.9]
Public Input No. 59-NFPA 409-2013 [Section No. 9.14.9.3]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:45:11 EDT 2013
Committee Statement
Resolution: FR-16-NFPA 409-2013
Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancy
requirements throughout this standard.
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Public Input No. 67-NFPA 409-2013 [ New Section after 6.2.8.1 ]
proposed new 6.2.8.1.4
Listed detection systems (such as optical flame detection) shall be acceptable in lieu of heat detection if
both approved by the Authority Having Jurisdiction and installed in accordance with NFPA 72.
Statement of Problem and Substantiation for Public Input
The purpose of this change is to make it clear than an owner and AHJ may agree to adopt an alternate detection
system without requiring two detection systems.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 68-NFPA 409-2013 [New Section after 7.7]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:33:45 EDT 2013
Committee Statement
Resolution: FR-18-NFPA 409-2013
Statement: The purpose of this change is to make it clear than an owner and AHJ may agree to adopt an
alternate detection system without requiring two detection systems.
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Public Input No. 65-NFPA 409-2013 [ New Section after 6.2.8.4 ]
proposed new 6.2.8.4.1
Where wet-pipe sprinkler systems are provided, detection of sprinkler water flow shall be acceptable as the
means of heat detection.
Statement of Problem and Substantiation for Public Input
This is a clarification of the intent of the standard.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 66-NFPA 409-2013 [New Section after 7.7.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:25:02 EDT 2013
Committee Statement
Resolution: The proposed text would place requirements regarding the actuation of the low-level foam system
within the section that addresses the actuation of preaction sprinkler systems.
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Public Input No. 73-NFPA 409-2013 [ Section No. 6.2.8.5.1 ]
6.2.8.5.1 *
Actuation of any closed-head sprinkler system shall simultaneously operate the low-level foam protection
system (s) associated with it's area of coverage .
Statement of Problem and Substantiation for Public Input
In Group I hangars low-level foam systems may need to be divided into multiple systems or zones. The standard
is very clear that the capability to discharge all zones of a low-level foam system must be provided. For
foam-water deluge sprinklers the standard implies that the systems are to be operated on a system by system
basis in response to fire alarm initiating devices. Similarly for low-level foam, the standard needs to clarify if the
systems or zones must all be discharged simultaneously, or if the response can be zoned in some manner. The
recommendation is to allow a zoned response of the low-level systems.
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Jul 08 23:17:33 EDT 2013
Committee Statement
Resolution: The committee has formed a task group to study the issue of zoning of the low-level foam systems.
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Public Input No. 40-NFPA 409-2013 [ Section No. 6.2.9.3.1.1 ]
6.2.9.3.1.1
Where aircraft storage and servicing areas house only unfueled aircraft, as defined in 3.3.15 , hand hose
systems shall be provided in accordance with 6.2.9.4 of this standard.
Statement of Problem and Substantiation for Public Input
Hand hose systems for hangars housing unfueled aircraft are addressed in Chapter 12, Unfueled Aircraft
Hangars. Paragraphs 12.5.10 and 12.5.6.1 indicate inside hand hose systems are not required.
This change relocates unfueled aircraft hangar criteria to the chapter covering the subject, and eliminates
conflicting criteria.
Submitter Information Verification
Submitter Full Name: LIANE OZMUN
Organization:
FRANKFURT-SHORT-BRUZA
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Jul 02 13:20:53 EDT 2013
Committee Statement
Resolution: FR-19-NFPA 409-2013
Statement: Hand hose systems for hangars housing unfueled aircraft are addressed in Chapter 12, Unfueled
Aircraft Hangars. Paragraphs 12.5.10 and 12.5.6.1 indicate inside hand hose systems are not
required.
This change relocates unfueled aircraft hangar criteria to the chapter covering the subject, and
eliminates conflicting criteria.
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Public Input No. 63-NFPA 409-2013 [ Section No. 6.2.10.8.2 ]
6.2.10.8.2
The total pumping capacity shall be such that the maximum demand is met with the largest fire pump
out of service. be provided using fire pumps of equal capacity. No fewer than two fire pumps shall be
provided.
Statement of Problem and Substantiation for Public Input
The "largest fire pump out of service" requirement is a level of redundancy not found in any other NFPA occupancy
standard. NFPA 20 takes considerable care in ensuring fire pump reliability. This proposal relaxes the
requirement for water supply redundancy in a manner analogous to the divided water supply requirement
of.6.2.10.7 and does not allow the hangar to be protected by only a single fire pump.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 64-NFPA 409-2013 [Section No. 9.14.13.2]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:17:04 EDT 2013
Committee Statement
Resolution: FR-41-NFPA 409-2013
Statement: The "largest fire pump out of service" requirement is a level of redundancy not found in any other
NFPA occupancy standard. NFPA 20 takes considerable care in ensuring fire pump reliability. This
revision relaxes the requirement for water supply redundancy, but does not allow the hangar to be
protected by only a single fire pump. See also CI 40, which proposes an alternative revision for this
section.
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Public Input No. 1-NFPA 409-2012 [ Section No. 6.2.10.9 ]
6.2.10.9* Flushing Underground Pipe.
Underground mains and each lead-in connection shall be flushed as specified in NFPA 15 24 .
Statement of Problem and Substantiation for Public Input
The addition of NFPA 24 into this section makes the document more consistent with the flushing guidelines
established in the reference for Private Underground Fire Service Mains and is consistent with section 9.14.13.7.
Submitter Information Verification
Submitter Full Name: Doug Hohbein
Organization:
Northcentral Fire Code Develop
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Aug 16 09:52:47 EDT 2012
Committee Statement
Resolution: FR-20-NFPA 409-2013
Statement: The addition of NFPA 24 into this section makes the document more consistent with the flushing
guidelines established in the reference for Private Underground Fire Service Mains and is consistent
with section 9.14.13.7.
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Public Input No. 3-NFPA 409-2012 [ Section No. 6.2.10.9 ]
6.2.10.9* Flushing Underground Pipe.
Underground mains and each lead-in connection shall be flushed as specified in NFPA 15 25 .
Statement of Problem and Substantiation for Public Input
NFPA 25 addresses testing, inspection, and maintenance of water based systems.
Submitter Information Verification
Submitter Full Name: John Chartier
Organization:
Northeastern Regional Fire Cod
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Aug 16 11:25:42 EDT 2012
Committee Statement
Resolution: FR-20-NFPA 409-2013
Statement: The addition of NFPA 24 into this section makes the document more consistent with the flushing
guidelines established in the reference for Private Underground Fire Service Mains and is consistent
with section 9.14.13.7.
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Public Input No. 52-NFPA 409-2013 [ New Section after 7.1 ]
new 7.1.5
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.
Statement of Problem and Substantiation for Public Input
See proposed new 6.1.6 which is PI 51.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:26:28 EDT 2013
Committee Statement
Resolution: FR-42-NFPA 409-2013
Statement: NFPA 11 (2010 edition) 4.7.2.1 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.
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Public Input No. 70-NFPA 409-2013 [ Sections 7.1, 7.2, 7.3, 7.4 ]
7.1
Sections 7.1, 7.2, 7.3, 7.4
7.1 General.
7.1.1
The protection of aircraft storage and servicing areas of Group II aircraft hangars shall be in accordance
with any one of the following:
(1) The provisions of Chapter 6 , unless foam-water deluge systems utilizing air-aspirating discharge
devices are installed for the protection of Group II aircraft hangars, in which case the discharge rate
specified in 6.2.2.12 of this standard is permitted to be reduced to a minimum of 6.5 L/min/m 2
(0.16 gpm/ft 2 ) of floor area
(2) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,
low-level, low-expansion foam system in accordance with Sections 7.3 and 7.4
(3) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,
high-expansion foam system in accordance with Sections 7.3 and 7.5
(4) A closed-head foam-water sprinkler system in accordance with Section 7.6
7.1.2
Group II aircraft hangar storage and service areas housing unfueled aircraft shall be provided with
automatic sprinkler protection as specified in Chapter 12 .
7.1.3
Automatic closed-head sprinkler protection shall be provided inside separate shop, office, and storage
areas located inside aircraft maintenance and servicing areas. The design shall be in accordance with
hazard classifications specified in NFPA 13.
7.1.4
In addition to the provision for sprinkler and foam extinguishing systems as required by this chapter,
protection as required by 6.2.9 and Sections 6.3 and 6.4 also shall be provided.
7.2 Closed-Head Water Sprinkler System for Aircraft Storage and Servicing Areas.
7.2.1 *
Sprinkler systems shall be either wet pipe or preaction, designed and installed in accordance with the
applicable sections of NFPA 13 and the provisions of this chapter.
7.2.2
Sprinkler piping shall be hydraulically sized in accordance with NFPA 13.
7.2.3
Sprinkler spacing shall be as specified in 6.2.2.3 .
7.2.4
Where open hangar doors result in interference with the distribution of water from the hangar sprinkler
systems, additional sprinklers shall be provided to ensure required floor coverage.
7.2.5
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 464.5 m 2 (5000 ft 2 ) area, including the hydraulically most demanding area as defined in NFPA
13.
7.2.6
Sprinklers shall be nominal K-80 (K-5.6) or K-115 (K-8.0) sprinklers.
7.2.7
Sprinklers shall have a temperature rating of 162°C to 190°C (325°F to 375°F).
7.2.8
Sprinkler systems shall be flushed and tested in accordance with NFPA 13.
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7.3 *
Foam Concentrate — General.
The friction losses in piping carrying foam concentrate shall be calculated using the Darcy formula, also
known as the Fanning formula.
7.3.1
The foam concentrate supplied with the system shall be listed for use with the distribution equipment.
7.3.2
There shall be a reserve of foam concentrate of a compatible type directly connected to the system. 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.
7.3.3 Foam Concentrate Pumps.
7.3.3.1
Foam concentrate pump installations shall comply with the applicable provisions of NFPA 20, except as
modified by this standard.
7.3.3.2
Where foam concentrate is introduced into the water stream by pumping, the total foam concentrate
pumping capacity shall be such that the maximum flows and pressures are met with the largest foam
concentrate pump out of service. The reserve pump(s) shall be arranged to operate only upon failure of the
primary pump(s).
7.3.3.3
Piping shall be arranged so that maximum foam concentrate demand is supplied by any foam concentrate
pump from either primary or reserve foam concentrate tanks.
7.3.3.4
Foam concentrate pumps shall be provided with means of pressure relief from the pump discharge to
prevent excessive pressure and temperature. Discharge from the relief valve shall be piped back to the
foam concentrate storage tank. Connection to the suction piping shall not be permitted.
7.3.3.5
The pressure-regulating valve shall not be used as the pressure relief valve. Foam concentrate pumps shall
be started automatically by either a pressure drop in the foam concentrate piping system or a signal from
the detection system control panel.
7.3.3.6
A pressure maintenance pump shall be provided to maintain pressure in the foam concentrate piping
system where foam concentrate lines to the protective system injection points are run underground or
where they run aboveground for more than 15 m (50 ft).
7.3.3.7
Once started, foam concentrate pumps shall be arranged to run continuously until stopped manually. There
shall be an audible “pump running” alarm in a constantly attended location.
7.3.3.8
Power supply for the drivers of foam concentrate pumps shall be installed in accordance with NFPA 20 and
NFPA 70 . Power supplies shall be arranged such that disconnecting power to the protected facility during a
fire shall not disconnect the power supply to the foam concentrate pump feeder circuit.
7.3.3.9
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed fire pump
controller shall be used.
(2) For electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding
22.4 kW (30 horsepower), a listed fire pump controller or listed limited service controller shall be used.
(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited service
controller shall be used.
(4) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.
7.3.4
The control valves, foam–liquid concentrate storage, injection system, and foam concentrate pump shall be
located outside aircraft storage and servicing areas.
7.3.5
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Plans and specifications for closed-head foam-water sprinkler systems shall provide the information
required by 6.2.1 of this standard and NFPA 16. Plans and specifications for other foam extinguishing
systems shall provide the information required by 6.2.1 .
7.3.6 Acceptance Tests.
7.3.6.1
Acceptance tests for closed-head foam-water sprinkler systems shall be performed in accordance with
NFPA 16.
7.3.6.2
Acceptance tests for foam extinguishing systems shall be performed in accordance with 6.2.11.1 ,
6.2.11.2 , 6.2.11.6 , and 6.2.11.8 .
7.3.6.2.1
The systems shall be subjected to flow tests, with foam flowing from the maximum number of foam
distributors expected to operate, in order to ensure that the hangar is protected in conformance with the
design specifications and to determine if the flow pressures, agent discharge capacity, foam coverage, and
percentage of concentration are satisfactory.
7.3.6.2.1.1
A flow test shall be performed with only the foam system operating.
7.3.6.2.1.2
A flow test shall be performed with the foam system operating at the design pressure with the sprinkler
system and hose demand.
7.3.6.3 *
The timing of foam system discharge shall be measured beginning at the time of system actuation.
7.3.7
The installing company shall furnish a written statement to the effect that the work has been completed in
accordance with approved plans and specifications and tested in accordance with the provisions of 7.3.6 .
7.4 *
Low-Expansion Foam System.
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7.4.1
Foam systems shall be of the fixed type and shall be designed and installed in accordance with the
requirements for fixed-type systems in NFPA 11.
7.4.2
The minimum application rate of foam solution shall be 6.5 L/min/m 2 (0.16 gpm/ft 2 ) where protein-based
or fluoroprotein-based concentrate is used. Where AFFF concentrate is used, the minimum application rate
of foam solution shall be 4.1 L/min/m 2 (0.10 gpm/ft 2 ).
7.4.3 *
The discharge rate of the system shall be based on the rate of application multiplied by the entire aircraft
storage and servicing floor area.
7.4.4
The foam system shall use low-level monitor-type discharge nozzles, with individual manual shutoff valves
for each nozzle. The discharge nozzles shall be arranged to achieve initial foam coverage in the expected
aircraft parking area.
7.4.5 *
The quantity of foam concentrate shall be calculated for a 10-minute discharge at the water flow rate based
on the supply calculation method.
7.4.6 The low-level foam system shall be designed to achieve distribution of foam over the entire aircraft
storage and service area. The design objective shall be to achieve coverage of the entire aircraft storage
and servicing area to within 1.5 m (5 ft) of the perimeter walls and doors within 3 minutes of system
actuation.
We propose that subparts (1), (2), (3), and (4) of 7.1.1 be removed and replaced with the following
amendment:
(1) Group II hangars used for storage of aircraft and routine maintenance only shall have an automatic
sprinkler protection system in accordance with Section 7.2, but the hangar shall be exempt from foam
requirements per 412.4.6 of the International Building Code.
(2) Hazardous operations and equipment (doping, hot work, fuel transfer, fuel tank
repair/maintenance, and spray finishing) per International Building Code 412.4.6.1 and
412.4.6.3 is prohibited in Group II hangars without a foam fire suppression system in accordance
with sections 7.3, 7.4, 7.5, and 7.6.
Additional Proposed Changes
File Name
Description
NFPA_Letter_2_.docx
NFPA Ch. 7 proposed changes
Approved
Statement of Problem and Substantiation for Public Input
Group II Hangars would no longer be required to install foam fire suppression systems. See letter attached.
Submitter Information Verification
Submitter Full Name: Will Hickman
Organization:
City of Fort Worth
Affilliation:
Fort Worth Spinks Airport
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Jul 08 15:04:04 EDT 2013
Committee Statement
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Resolution: No new information has been provided to change the protection criteria for Group II hangars.
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Public Input No. 46-NFPA 409-2013 [ Section No. 7.1.1 ]
7.1.1
The protection of aircraft storage and servicing areas of Group II aircraft hangars shall be in accordance
with any one of the following:
(1) The provisions of Chapter 6 , unless foam-water deluge systems utilizing air-aspirating discharge
devices are installed for the protection of Group II aircraft hangars, in which case the discharge rate
specified in 6.2.2.12 of this standard is permitted to be reduced to a minimum of 6.5 L/min/m2 (0.16
gpm/ft2) of floor area
(2) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,
low-level, low-expansion foam system in accordance with Sections 7.3 and 7.4
(3) A combination of automatic sprinkler protection in accordance with Section 7.2 and an automatic,
high-expansion foam system in accordance with Sections 7.3 and 7.5
(4) A closed-head foam-water sprinkler system in accordance with Section 7.6
(5)
A combination of automatic sprinkler protection in accordance with 7.2 and a fuel containment floor
system in accordance with 7.X
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: TRISTAN MACKINTOSH
Organization:
Fireless Flooring
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 05 11:32:36 EDT 2013
Committee Statement
Resolution: The fuel containment floor system technology has not been fully tested.
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Public Input No. 36-NFPA 409-2013 [ Section No. 7.2.5 ]
7.2.5
The 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 464.5 m 2 (5000 ft 2 ) area, including the hydraulically
most demanding area as defined in NFPA 13.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Sat Jun 29 13:24:36 EDT 2013
Committee Statement
Resolution: FR-46-NFPA 409-2013
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.
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Public Input No. 23-NFPA 409-2013 [ Section No. 7.3.3.9 ]
7.3.3.9
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed fire pump
controller shall be used.
(2) For electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding
22.4 kW (30 horsepower), a listed fire pump controller or listed limited service controller shall be
used.
(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited service
controller shall be used.
For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.
(1) Controllers for foam concentrate pumps shall comply with the requirements of section 6.2.7.9.
Additional Proposed Changes
File Name
Description Approved
7.3.3.9.pdf
Cover Sheet
Statement of Problem and Substantiation for Public Input
Foam pumps feed full service controllers and should be no less than full service controllers. Listed full service
controllers are now available in horsepowers down to 1.0 Hp.
Note: At one time, full service controllers were not available below 30 Hp.
Note: Similar proposals have been submitted to NFPA-11 and NFPA-16.
Submitter Information Verification
Submitter Full Name: James Nasby
Organization:
Columbia Engineering
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Feb 26 09:05:04 EST 2013
Committee Statement
Resolution: FR-50-NFPA 409-2013
Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancy
requirements throughout this standard.
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Public Input No. 58-NFPA 409-2013 [ Section No. 7.3.3.9 ]
7.3.3.9
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4 kW (30 horsepower), a listed full
service fire pump controller shall be used.
(2) For
electric-drive foam concentrate pumps greater than 11 kW (15 horsepower) but not exceeding 22.4 kW
(30 horsepower), a listed fire pump controller or listed limited service controller shall be used.
(3) For electric foam concentrate pumps less than 11 kW (15 horsepower), a listed limited service
controller shall be used.
(4) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.
Statement of Problem and Substantiation for Public Input
See proposed change to 6.2.7.10 which is PI 57.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 57-NFPA 409-2013 [Section No. 6.2.7.10]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:48:44 EDT 2013
Committee Statement
Resolution: FR-50-NFPA 409-2013
Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancy
requirements throughout this standard.
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Public Input No. 72-NFPA 409-2013 [ Section No. 7.4.4 ]
7.4.4
The foam system shall use low-level discharge nozzles Where monitor -type discharge nozzles
are used , they shall be provided with individual manual shutoff valves for each nozzle. The discharge
nozzles shall be arranged to achieve initial foam coverage in the expected aircraft parking area.
Statement of Problem and Substantiation for Public Input
This comment is to make 7.4.4 read the same as 6.2.5.4.3. There is no reason to restrict low-level low expansion
foam systems in Group II hangars to be only monitor nozzles, while allowing other foam delivery systems such as
grate nozzles in Group I hangars.
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Jul 08 22:42:14 EDT 2013
Committee Statement
Resolution: FR-21-NFPA 409-2013
Statement: The revision harmonizes 7.4.4 for Group II hangars with 6.2.5.4.3 for Group I hangars.
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Public Input No. 76-NFPA 409-2013 [ Section No. 7.5.4 ]
7.5.4
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 in 6.12.8. 2.3. 5. 2 (b) 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
Description Approved
nfpa409_PI_Kasiski_7-5-4.pdf
Cover Sheet
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Robert Kasiski
Organization:
FM Global
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Jul 11 13:34:07 EDT 2013
Committee Statement
Resolution: There are sufficient safety factors in the existing design criteria to address this concern.
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Public Input No. 61-NFPA 409-2013 [ Section No. 7.5.5 ]
7.5.5
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.
Statement of Problem and Substantiation for Public Input
See proposed revision to 6.2.5.5.5 which is PI 60.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 60-NFPA 409-2013 [Section No. 6.2.5.5.5]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:10:00 EDT 2013
Committee Statement
Resolution: Adequate technical data has not been provided to support the use of inside air.
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Public Input No. 37-NFPA 409-2013 [ Section No. 7.6.2 ]
7.6.2
The Regardless of the celing slope, the minimum discharge density shall be 6.5 L/min/m 2 (0.16 gpm/ft 2 )
of foam solution over the entire storage and service area.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Sat Jun 29 13:26:48 EDT 2013
Committee Statement
Resolution: FR-47-NFPA 409-2013
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.
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Public Input No. 48-NFPA 409-2013 [ New Section after 7.6.7.1 ]
7.X Fuel Containment Floor System.
7.X.1 Hangars protected in accordance with 7.1 (5) shall be protected with a fuel containment floor
system.
7.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.
7.X.3 System floor size
7.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 7.X.3.2
7.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.
7.X.3.2.1 The fuel containment floor system shall consist of a single continuous floor per each
aircraft.
7.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 7.X.3.2
7.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.
7.X.4 Activated water sprinklers as per 7.2 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.
7.X.5 Fuel removal
7.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 5.11.2
7.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
5.11.2.3.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: TRISTAN MACKINTOSH
Organization:
Fireless Flooring
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Jul 05 11:34:47 EDT 2013
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Committee Statement
Resolution: The fuel containment floor system technology has not been fully tested.
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Public Input No. 68-NFPA 409-2013 [ New Section after 7.7 ]
proposed new 7.7.5
Listed detection systems (such as optical flame detection) shall be acceptable in lieu of heat detection if
both approved by the Authority Having Jurisdiction and installed in accordance with NFPA 72.
Statement of Problem and Substantiation for Public Input
See proposed new 6.2.8.1.4 which is PI 67. The purpose of this change is to make it clear than an owner and
AHJ may agree to adopt an alternate detection system without requiring two detection systems.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 67-NFPA 409-2013 [New Section after 6.2.8.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:36:09 EDT 2013
Committee Statement
Resolution: FR-52-NFPA 409-2013
Statement: The purpose of this change is to make it clear than an owner and AHJ may agree to adopt an
alternate detection system without requiring two detection systems.
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Public Input No. 87-NFPA 409-2013 [ Section No. 7.7 ]
7.7 Detection and Actuation Systems.
7.7.1
Detectors for actuating high- or low-expansion foam systems and for actuating preaction sprinkler
systems shall be rate-of-rise, fixed-temperature, or rate-compensation type. deluge and sprinkler
systems at ceiling or roof height, shall be heat detectors or flame detectors.
Detectors and systems for initiating discharge of expanded foam onto a fuel spill or fire shall be flame
detectors configured to actuate foam discharge in less than 10 seconds. Flame detectors shall be arranged
optimize detection of fires at floor level below aircraft fuel tanks at planned aircraft parking areas.
The first detector to operate shall signal alarm, but two detectors shall operate before initiating a foam
discharge. Flame detectors shall be aligned to, and provided in sufficient quantity to ensure proper
coverage in the event of any single detector being out of service. In multiple zone systems sharing a
common water or foam supplies, the first zone to actuate shall prevent later zones from operating to avoid
unnecessary depletion of foam concentrate supplies. Manual controls shall be configured to override this
selection if necessary.
7.7.2
These detectors shall be installed in accordance with NFPA 72 .
7.7.3
Detection systems shall be provided with supervision as required by NFPA 72 .
7.7.4
Manual actuation stations shall be located so that each system can be individually operated from both
inside and outside the aircraft storage and servicing area. The manual stations shall be installed so that
they are unobstructed, readily accessible, and located in the normal paths of exit from the area.
Additional Proposed Changes
File Name
NFPA_409_7.7_Flame_Detectors.docx
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
In high roof buildings like hangars, thermal detection responds fast enough to protect the building structure but too
slowly to deliver effective fire protection to high value property within the hangar at low level such as spare parts
and aircraft.
To meet the fuel spill foam suppression criteria of NFPA 11 fire suppression is required in 2.5 minutes, 30 seconds
to start the foam delivery and 2 minutes to generate a foam blanket of adequate depth to submerge the risk.
Flame detectors can be, and are often allowed to start hangar foam systems using the provisions of NFPA 409 1.3
& 1.4, however many AHJs are reluctant to deviate from the letter of NFPA codes, and in the past some have
simply refused to allow such deviation.
Although it is expected that each zone would have 4 flame detectors, where there are two parking areas sharing a
hangar doorway, with no convenient flame detector mounting available air-side between the two parking areas it is
possible to meet these requirements with 3 flame detectors per parking area.
Note: Supporting material is available for review at NFPA Headquarters.
Submitter Information Verification
Submitter Full Name: RICHARD GILLESPIE
Organization:
FIRE ENGR SOLUTIONS P/L
Street Address:
City:
State:
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Submittal Date:
Fri Jul 12 09:25:35 EDT 2013
Committee Statement
Resolution: This proposal exceeds the level of safety prescribed by this minimum standard. See FR 52 (7.7.5).
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Public Input No. 66-NFPA 409-2013 [ New Section after 7.7.1 ]
proposed new 7.7.1.1
Where wet-pipe sprinkler systems are provided, detection of sprinkler water flow shall be acceptable as the
means of heat detection.
Statement of Problem and Substantiation for Public Input
See proposed new section 6.2.8.4.1 which is PI 65. This is a clarification of the intent of the standard.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 65-NFPA 409-2013 [New Section after 6.2.8.4]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:29:01 EDT 2013
Committee Statement
Resolution: FR-23-NFPA 409-2013
Statement: The section was revised to harmonize with the requirements in Chapter 6 for Group I hangars.
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Public Input No. 25-NFPA 409-2013 [ Section No. 8.7.1 ]
8.7.1*
Grounding facilities shall be provided for removal and control of static electrical accumulations on aircraft
while aircraft are stored or are undergoing servicing in a hangar shall be permitted .
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Donald Cook
Organization:
Shelby County Department of De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Feb 28 15:57:56 EST 2013
Committee Statement
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.
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Public Input No. 27-NFPA 409-2013 [ Section No. 8.7.2 ]
8.7.2
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 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. Floorgrounding receptacles shall be designed to minimize the tripping hazard.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Donald Cook
Organization:
Shelby County Department of De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Feb 28 16:12:45 EST 2013
Committee Statement
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.
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Public Input No. 26-NFPA 409-2013 [ Sections 9.12.1, 9.12.2 ]
Sections 9.12.1, 9.12.2
9.12.1
Membrane-covered rigid-steel-frame-structure hangars housing other than unfilled aircraft shall be
provided with grounding Grounding facilities for the removal and control of static electrical accumulations
on aircraft while aircraft are stored or undergoing servicing in a hangar. membrane-covered rigid-steelframe-structure hangars housing other than unfilled aircraft shall be permitted.
9.12.2
Floor-grounding receptacles shall be provided. The permitted. Where installed, the receptacles 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.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Donald Cook
Organization:
Shelby County Department of De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Feb 28 16:05:13 EST 2013
Committee Statement
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.
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Public Input No. 53-NFPA 409-2013 [ Section No. 9.14.5.3 ]
9.14.5.3
Each 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 .
Statement of Problem and Substantiation for Public Input
See proposed new 6.1.6 which is PI 51.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 51-NFPA 409-2013 [New Section after 6.1.1]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:29:33 EDT 2013
Committee Statement
Resolution: FR-45-NFPA 409-2013
Statement: NFPA 11 (2010 edition) 4.7.2.1 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.
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Public Input No. 77-NFPA 409-2013 [ Section No. 9.14.7.5.3 ]
9.14.7.5.3
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 6.12.8.2. 3. 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_9-14-7-5-3.pdf
Description Approved
Cover Sheet
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Robert Kasiski
Organization:
FM Global
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Jul 11 13:35:44 EDT 2013
Committee Statement
Resolution: There are sufficient safety factors in the existing design criteria to address this concern.
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Public Input No. 62-NFPA 409-2013 [ Section No. 9.14.7.5.5 ]
9.14.7.5.5
Foam generators shall be supplied with air from outside outside 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.
Statement of Problem and Substantiation for Public Input
See proposed revision to 6.2.5.5.5 which is PI 60.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 60-NFPA 409-2013 [Section No. 6.2.5.5.5]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:12:35 EDT 2013
Committee Statement
Resolution: Adequate technical data has not been provided to support the use of inside air.
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Public Input No. 59-NFPA 409-2013 [ Section No. 9.14.9.3 ]
9.14.9.3
Controllers for foam concentrate pumps shall be as follows:
(1) For electric-drive foam concentrate pumps greater than 22.4kW (30 horsepower), a listed full
service fire pump controller shall be used.
(2)
(3) For
electric-drive foam concentrate pumps greater than 11kW (15 horsepower) but not exceeding 22.4kW
(30 horsepower), a listed fire pump controller or listed limited-service controller shall be used.
(4) For electric-drive foam concentrate pumps less than 11kW (15 horsepower), a listed limited-service
controller shall be used.
(5) For diesel engine–drive foam concentrate pumps, a listed fire pump controller shall be used.
Statement of Problem and Substantiation for Public Input
See proposed change to 6.2.7.10 which is PI 57.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 57-NFPA 409-2013 [Section No. 6.2.7.10]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:52:50 EDT 2013
Committee Statement
Resolution: FR-51-NFPA 409-2013
Statement: To allow limited service foam pump controllers is inconsistent with the reliability and redundancy
requirements throughout this standard.
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Public Input No. 64-NFPA 409-2013 [ Section No. 9.14.13.2 ]
9.14.13.2
The total pumping capacity shall be such that maximum demand shall be met with the largest fire pump
out of service. provided using fire pumps of equal capacity. No fewer than two fire pumps shall be
provided.
Statement of Problem and Substantiation for Public Input
See proposed change to 6.2.10.8.2 which is PI 63.
Related Public Comments for This Document
Related Comment
Relationship
Public Input No. 63-NFPA 409-2013 [Section No. 6.2.10.8.2]
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:21:28 EDT 2013
Committee Statement
Resolution: FR-54-NFPA 409-2013
Statement: The "largest fire pump out of service" requirement is a level of redundancy not found in any other
NFPA occupancy standard. NFPA 20 takes considerable care in ensuring fire pump reliability. This
revision relaxes the requirement for water supply redundancy, but does not allow the hangar to be
protected by only a single fire pump. See also CI 53, which proposes an alternative revision for this
section.
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Public Input No. 39-NFPA 409-2013 [ Section No. 10.2.1 ]
10.2.1
The Regardless of the ceiling slope, the protection of aircraft paint hangars shall be in accordance with
either Chapter 6 or Chapter 7 of this standard, whichever is applicable.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Sat Jun 29 13:32:15 EDT 2013
Committee Statement
Resolution: FR-48-NFPA 409-2013
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.
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Public Input No. 69-NFPA 409-2013 [ Chapter 11 [Title Only] ]
Final Acceptance Testing and Periodic Inspection and Testing
Proposal is that a new Chapter be created to put all testing requirements for final acceptance and ongoing
maintenance in one place. Centralizing these requirements will give us an opportunity to eliminate common
sources of confusion and make the standard easier to use. Recommend that a Task Group be formed to
accomplish this.
Statement of Problem and Substantiation for Public Input
Centralizing all testing requirements will eliminate common sources of confusion and make the standard easier to
use.
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 18:56:24 EDT 2013
Committee Statement
Resolution: CI-60-NFPA 409-2013
Statement: This Committee Input proposes to significantly revise Chapter 11. The committee has formed a task
group to better define the inspection and maintenance requirements of fire protection systems in
hangars, since many of these systems are not within the scope of NFPA 25. This proposal is provided
as a baseline to seek public comment on the subject. The section references in the revised table are
based on the following documents: NFPA 25, 2011 Edition; NFPA 11, 2010 Edition; NFPA 72, 2010
Edition; NFPA 80, 2010 Edition; NFPA 90A, 2009 Edition; NFPA 1962, 2008 Edition; NFPA 33, 2007
Edition; Air Force Instruction AFI 32-1065, Grounding Systems, October 1998.
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Public Input No. 38-NFPA 409-2013 [ Section No. 12.5.6 [Excluding any Sub-Sections] ]
The Regardless of the ceiling slope, the design density from sprinkler systems shall be a minimum of 6.9
L/min/m2 (0.17 gpm/ft2) over any 464.5 m2 (5000 ft2) area, including the hydraulically most demanding
area as defined in NFPA 13.
Statement of Problem and Substantiation for Public Input
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 Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Sat Jun 29 13:29:08 EDT 2013
Committee Statement
Resolution: FR-49-NFPA 409-2013
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.
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Public Input No. 2-NFPA 409-2012 [ Section No. A.3.3.2 ]
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A.3.3.2 Aircraft Hangar.
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For overall height of various transport-type aircraft, see Table A.3.3.2. Offices and similar administrative
areas are not considered part of the hangar when properly separated per 5.2.3, 8.2.3 and 9.2.3.
Table A.3.3.2 Gross Wing Area and Overall Height for Selected Aircraft
Gross Wing Area
Aircraft
Airbus A-380*
m2
830.0
ft 2
Overall Height
m
ft–in.
8920
24.1 †
79–0
Antonov An-124*
628.0 †
6760
21.0 †
69–2
Lockheed L-500-Galaxy*
576.0 †
6200
19.8 †
65–1
Boeing 747*
541.1 †
5825
19.4 †
63–8
Airbus A-340-500, -600*
437.0 †
4703
16.7 †
54–11
Boeing 777*
427.8 †
4605
18.5 †
60–9
Ilyushin II-96*
391.6 †
4215
DC-10-20, 30*
367.7 †
3958
17.7 †
58–1
Airbus A-340-200, -300, A-330-200, -300*
361.6 †
3892
16.7 †
54–11
DC-10-10*
358.7 †
3861
17.7 †
58–1
Concorde*
358.2 †
3856
12.2 †
40–0
Boeing MD-11*
339.9 †
3648
17.6 †
57–9
Boeing MD-17*
353.0 †
3800
16.8 †
55–1
L-1011*
321.1 †
3456
16.9 †
55–4
Ilyushin II-76*
300.0 †
3229
14.8 †
48–5
Boeing 767*
283.4 †
3050
15.8 †
52–0
Ilyushun IL-62*
281.5 †
3030
12.3 †
40–6
DC-10 MD-10
272.4
2932
DC-8-63, -73
271.9
2927
DC-8-62, -72
271.8
2926
DC-8-61, 71
267.8
2883
Airbus A-300
260.0 †
2799
16.5 †
54–3
Airbus A-310
218.9 †
2357
15.8 †
51–10
Tupolev TU-154
201.5 †
2169
11.4 †
37–4
Boeing 757
185.2 †
1994
13.5 †
44–6
Tupolev TU-204
182.4 †
1963
13.9 †
45–7
Boeing 727-200
157.9 †
1700
10.4 †
34–0
Lockheed L-100J Hercules
162.1 †
1745
11.6 †
38–3
Yakovlev Yak-42
150.0 †
1614
9.3 †
32–3
Boeing 737-600, -700, -800, -900
125.0 †
1345
12.5 †
43–3
Airbus A-318, A-319, A-320, A-321
122.6 †
1319
11.8 †
38–8
Boeing MD 80
112.3 †
1209
9.0 †
29–7
9.3 †
30–7
7.9 †
25–10
MD 90
Gulfstream V
105.6 †
1137
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Gross Wing Area
m2
Aircraft
ft 2
Overall Height
m
ft–in.
Boeing 737-300, -400, -500
105.4 †
1135
11.1 †
36–6
Tupolev TU-334, TU-354
100.0 †
1076
9.4 †
30–9
BAC 1-11-500
95.8 †
1031
7.5 †
24–6
NAMC YS-11
94.8 †
1020
8.9 †
29–5
Fokker 100, 70
93.5 †
1006
8.5 †
27–10
BAC 1-11-300, -400
93.2
1003
7.5 †
24–6
Boeing 717
93.0 †
1001
8.8 †
29–1
DC-9-30
93.0 †
1001
8.4 †
27–6
Boeing 737-200
91.0 †
980
11.3 †
37–0
Gulfstream IV
88.3 †
950
7.4 †
24–5
DC 9-10
86.8 †
934
8.4 †
27–6
BAe 146, RJX-70, -85, -100
77.3 †
832
8.6 †
28–3
Fokker 50, 60
70.0 †
753
2.7 †
27–3
Canadair RJ-700
68.6 †
738
7.6 †
24–10
Dash 8 Q400
63.0 †
679
7.5 †
24–7
ATR 72
61.0 †
656
7.6 †
25–1
Airtech CN-235
59.1 †
636
8.2 †
26–10
Saab 2000
55.7 †
600
7.7 †
25–4
Canadair RJ-100, -200
54.5 †
587
6.2 †
20–5
ATR 42
42.5 †
586
7.6 †
24–10
Dash 8 Q100, Q200
54.3 †
585
7.5 †
24–7
Embraer ERJ-135, -145
51.1 †
550
6.9 †
22–1
Cessna 750
48.9 †
527
5.8 †
18–11
Cessna 680
47.9 †
516
5.5 †
19–2
Saab 340
41.8 †
450
6.9 †
22–1
Embraer EMB-120
39.4 †
424
6.3 †
20–10
Bell Boeing V-22
39.5 †
382
6.6 †
21–9
Britten-Norman BN2
30.2 †
325
4.2 †
13–8
Cessna 650
28.9 †
312
5.1 †
16–9
Beech 1900
28.8 †
310
4.7 †
15–6
Beech King Air C90
27.3 †
294
4.3 †
14–3
*Aircraft with wing area in excess of 279 m2 (3000 ft2).
†Data from Jane’s All the World's Aircraft.
Statement of Problem and Substantiation for Public Input
Offices separated from aircraft storage and servicing areas should not be held to the strict standard of a hangar
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when fire rated construction is provided. This will allow a two-story office area adjacent to but separated from the
hangar. Section 8.1.2 would seem to prohibit this arrangement.
Submitter Information Verification
Submitter Full Name: Doug Hohbein
Organization:
Northcentral Fire Code Develop
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Aug 16 09:53:57 EDT 2012
Committee Statement
Resolution: CI-61-NFPA 409-2013
Statement: This Committee Input proposes to significantly revise the requirements of Chapter 8. There is
sufficient confusion and uncertainty in the application of the standard to Group III hangars that this
proposal is presented for public review. The concepts of hangar clusters and row hangars tend to
cause confusion. In order to simplify this chapter, the committee is considering whether aircraft
storage and servicing areas that are adequately separated by internal or external partitions should be
considered independently of other nearby spaces and in accordance with the locally adopted building
code. See also CI 62 (3.3.9).
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Public Input No. 50-NFPA 409-2013 [ Section No. A.5.11.2.4 ]
A.5.11.2.4
In general, this means that the design has to be adequate to ensure that the liquid level at the
center of the drain is below the top surface of the drain trench drain inlet grating for grated round,
rectangular, and long trench-type inlets or below the floor surface in the case of a slit trench .
Statement of Problem and Substantiation for Public Input
Appendix material was not updated when trench drains were required. This is an editorial correction.
Submitter Information Verification
Submitter Full Name: Michael Aaron
Organization:
The RJA Group, Inc.
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Jul 07 17:16:19 EDT 2013
Committee Statement
Resolution: FR-25-NFPA 409-2013
Statement: The clarification provided by the annex material is no longer needed.
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