Public Comment No. 24-NFPA 409-2014 (Section No. 5.2.1) : Related Item

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Public Comment No. 24-NFPA 409-2014 [ Section No. 5.2.1 ]
5.2.1 *
Where aircraft storage and servicing areas are subdivided into separate fire areas, the separation shall be
by a fire wall barrier having not less than a 3 2 -hour fire resistance rating. Any openings in such fire walls
barriers communicating directly between two aircraft storage and servicing areas shall be provided with a
listed 3 2 -hour fire door or 3 2 -hour shutter actuated from both sides of the wall. Where areas are of
different heights, the tallest wall shall have a fire resistance rating of not less than 3 than 2 hours.
Statement of Problem and Substantiation for Public Comment
NFPA's Building Code Development Committee (BCDC) supports Committee Input #29. A fire barrier of 2 hour
rating is an adequate separation. Fire wall are over kill. To provide the structural protection necessary for a fire
wall would be nearly impossible considering the clear span trusses being utilized in these facilities.
Related Item
Committee Input No. 29-NFPA 409-2013 [Section No. 5.2.1]
Submitter Information Verification
Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, Washington
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 15 14:48:41 EDT 2014
3 of 35 6/24/2014 9:07 AM
Public Comment No. 27-NFPA 409-2014 [ Section No. 5.9.6 [Excluding any
Sub-Sections] ]
Because entry of fuel, oil, and water into landing gear pits is inevitable, drainage , an active flooring system
, or pumping facilities shall be provided.
An active flooring system is an alternative to drainage or pumping system to contain flammable liquid in landing
gear pits, so guidance should be given in the code.
Related Item
Public Input No. 45-NFPA 409-2013 [New Section after 6.2.7.10]
Submitter Full Name: TRISTAN MACKINTOSH

Organization: FIRELESS FLOORING
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 16 10:04:10 EDT 2014
4 of 35 6/24/2014 9:07 AM
Public Comment No. 29-NFPA 409-2014 [ New Section after 5.9.6.3 ]
5.9.6.4 ....Where active flooring systems are used they shall be designed, installed, and maintained
in accordance to the manufacturer’s instructions and be listed for the purpose.
Where active flooring systems are used they shall be designed, installed, and maintained in accordance to the
manufacturer’s instructions and be listed for the purpose.
Related Item

Street Address:
City:
State:
Zip:
5 of 35 6/24/2014 9:07 AM
Public Comment No. 38-NFPA 409-2014 [ Section No. 5.11.2.1 ]
5.11.2.1
In aircraft storage and servicing areas of hangars, floor trench drainage in accordance with 5.11.2.2
through 5.11.2.12 or a approved active flooring system in accordance with 5.11.2.2 through 5.11.2.12 and the
manufacturer's instructions shall be provided.
Specific manufacturer's instructions could be applicable for active flooring systems

Related Item

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6 of 35 6/24/2014 9:07 AM
6.1.1
The protection of aircraft storage and servicing areas for Group I hangars shall be in accordance wtih any
one of the following:
(1) See text from 2011 edition
6.1.2
Group I aircraft hangar storage and service areas housing unfueled aircraft shall be provided with
protection in accordance with 6.1.1 or with automatic sprinkler protection as specified in Chapter 12.
Where the provisions of Chapter 12 are used, no provisions of Chapter 6 are required.
There are two changes being proposed here. The first is to return section 6.1.1 with its three subsections to the
text of the 2011 edition. No First Revision was recorded to delete existing section 6.1.1 and its subsections, but
they do not appear in the first draft language on the website.
Second, the additional sentence has been suggested to clear up the protection requirements for unfueled aircraft.
There is a great deal of confusion in the field as to whether the committee intends to also require the provisions of
Chapter 6 when the user has chosen to protect an hangar for unfueled aircraft in accordance with Chapter 12. Of
particular concern is section 6.2.10.8.2, which requires an extra fire pump. Some AHJ's are enforcing this section
for hangars designed for unfueled aircraft that are protected in accordance with Chapter 12 even though Chapter
12 does not have similar language. Explicit instructions not to use Chapter 6 if Chapter 12 is followed would be
extremely helpful to the users of NFPA 409.
Related Item
Public Input No. 47-NFPA 409-2013 [Section No. 6.1.1]
Submitter Full Name: Kenneth Isman

Organization: National Fire Sprinkler Association
Affilliation: NFSA Engineering and Standards Committee
Street Address:
City:
State:
Zip:
7 of 35 6/24/2014 9:07 AM
6.1.7
Foam solution piping shall be permitted to be black steel meeting the requirements of NFPA 13.
The NFPA-11 Technical Committee respectfully requests the NFPA-409 Technical Committee reconsider the
decision to permit the use of black steel pipe for foam solution lines used in foam systems that are dry and/or open
to atmosphere. This will allow for alignment of the discharge piping requirements of foam systems between the
two standards.
NFPA-409 only requires operational flow testing of foam systems every 5 years. In the case of AFFF deluge
sprinkler systems that testing is typically done by discharging through a test header with no flow through the
sprinkler discharge piping network. As such there is no easy way to flush corrosion debris that may have formed
in the foam solution piping since installation. In fact, there is no follow up water discharge testing for aircraft
hangar AFFF deluge sprinkler systems that determines whether sprinkler piping and/or deluge sprinklers may be
obstructed. High expansion foam systems are typically discharged with water through the foam generators to
confirm proper operation of the water motor that drives the fan.
Based upon experience of members of the NFPA-11 Technical Committee that service and test deluge sprinkler
and high expansion foam systems it is clear that internal pipe scale and corrosion can cause systems failures due
to obstruction of the piping and discharge outlets. Foam solution piping in aircraft hangar systems is subject to
wide temperature and humidity fluctuations that create condensation that promotes internal corrosion of black
steel pipe over time. This problem is more pronounced in hangars located in high humidity areas near the coasts
and islands where the air can contain salt. Water remaining in the system piping from system commissioning tests
will also cause corrosion over time. In some aircraft hangars corrosion of black steel foam solution sprinkler piping
has been severe enough to warrant replacement due to leaks and concern about pipe integrity.
A series nine of photos (attached) illustrate the problems discovered in black steel foam solution piping as the
systems were being inspected and tested. Not all of the pictures directly relate to aircraft hangar system foam
solution piping but they indicate the same problems that can be experienced in aircraft hangar foam systems.
A technical article by FM Global and published in Sprinkler Age magazine (February 2013, Vol 32/02, page 22)
states that bare black steel pipe is not suitable for dry or pre-action systems due to high volume of corrosion that
can obstruct piping and sprinklers. The article also concludes that galvanized pipe may not eliminate corrosion but
it is the best option and has served the industry well.
Based on the field problems experienced with dry and/or deluge type foam systems installed with black steel foam
solution piping the NFPA-11 Technical Committee urges the use of galvanized pipe for aircraft hangar foam
systems where the internal foam solution pipe surfaces are exposed to atmosphere.
Note: Supporting material is available for review at NFPA Headquarters.

Related Item
First Revision No. 13-NFPA 409-2013 [New Section after 6.1.1]
Submitter Full Name: TC on FOM-AAA

Organization: TC on Foam
Street Address:
City:
State:
Zip:
8 of 35 6/24/2014 9:07 AM
6.1.7
Foam solution piping shall be permitted to be black steel meeting be any ferrous material meeting the
requirements of NFPA 13.
NFPA's Building Code Development Committee (BCDC) believes NFPA 13 addresses the type of ferrous piping
materials that are allowed. Black steel is a ferrous material, and ferrous materials should be referenced to NFPA
13. This revision simplifies the intent of the provision.
Related Item

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9 of 35 6/24/2014 9:07 AM
6.1.7
Foam solution piping shall be permitted to be black steel meeting the requirements of NFPA 13.
No technical data or information was presented by the NFPA 409 Technical Committee to substantiate the use of
black steel pipe for foam solution (99%, 98%, 97%, or 94% water) in place of galvanized pipe. This new Section
6.1.7 would supersede the requirements of NFPA 11 and/or NFPA 16. NFPA 11 is in the current Fall 2014 revision
cycle, with Section 4.7 - Piping (SR # 12) being completely revised, including differentiating the piping
requirements between foam concentrate and foam solution. If adopted, this Second Draft Revision of NFPA 11
(which passed ballot by the Technical Committee) will also allow for the usage of black steel pipe when the
discharge devices are closed to the atmosphere.
To substantiate the usage of galvanized pipe, even for indoor systems (e.g. aircraft hangars), Steel Pipe Material
Corrosion, an article authored by Paul Su and David Fuller of FM Global in Sprinkler Age (February 2013, Vol.
32/02, p22), concludes that “bare/black steel should not be used in a dry or pre-action system due to the high
volume of corrosion
products that can obstruct piping and sprinklers”. It also concludes “galvanized pipe does not eliminate corrosion
but is the best option and has served the industry well.” Below is a hyperlink to Sprinkler Age, February 2013 for
review of the article by Technical Committee members. (Hyperlink to Sprinkler Age, February 2013:
http://digital.turn-page.com/i/109066).
Related Item
Submitter Full Name: Matthew Daelhousen

Organization: FM Global
Street Address:
City:
State:
Zip:
10 of 35 6/24/2014 9:07 AM
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
(1) 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.
This public comment is to reject FR No. 16 and return to language of previous edition. Limited service controllers
are specifically designed for small horsepower motors. The reliability of limited service controllers is improved
because NFPA 20 requires the same type of circuit breaker in a limited service controller as in a full service
controller. The option of controller type should be left to the design professional utilizing the requirements of NFPA
20.
Related Item
First Revision No. 16-NFPA 409-2013 [Section No. 6.2.7.10]
Submitter Full Name: Roland Asp

Organization: National Fire Sprinkler Association
Affilliation: NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date: Mon May 12 11:50:14 EDT 2014
11 of 35 6/24/2014 9:07 AM
6.2.10.8 Fire Pumps.

6.2.10.8.1
Fire pumps shall be installed in accordance with NFPA 20 and in accordance with the provisions of
6.2.10.8.2 through 6.2.10.8.6 .
A. 6.2.10.8 .2
The total pumping capacity shall be provided using fire pumps of equal capacity should be such that the
maximum demand is met with the largest fire pump out of service .
6.2.10.8. 3
No fewer than two fire pumps shall be provided.
6.2.10.8. 4
Pump houses and rooms shall be of fire-resistive or noncombustible construction. Where internal
combustion engines used for driving fire pumps are located inside the fire pump house or room, protection
shall be provided by automatic sprinklers installed in accordance with NFPA 13.
6.2.10.8.5 *
Fire pumps shall be started automatically by either a drop in water pressure or a signal from the detection
control panel. Where two or more fire pumps are used, they shall be provided with automatic sequential
starting.
6.2.10.8.6
Where pressure is used as the starting sequence for fire pumps, a small auxiliary pressure maintenance
pump or other suitable means to maintain normal system pressures shall be provided.
6.2.10.8.7
Once started, fire pumps shall be arranged to run continuously until they are stopped manually. There shall
be an audible “pump running” alarm in a constantly attended area.
NFPA's Building Code Development Committee (BCDC) is opposed to this First Revision and supports Committee
Input #40. This First Revision would require two fire pumps which is overkill. There is no substantial evidence that
this redundancy is necessary due to reliability problems with fire pumps. We agree that NFPA 20 takes
considerable care in ensuring fire pump reliability.
Related Item
First Revision No. 41-NFPA 409-2013 [Section No. 6.2.10.8.2]
Committee Input No. 40-NFPA 409-2013 [Section No. 6.2.10.8.2]

Street Address:
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Public Comment No. 19-NFPA 409-2014 [ Sections 6.2.11.4, 6.2.11.5, 6.2.11.6, 6.2.11.7 ]
Sections 6.2.11.4, 6.2.11.5, 6.2.11.6, 6.2.11.7

6.2.11.4
The smallest single foam-water deluge system shall be discharged using foam concentrate or a suitable
alternative test liquid . This test shall be run for a length of time to stabilize discharge before test samples
are taken to determine foam concentrate percentage, or before readings of flow rates in the concentrate
supply pipes and the water supply pipes are captured for the purpose of calculating the foam concentrate
percentage .
6.2.11.5
The maximum number of systems expected to operate shall be simultaneously discharged with foam, or
with a mixture of water and alternative test liquid . This test shall be run for a length of time to stabilize
discharge before test samples are taken to determine foam concentrate percentage, or
before readings of flow rates in the concentrate supply pipes and the water supply pipes are captured for
the purpose of calculating the foam concentrate percentage ..
6.2.11.6
Any proportioner not tested under the requirements of 6.2.11.4 or 6.2.11.5 shall be individually tested with
foam concentrate to , or with an alternative test liquid, to determine concentrate percentage.
6.2.11.7
Supplementary and low-level protection systems shall be subjected to foam flow tests, with foam, or with a
mixture of water and alternative test liquid, flowing simultaneously from the maximum number of sprinkler
systems expected to operate, in order to ensure that the hazard is protected in conformance with the
design specification and to determine whether the flow pressures, agent discharge capacity, foam
coverage, percent concentration, and other operating characteristics are satisfactory.
6.2.11.7.1
Where separate proportioning systems are utilized for the foam-water deluge sprinklers and the
supplementary protection systems, water only shall be permitted to be flowed in the foam-water deluge
sprinkler systems simultaneously with foam, or with a mixture of water and alternative test liquid, in the
supplementary protection system.
Please see problem statement under related comment #21.
Related Public Comments for This Document
Related Comment Relationship

Public Comment No. 21-NFPA 409-2014 [New Comments #19, #20 and #21 are all related to alternative
Section after A.6.2.10.9] methods of testing the system.
Related Item
Public Input No. 78-NFPA 409-2013 [New Section after 3.3.17]
Submitter Full Name: KAARE HOLM

Organization: NOFOAM SYSTEMS
Affilliation: NAVFAC licensee
Street Address:
City:
State:
Zip:
Submittal Date: Wed May 14 19:44:59 EDT 2014
13 of 35 6/24/2014 9:07 AM

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National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Comment No. 24-NFPA 409-2014 [ Section No. 5.2.1 ]

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Jim Muir

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Public Comment No. 29-NFPA 409-2014 [ New Section after 5.9.6.3 ]

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Public Comment No. 38-NFPA 409-2014 [ Section No. 5.11.2.1 ]

Statement of Problem and Substantiation for Public Comment

Specific manufacturer's instructions could be applicable for active flooring systems

Submitter Information Verification

Submitter Full Name: TRISTAN MACKINTOSH

Public Comment No. 32-NFPA 409-2014 [ Section No. 6.1.1 ]

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Kenneth Isman

Public Comment No. 22-NFPA 409-2014 [ Section No. 6.1.7 ]

Statement of Problem and Substantiation for Public Comment

Note: Supporting material is available for review at NFPA Headquarters.

Submitter Information Verification

Submitter Full Name: TC on FOM-AAA

Public Comment No. 25-NFPA 409-2014 [ Section No. 6.1.7 ]

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Jim Muir

Public Comment No. 7-NFPA 409-2014 [ Section No. 6.1.7 ]

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Matthew Daelhousen

Public Comment No. 10-NFPA 409-2014 [ Section No. 6.2.7.10 ]

(1) electric foam pump controller shall be used.

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Roland Asp

Public Comment No. 34-NFPA 409-2014 [ Section No. 6.2.10.8 ]

6.2.10.8 Fire Pumps.

Statement of Problem and Substantiation for Public Comment

Submitter Information Verification

Submitter Full Name: Jim Muir

Sections 6.2.11.4, 6.2.11.5, 6.2.11.6, 6.2.11.7

Statement of Problem and Substantiation for Public Comment

Please see problem statement under related comment #21.

Related Public Comments for This Document

Related Comment Relationship

Submitter Information Verification

Submitter Full Name: KAARE HOLM

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