Technical Committee on Gaseous Fire Extinguishing Systems · The standards documents are currently...

Technical Committee on Gaseous Fire Extinguishing Systems

M E M O R A N D U M

DATE: March 4, 2010 TO: Principal and Alternate Members of the Technical Committee on Gaseous

Fire Extinguishing Systems FROM: Jonathan Levin, Associate Fire Protection Engineer/NFPA Staff Liaison SUBJECT: AGENDA PACKAGE – NFPA 12/2001 F2010 ROC Meeting ________________________________________________________________________ Enclosed is the agenda for the Report on Comments (ROC) meeting for NFPA 12,

Standard on Carbon Dioxide Extinguishing Systems, and NFPA 2001, Standard on Clean

Agent Fire Extinguishing Systems. It is imperative that you review the comments in

advance, with your ideas and substantiations for your views. If you have alternate

suggestions for text changes, please come prepared with the words and respective

substantiation. Feel free to contact Patti Mucci for administrative questions at (617) 984-

7948, or me for technical questions at (617) 984-7245. You can also reach me via e-mail at

[email protected]. I look forward to meeting everyone in Tampa, FL at the Hilton Tampa

Airport Westshore.

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Table of Contents

Meeting Agenda

3

Committee Address List

4

Committee Distribution

11

F2010 ROP Meeting Minutes

13

F2010 Key Dates

18

Staff Liaison Notice

19

Public Comments 26

2

Technical Committee on Gaseous Fire Extinguishing Systems

ROC Meeting March 23 – 24, 2010 8:00 am – 5:00 pm

Hilton Tampa Airport Westshore 2225 North Lois Avenue Tampa, FL 33607-2355

(813) 877-6688

AGENDA

Tuesday, March 23, 2010

1. Call to Order – 8:00 AM 2. Introductions 3. Proposed Agenda 4. Committee Member Status and Update of Membership Roster 5. Approval of F2010 ROP Meeting Minutes 6. Chairman Comments 7. NFPA Staff Liaison Presentation and Review of Key Dates in A2011 Cycle 8. Act on NFPA 12 Public Comments 9. Act of NFPA 2001 Public Comments 10. Adjourn Meeting – 5:00 PM

Wednesday, March 24, 2010

1. Call to Order – 8:00 AM 2. Complete action on NFPA 2001 Public Comments if Applicable 3. Generate Committee Proposals 4. Discuss Old Business 5. Discuss New Business 6. Adjourn Meeting – 12:00 PM

3

3/4/2010

Gaseous Fire Extinguishing SystemsGFE-AAAName Representation Class Office

Distribution by %

Company

Douglas J. Barylski US Department of the Navy E Principal

Suzanne E. Hemann US Coast Guard E Principal

Bella A. Maranion US Environmental Protection Agency E Principal

Louise C. Speitel US Federal Aviation Administration E Principal

Fred K. Walker US Department of the Air Force E Principal

5Voting Number Percent 17%

Ronald C. Adcock Marsh USA Inc. MARSH I Principal

John E. Dellogono Liberty Mutual Property PCIAA I Principal

Todd A. Dillon XL Global Asset Protection Services XLGAPS I Principal

Robert Kasiski FM Global FM I Principal


Robert H. Kelly Fire Defense Equipment Company,Inc.

FSSA IM Principal

James L. Kidd The Hiller Companies IM Principal

Norbert W. Makowka National Association of FireEquipment Distributors

NAFED IM Principal


Maurizio Barbuzzi North American Fire GuardianTechnology, Inc.

M Principal

William A. Eckholm Firetrace International M Principal

Dale R. Edlbeck Tyco Safety Products/Ansul Inc. TYCO M Principal

Robert G. Richard Honeywell, Inc. M Principal

Paul E. Rivers 3M Fire Protection M Principal

Mark L. Robin DuPont Fluoroproducts M Principal

Joseph A. Senecal UTC/Kidde-Fenwal, Inc. UTC M Principal

Brad T. Stilwell Fike Corporation M Principal


Gregory T. Linteris National Institute of Standards &Technology

RT Principal

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Thursday, March 4, 2010

Gaseous Fire Extinguishing SystemsGFE-AAAName Representation Class Office

Distribution by %

Company

Blake M. Shugarman Underwriters Laboratories Inc. UL RT Principal


Jeffrey L. Harrington Harrington Group, Inc. SE Chair

Philip J. DiNenno Hughes Associates, Inc. SE Principal

Paul F. Helweg, Jr. Global Risk Consultants Corporation SE Principal

Robert T. Wickham Wickham Associates SE Principal

Thomas J. Wysocki Guardian Services, Inc. SE Principal


Don A. Enslow BP Exploration (Alaska), Inc. U Principal

William A. Froh US Department of Energy U Principal


29Total Voting Number

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NFPA 12/2001 Technical Committee Meeting September 22-24, 2009

Orlando, Florida Meeting Minutes (draft)

The meeting was opened at 8:30 AM on Tuesday September 22, 2009 with an introduction from Committee Chairman, Jeff Harrington along with NFPA liaison Rich Bielen. The standards documents are currently in the Fall 2010 cycle. The document and comment timelines are presented below. Committee members and guests introduced themselves. This was followed by a motion to approve the minutes from the October 12, 2006 meeting. The motion was accepted.

NFPA 12 Log #1 – A motion to Accept-in-Principle was made and, following discussion regarding revising the wording to “notification appliances” to be consistent with NFPA 71, passed. Log # 3 – A motion to Accept was made and, following discussion, passed. Log # 5 – A motion to Accept-in-Principle was made and, following discussion, was rescinded and modified to a motion to Reject. The reasoning was that the committee believed that a single checklist format did not adequately address all variables with CO2 system acceptance testing. The log was Rejected. Subsequently, the committee proposed action to require that documentation of the CO2 system acceptance testing shall be submitted. The discussion concerned similar ideas to Log # 5 in that the AHJ already determines the adequate documentation. By a vote of 8 – 10 the motion was Rejected. This resulted in no committee proposal. Log # 2 – A motion to Accept was made and passed. Committee Proposal CP-1 – A motion was made to revise the flooding factors shown in 5-3.3(b) due to typographical errors and this was Accepted.

NFPA 2001 Log # 6 – A motion to Accept-in-Principle was made and passed. Log # 7 – A motion to Reject was made and passed. The extinguishing agent data is not yet available for inclusion in the Standard. Log # 8 – See action on Log # 7. Log # 9 – See action on Log # 7.

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Log # 10 – See action on Log # 7. Log # 11 – See action on Log # 7. Log # 43 – A motion to Accept was made and passed. Log # 2 – A presentation from a representative of FirePass was made to the committee. Following the presentation a motion to Reject was made and passed. The data is not in a format or sufficient detail to include in the Standard at this time. Log # CP-8 – A committee proposal was made to clarify that any clean agent in the Standard shall be EPA SNAP approved. The motion passed. Log # 31 – A motion to Reject was made and passed. See action on CP-2. Log # 29 – A motion to Accept-in-Principle was made and passed. Discussion involved inclusion of both Ozone Depletion Potential (ODP) and Global Warming Potential (GWP) for all agents in a table in the Annex. Log # 16 – A motion to Accept was made and passed. Log # CP-10 – A committee proposal was made to include the definition of “Adjusted Minimum Design Concentration”. Following discussion the motion was Accepted. Log # CP-11 – A committee proposal was made to include the definition of “Final Design Concentration”. Following discussion the motion was Accepted. Log # 21 – A motion to Accept was made and passed. Log # 42 – A motion to Accept was made and passed. Log # 17 – A motion to Accept was made and passed. Log # 19 – A motion to Reject was made and passed. The committee believes that the technology for air sampling allows several levels of alarm notification and no rationale is presented for excluding these detection devices. Log # 20 – A motion to Reject was made and passed. The committee believes the proposal addresses a human health issue which is adequately addressed in the Standard in multiple sections. Log # 3 – A motion to Accept-in-Part was made and passed. Section 4.3.3.6 remains the same and revision of 4.3.3.6.2. Log # 4 – Initial motion to Accept was passed by vote of 11-7. Following committee action on other Logs the proposal was re-visited and an amended motion to Accept-in-Principle was made and passed. The committee believes that removal of the actuating device shall result in a system supervisory alarm. This is similar to water based systems that have supervision of sprinkler control valves which would impair the system if closed.

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Log # 18 – A motion to Accept-in-Principle was made and passed. The concept of a disconnect device was accepted with revision to the proposed wording. Log # 5 – A motion to Accept-in-Principle-in-Part was made and passed. The committee believes that protecting the raised floor space is needed, but some wording of the proposal was deleted. Log # 32 – A motion to Reject was made and passed. The proposal would connect the Class A extinguishing concentration to a Class B extinguishing concentration and remove the test method associated with Class A minimum extinguishing concentration. Log # 30 – A motion to Accept was made and passed. There was much discussion regarding the current Class A minimum extinguishing concentration and the Class A design concentration. Topics included the current ISO standards, the UL test criteria and the current minimum extinguishing concentrations. The committee believes an increase of 30% of the Class A minimum extinguishing concentration is necessary. Log # CP-4 – A committee proposal was made to revise 5.4.2.3 based on the action taken on Log # 30. The motion to Accept was passed. Log # CP-2 – A committee proposal was made to revise 5.4.2.5.1 to require a design concentration for Class C hazards of 1.6 times the Class A minimum extinguishing concentration. There was much discussion regarding the current Class C design concentration requirements along with ISO requirements and published test reports regarding extinguishment of energized electrical equipment. The proposal was Accepted. A committee Task Group comprised of Joe Senecal, Tom Wysocki, Phil DeNenno, Paul Rivers, Bob Kasiski, and Mark Robin worked to craft the proposed wording and present the compilation of data. Log # 33 – A motion to Reject was made and passed. See action on Log CP-2. Log # 28 – A motion to Accept-in-Principle was made and passed. The committee supports the use of clean agents in applications where the successful use is demonstrated by actual test results. Log # 26 – A motion to Reject was made and passed. Discussion involved the potential reduction in the conservative application for certain agents in particular conditions. Log CP-5 – A committee proposal was made to require that 85% of the minimum design concentration be held for 10 minutes at the highest point of combustibles within an enclosure to allow for response by trained personnel. The committee emphasizes that the minimum design concentration is different than the final design concentration, which may be higher due to enclosure physical conditions. The motion passed. Log # 23 – A motion to Accept-in-Principle was made and passed. See action on Log # 24. Log # 24 – A motion to Accept-in-Principle was made and passed. Discussion involved allowing longer time for an inert gas agent to achieve 95% of the minimum design concentration. The committee believes this could result in reduction of some system materials. The current test criteria establishes a 60-second time limit and this proposal

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allows for testing to determine the successful application at greater times to achieve the required concentration. Log CP-6 – A committee proposal was made to require a periodic visual inspection of the enclosure integrity to determine whether physical conditions changed which could lead to failure for extinguishment. The motion passed. Log # 41 – A motion to Accept was made and passed. Log # 22 – A motion to Accept was made and passed. Log # CP-7 – A committee proposal was made to add clarification regarding the specified pressure limit which is lower than an enclosure pressure limit. The motion passed. Log # 12 – A motion to Accept was made and passed. Log # 25 – A motion to Reject was made and passed. Refer to committee action on Class C design concentration in CP-2. Log # CP-3 – A committee proposal was made to include Annex information regarding smoldering and deep seated Class A fires for additional support of Log # 28. The motion passed. Log # 14 – A motion to Accept-in-Principle was made and passed. The action deleted the “plus” and “minus” tolerance values. Log # CP-12 – A committee proposal was made to delete the word “superheated” from certain tables in the Annex as the terminology is incorrect for some and unnecessary for other tables. The motion passed. Log # 40 – A motion to Reject was made and passed. The technical data in the Standard is accurate and the terminology for “superheated” removed by the action on CP-12. Log # 44 – A motion to Reject was made and passed. See action on Log # 40. Log # 39 – A motion to Reject was made and passed. See action on Log # 40. Log # 34 – A motion to Reject was made and passed. See action on Log # 40 Log # 35 – A motion to Reject was made and passed. See action on Log # 40. Log # 36 – A motion to Reject was made and passed. See action on Log # 40. Log # 37 – A motion to Reject was made and passed. See action on Log # 25. Log # CP-13 – A committee proposal was made to delete the Annex material based on action regarding Log # 25. The motion passed. Log # 13 – A motion to Accept was made and passed.

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Log # 38 – A motion to Reject was made and passed. See action on Log # CP-9. Log # CP-9 – A committee proposal was made to revise the Annex C material as shown. Considerable effort was undertaken by Mr. Colin Genge to review the Annex C material and present to the committee the detailed revision suggestions. A Task Group comprised of Jeff Harrington, Tom Wysocki, Don Enslow, Phil DeNenno, Colin Genge, and Joe Senecal assisted with the review of the suggested revisions. The motion was passed. Log # 27 – A motion to Reject was made and passed. The committee believes the suggested material has not been peer reviewed and supported by further data at this time. Log # 15 – A motion to Accept was made and passed. The meeting was adjourned at 11:45 AM on September 24, 2009. Respectfully submitted: Ronald Adcock

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NFPA 12/2001 Revision Cycle

Fall 2010

Proposal Closing May 29, 2009

Final date for ROP Meeting August 28, 2009

Ballots Mailed to TC before September 18, 2009

ROP Published December 28, 2009

Comment Closing March 5, 2010

Final Date for ROC Meeting May 7, 2010

Ballots Mailed to TC before May 21, 2010

ROC Published August 27, 2010

Intent to Make a Motion Closing (NITMAM) October 22, 2010

Issuance of Consent Document (No NITMAMs) December 14, 2010

NFPA Annual Meeting Boston, MA June 2011

Issuance of Document with NITMAM August 11, 2011

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Note from the Staff Liaison

Dear Committee Members:

We are very pleased that you will be participating in the processing of the 2011 Edition

of NFPA 12 and NFPA 2001. Development of the Standard would not be possible

without the participation of volunteers like you.

Materials You Will Need to Have for the Committee Meeting

2008 Edition of NFPA 12 and NFPA 2001

Agenda with all attachments

Committee Officers' Guide (Chairs)

Roberts’ Rules of Order (Chairs – abbreviated version may be found in the Committee

Officer’s Guide)

"Nice to Have" Materials

NFPA Annual Directory

NFPA Manual of Style

Prepared Committee Comments (If applicable)

Preparation

Prepared actions and statements will clarify your position and provide the committee with

a starting point. Prepared actions and statements really help expedite the progress of the

meeting.

Getting Things Done

Comments

Only one posting of comments will be made; it will be arranged in section/order and will

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trouble accessing the website please contact Joanne Goyette at [email protected].

Please bring the comments to the committee meeting.

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The processing schedule to be followed by the committee is outlined in the schedule in

this package. As the schedule is very tight, no extensions of the deadline for receipt of

completed ballots or extensions of the period to change vote will be possible.

It is therefore suggested that those of you who must consult with others regarding your

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All actions at and following the committee meetings will be governed in accordance with

the NFPA Regulations Governing Committee Projects. The latest Regulations (as of this

printing) appear on pages 10-28 of the 2010NFPA Directory.

All committee actions will be in accordance with the NFPA Regulations Governing

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Consequently, committee's must follow the regulations and procedures.

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The following are the actions permitted by the Regulations Governing Committee

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Accept - The committee accepts the comment exactly as written. Only editorial

changes such as paragraph and section numbering, and corrections to spelling,

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If a comment is accepted without a change of any kind, except for editorial changes, the

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accepted in principle or accepted in principle in part. A complete reason for rejection of

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Accept in Principle in Part - This is a combination of "Accept in Principle"

and "Accept in Part" as shown above.

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Hold – Comments can be held and processed as a proposal during the next revision

cycle provided that one of the following conditions is met:

(a) The comment introduces a concept that has not had public review by being

included in a related proposal as published in the Report on Proposals.

(b) The comment would change the text proposed by the TC to the point that the TC

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(c) The comment would propose something that could not be properly handled within

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Any comment that is "Accepted in Principle", "Accepted in Part", "Accepted in Principle

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If the rejection or change was for the same reason that another comment was rejected or

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When the committee develops a committee action for a comment that is accepted in

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NFPA Committee Meetings are conducted in accordance with Roberts' Rules of Order.

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Member

• Member Addresses the Chair

• Receives Recognition from the Chair

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• (Another Member) Seconds the Motion.

Chair (Presiding Officer)

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It is imperative that you review the comments before the meeting and develop proposed

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and provide the committee with a starting point. Prepared actions and statements really

help expedite the progress of the meeting.

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Either fax or mail your ballot - Please do not do both. Don't return the entire package; just

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Alternate Members

At the end of each code cycle, the Standards Council reviews records of all members

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General Procedures for Meetings

• Use of tape recorders or other means capable of producing verbatim transcriptions

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• Note to Special Experts: Particular attention is called to Section 3.3(e) of the

NFPA Guide for the Conduct of Participants in the NFPA Codes and Standards

Development Process in the NFPA Directory that directs committee members to

declare their interest representation if it is other than their official designation as

shown on the committee roster, such as when a special expert is retained and

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represents another interest category on a particular subject. If such a situation

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other matter relating to those issues.

• Smoking is not permitted at NFPA Committee Meetings.

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Report on Comments – November 2010 NFPA 2001_______________________________________________________________________________________________2001- Log #2

_______________________________________________________________________________________________Dale R. Edlbeck, Tyco Fire Suppression & Building Products

2001-8Change the GWP value for IG-541 in table A.1.6 to 0.

No technical justification was presented for setting the IG-541 GWP value in table A.1.6 at 0.1.The reference document, Climate Change 2007: The Physical Science Basis Contribution of Working Group 1 to the

Fourth Assessment Report of the Intergovernmental Panel on Climate Change, Table 2.14 covers substances controlledby the Montreal Protocol, Hydrofluorocarbons, Perfluorinated compounds, Fluorinated ethers, Perfluoropolyethers andHydrocarbons and other compounds, no reference is given to inert gases and specifically IG-541.The United Nations Environmental Programme (UNEP), Halon Technical Options Committee, Technical Note #1

Revision 3 lists the GWP value for IG-541 as 0.We are not aware of any agency that lists a GWP of 0.1 for IG-541.

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

_______________________________________________________________________________________________2001- Log #21

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

2001-103.3.x* Adjusted Minimum Design Concentration (AMDC). The target minimum design concentration

after the Safety Factor and the Design Factors have been taken into account. This term is also referred to as simplyDesign Concentration throughout this document. In determining the Duration of Protection (5.6) it is 85 percent of theAMDC that must be held for the duration of the retention time.A.3.3.x This term is also referred to as simply Design Concentration throughout this document. In determining the

Duration of Protection (5.6) it is 85 percent of the AMDC that must be held for the duration of the retention time.NFPA terminology format requires that definitions need to be in single sentences, with the added

sentence in the explanatory Annex or in a separate section.I am the chair of the NFPA Advisory Technical Committee on Glossary of Terminology but this comment is not

submitted on their behalf because we have not had the opportunity to discuss it.

_______________________________________________________________________________________________2001- Log #22

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

2001-113.3.x* Final Design Concentration (FDC). The actual concentration of agent discharged into the

enclosure. The FDC is equal to, or greater than, the Adjusted Minimum Design Concentration.A.3.3.x The FDC is equal to, or greater than, the Adjusted Minimum Design Concentration.

NFPA terminology format requires that definitions need to be in single sentences, with the addedsentence in the explanatory Annex or in a separate section.I am the chair of the NFPA Advisory Technical Committee on Glossary of Terminology but this comment is not

submitted on their behalf because we have not had the opportunity to discuss it.

1Printed on 3/15/2010

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_______________________________________________________________________________________________Shane Clary, Bay Alarm Company

2001-16Accept the proposal.

The substantiation provided by Mr. Nadgir is correct. While air sampling systems may have severallayers of alarm, cross zoning requires the product of combustion to be detected by two separate detection points. Therisk of a false activation is increased with there being only one detection device required to trip the release of the cleanagent.

_______________________________________________________________________________________________2001- Log #19


2001-17Accept the proposal.

The substantiation provided by Mr. Sullivan is correct. To prevent an accidental or false trip of thesystem a cross zoned detection system should be used. This would require the products of combustion to be detectedby two different detectors within the same space.

_______________________________________________________________________________________________2001- Log #3

_______________________________________________________________________________________________Dale R. Edlbeck, Tyco Fire Suppression & Building Products

2001-19Delete the proposal wording in its entirety.

Primary actuation devices are available in many different versions, some of which will be very difficultto monitor and will not normally be removed from the container for maintenance purposes. It is impractical to requiresupervision of all primary actuation devices.Replacement of the actuating device is a function of servicing the system similar to removal of the discharge hose and

other actions typically involved in maintenance of fire suppression systems. It should not require the addition ofmonitoring equipment to assure completion.Many halocarbon agents systems are designed using distributed bottles and even in a two bottle system, if the

pneumatic actuator is not fitted/re-fitted following handover or servicing, this is not being monitored, so we still onlymonitor half of the system?


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_______________________________________________________________________________________________John C. Spalding, Healey Fire Protection, Inc. / Rep. Fire Suppression Systems Assn. (FSSA)

2001-194.3.4.1 Removal of an electric actuator from the agent storage container discharge valve which it

controls shall result in an audible and visual indication of system impairment at the system releasing control panel. Thisprovision of the standard shall become effective January 1, 2016. This provision of the standard shall not apply tosystems covered under Chapter 8 of this standard with the exception of those systems included under 8.6.Removal of an electric actuator from the selector valve which it controls shall result in an audible and visual indication

of system impairment at the system releasing control panel. This provision of the standard shall become effectiveJanuary 1, 2016. This provision of the standard shall not apply to systems covered under Chapter 8 of this standard withthe exception of those systems included under 8.6.Annex 4.3.4.1NFPA 72 14.2.5.4 requires that “Suppression systems shall be secured from inadvertent actuation, including

disconnection of releasing solenoids or electric actuators, closing of valves, other actions, or combinations thereof, forthe specific system, for the duration of the fire alarm system testing.”Clean agent systems generally have a device attached to one or more agent storage container discharge valves which,

upon signal from the fire system releasing control unit, causes the discharge valve(s) to operate to release the agent.The device is referred to as an electric actuator. These actuators are typically 1) a solenoid operated device or 2) asquib operated device.During system maintenance, it is a common procedure to remove the solenoid operated actuators from the agent

storage container discharge valve to prevent accidental discharge of the system and permit functional testing of theactuator. Some systems which incorporate selector valves also have electric actuators attached to the selector valves tocontrol their operation by electrical signal from the control panel. These electric actuators may also need to be routinelyremoved from their selector valves during maintenance.Since the electrical connection between the solenoid and the system control panel is not broken by this maintenance

procedure, special provision is required in order to provide an indication of system impairment at the releasing controlpanel when the electric actuator is physically removed from the valve which it controls. There have been numerousreports of systems inadvertently left disabled after maintenance because the technician failed to reinstall the actuator onits valve. Fortunately in all reported cases, the impairment was discovered before the system was required to operateand only successful extinguishments have been reported – no failures to operate under fire conditions have come to theattention of the technical committee responsible for this standard.Squib actuators are covered by this requirement only if the manufacturer’s maintenance instruction requires physical

removal of the squib operated device from the valve which it controls.With the evolution of technology, cost effective means to monitor the placement of actuators can be developed.

Because of the time required to develop hardware and obtain listings and approvals for the hardware, the effective dateof this provision of the standard is January 1, 2016.

The removal and restoring of an electric actuator from either the discharge valve of the extinguishingagent cylinder or selector valve is a critical maintenance function. The supervision of these devices will insure thesystem will function when called upon. The manufacturers of the systems will require time to design, test and bring tomarket the desired product.

_______________________________________________________________________________________________2001- Log #8

_______________________________________________________________________________________________Brad T. Stilwell, Fike Corporation

2001-19Revise text to read as follows:

Effective Date for Supervising the Actuator Connection: January 1, 2013.Time required to give system manufacturers the time to adapt their equipment to incorporate

supervision of the system actuator.


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_______________________________________________________________________________________________Luc Merredew, Kidde-Fenwal, Inc.

2001-19Removal of primary agent container actuating device from the discharge valve and/or selector

valve Where a separate electromechanical actuator (solenoid operated control) is used on a primary agent cylinderand/or selector valve, and the actuator or coil is removed to prevent unwanted discharge during maintenance or service,the removal of the actuator shall cause a trouble or supervisory signal at the releasing control unit.Installations commissioned on or after the 01/01/2016 shall comply with this requirement. This requirement shall not

apply to Installations requiring explosion proof electrical services.This proposal fails specify the particular technologies to which this the requirement applies, the

recommended language clarifies the target technology and provides insight to the underlying scenario being addressed.A suitable period of time is necessary for manufacturers to develop product that meets this requirement, and for

agencies to develop the necessary testing protocols. The suggested performance period is 5-years from the issuance ofthe revised standard.Explosion or flame proof actuation hardware should be excluded since the addition of the necessary rated hardware

and electrical service reduce overall reliability rather than improve it.It is also noted that NFPA 2001 does not currently require supervision of agent pressure (or mass); i.e. the loss of

agent below the functional limits indicated in the standard does not result in a trouble or supervisory signal at thereleasing control unit. It is the opinion of this member that the requirement to add supervision of actuator placement(protection against negligence) provides a lower net increase in reliability than would be added in the event that cylindersupervision was mandated by the standard.

_______________________________________________________________________________________________2001- Log #20


2001-20Revise the revised (ROP) text as follows:

4.3.6.1 To avoid unwanted discharge of a clean agent system, a supervised disconnect switch shall be provided. Thedisconnect switch shall interrupt the releasing circuit to the suppression system. and shall cause a trouble or supervisorysignal at the releasing control unit.

When using a fire detection system designed in accordance with NFPA 72, a trouble signal isproduced by a fault in the system wiring or other fault condition. When a circuit, device or appliance is temporalityremoved from the system through the use of a disconnect switch, a supervisory signal is transmitted and displayed bythe control. Having the word "trouble" within this paragraph is in conflict with NFPA 72.


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_______________________________________________________________________________________________Thomas J. Wysocki, Guardian Services, Inc.

2001-21Add new text as follows:

When a clean agent total flooding system is being provided for the protection of a room with a raised or sunkenfloor, the room and raised or sunken floor shall be simultaneously protected.Add the following to the above text accepted the ROP:

If only the space under the raised floor is to be protected by a total flooding system, an inert gas shall be usedto protect that space.Annex 5.3.5.1 NFPA 75 2009 edition 8.1.1.2 requires “An automatic sprinkler system, a carbon dioxide extinguishing

system, or an inert agent fire extinguishing system for the protection of the area below the raised floor in an informationtechnology equipment room or information technology equipment area shall be provided.” NFPA 75 2009 editionA.8.1.1.2 notes that Halocarbon agents should not be used to protect the space below a raised floor unless the spaceabove the raised floor is likewise protected by the system and the system is designed to discharge simultaneously intoboth the space below the raised floor and the room above the raised floor.During and after a discharge some of the agent from the space under the raised floor will migrate into the room abovethe raised floor. If any fire exists in the equipment above the raised floor, the agent at a concentration below theextinguishing concentration may be exposed to the fire. If the agent were a halocarbon, considerable decomposition ofthe agent could occur. Note that NFPA 12A 2009 5.3.1.2 also prohibits the use of Halon 1301 for flooding the spaceunder a raised floor if the room above the raised floor is not simultaneously protected by the Halon 1301 total floodingsystem.

NFPA standards 75 and 12A address the protection of the space below a raised floor. Since Log 5adds text to specifically address protection of rooms with raised floors, there should be additional text under 5.3.4.1 toclarify the requirements for clean agent protection of the space below the raised floor and correlate with relatedrequirements in existing NFPA standards. The recommended Annex 5.3.5.1 further correlates with NFPA 75 and NFPA12A and provides explanation of the intent of the requirement.

_______________________________________________________________________________________________2001- Log #5


2001-21When a clean agent total flooding system is being provided for the protection of a room with a

raised or sunken floor, the room and raised or sunken floor shall be simultaneously protected. Each volume, room andraised or sunken floor, shall be provided with detectors, piping network and nozzles.

It is important that the raised or sunken floor volume have dedicated detectors and distribution pipingand nozzles to detect a fire and properly distribute the agent throughout this segregated volume.

_______________________________________________________________________________________________2001- Log #7

_______________________________________________________________________________________________John C. Spalding, Healey Fire Protection, Inc. / Rep. Fire Suppression Systems Assn. (I-SSA)

2001-24Reject the ROP Log # 30 and return to the current text in the 2008 edition of the standard.

The substantiation of Log #30 lacks any supporting statistical data to indicate any failures to extinguishthe Class A fires with a 1.2 safety factor. The current 1.2 safety factor is supported by the installation of over 23,400clean agent systems by installing members of the FSSA with no reports of failures to extinguish any Class A fires.


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The minimum design concentration for a Class A surface fire hazard shall be the extinguishing concentration, asdetermined by 5.4.2.2, times a safety factor of 1.2.

This comment keeps this section of NFPA as it is currently written and has always been. To datethere have been no reports of fires in the field that have failed to be extinguished by a clean agent system designed inaccordance with NFPA 2001. Four years ago I did a study on the extinguishing time differences between MEC and asafety factor of 1.2.Note: Supporting material is available for review at NFPA Headquarters.

_______________________________________________________________________________________________2001- Log #10



5.4.2.5 The minimum design concentration for a Class C hazards shall be the extinguishing concentration, asdetermined by 5.4.2.2, times a safety factor of 1.35.5.4.2.5.1 The minimum design concentration for spaces containing energized electrical hazards supplied at greater

than 480 volts which remains powered during and after agent discharge, shall be determined by testing, as necessary,and a hazard analysis.

To date there have been no reports of fires in the field that have failed to be extinguished by a cleanagent system designed in accordance with NFPA 2001. In 2003 the minimum design concentrations of HFC-227eaClean Agent systems protecting Class A and Class C fires was reduced to 6.25 percent. Although there have been nofailures of these systems to extinguish fires there is always a question of how much real world data there is to supportthe 6.25 percent design concentration. This comment moves the minimum design concentration for HFC-227 ea backto 7 percent.Note: Supporting material is available for review at NFPA Headquarters.

_______________________________________________________________________________________________2001- Log #6


2001-26Reject Log #CP2 and return to the current text in Section/Paragraph 5.4.2.5 of the 2008 edition.

The committee proposal reflects a dramatic increase in the design of systems protecting hazards thathave historically been successfully protected using the current 2008 edition design concentrations. The committeeproposal lacks any supporting data indicating a need for the higher concentrations as a result of failures. The FSSAinstalling members report successfully extinguishing 189 fires, of which a minimum of 19 where identified as energizedelectrical fires involving computer equipment, HVAC units and UPS equipment. Most of the equipment involved powerconsumption far exceeding the committee’s guideline of 5kw.


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_______________________________________________________________________________________________Mark L. Robin, DuPont Fluoroproducts

2001-265.4.2.5.1 The minimum design concentration for a hazard that includes electrical equipment, listed

in Table 5.4.2.5.1, which remains powered during and after agent discharge shall be 1.6 times the Class A extinguishingconcentration as determined in 5.4.2.2.

There has been no technical justification submitted to substantiate the need for a 1.6 safety factor, norhas any data been submitted indicating any of the indicated scenarios would require a safety factor of 1.6. After 20years of experience with clean agents in the field, no reports have surfaced indicating failure of clean agent systems toextinguish such fires. On the contrary, fire extinguishments in energized air handling equipment which dissipated morethan 5 kW have been reported, the threshold at which the proposal would require an increase in Class C designconcentration.


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_______________________________________________________________________________________________Luc Merredew, Kidde-Fenwal, Inc.

2001-26Delete the committee action related to Log # CP2 in its entirety.

This proposal fails to provide any data showing real world losses have occurred in applicationsprotected by agent concentrations of MEC x 1.2. However, systems thus designed have extinguished fires on numerousoccasions (NFPA/FSSA members have collated data on same), including applications with individual equipment rated athigher than 5kW. There are no data that we are aware of showing real world losses at any combination of concentrationor electrical energy level, with the exception of carbon dioxide work completed in the 1950s, which itself may warrant areview as that the assumptions regarding electrical equipment design and construction in the 1950s may not beapplicable today. As an organization we recognize that work on this area is warranted and it was to this end that wecollaborated, and sponsored, the NFPA FPRA investigation into this subject. The results were inconclusive, yet thecommittee is forging forward with a solution to problem that has not yet been properly identified or definedAgain, this proposal fails to provide correlating data that establishes the diameter of cable bundle, the spacing or fill of

cable trays or the power drawn by individual pieces of equipment with fire risk, loss data or typical application standards.The arbitrary requirements are simply an adaptation of language from ISO 14520 – requirements that themselves havelittle or no technical substantiation. Even if ISO had been developed based on European installation norms – which itappears was not the case – these parameters have not been reviewed on the basis of North American installationstandards, design practices and/or electrical codes.The 1.6 safety factor is an arithmetic mean of several fire tests with no systematic linkage. Although it is conveniently

close to the ISO value i.e. 95% of the heptane cup burner x 1.3, it lacks the technical justification to be incorporated intoa standard.There is no discussion in the proposed language of the inherent power limiting design of the vast majority of electrical

services installed in clean agent applications.There are no data to support the effective prohibition of clean agent applications protecting equipment of over 480V; a

prohibition because an undefined test is required by the new language. The power level is arbitrary and has not beenselected due to specific hazard surveys or fire losses involving higher energy equipment. Further, it does not adequatelydefine whether this is a nominal or peak value.Experience from colleagues and customers in countries that have adopted, or enforce, ISO 14520 suggests that the

higher concentration required for energized electrical hazards is often specified due to the following:— Information on final installation not available at time of design/bid,— Owner/owner’s representative does not wish to limit future outfitting options for protected space,— Concerns over liability at installer/service organization level in the event that a small change could move the

installation into next category (e.g. new cables are added into a cable tray increasing the fill from 15% to 30% of itscross-section).The US, the primary market served by the NFPA standard, is the most conservative and highly regulated fire protection

market in the world – therefore it is reasonable to assume that the effective standardization of the higher concentrationwill occur. It is fair to forecast then, that a large number of installations will be protected using the 1.6 safety factor. Thisincrease will have a number of effects. Most notably the margin of safety between design concentration and the agentexposure limiting values (or exposure durations) will be reduced and the cost of an installed system will increasedramatically. With a 33% increase in agent necessitated by the increased safety factor, more cylinders, piping, fittingsand other hardware will be required.As a result of the above, it is possible that some of the currently available solutions will become unattractive, will be

considered unsuitable, or simply not offered. While it is certain that the technical committee does not intend to introducethese market effects it is possible that competition could be harmed. It would be prudent to consider whether this couldinvoke a review under antitrust legislation.The dramatic increase, of over 33%, in the delivered agent will place a significant burden on consumers of these

systems. Consumers with ongoing operations will likely be reviewing the NFPA technical committee proceedings tounderstand why such an increase was considered necessary. System owners may look to the USDOJ to investigate theNFPA for possible violations of anti-trust statutes. These statues are broadly defined and cover a wide range of markets,industries and actions. The US legal system seeks only proof of potential harm to the consumer and not explicitmalicious intent in order to assess a conviction. Considering the lack of data substantiating the problem, as well as theminimal data collected to define the solution, NFPA’s legal defense could be hampered. Aside from the potential legal


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Report on Comments – November 2010 NFPA 2001issues, it is not unreasonable to assume that these impacts will result in owners opting not to install clean agentsystems, thereby increasing the risk of fire, personal injury, fire damage and the environmental impact of fire emissionsand reconstruction.The committee proposal does not address the installed base either in practical terms, i.e. whether or not systems

already installed would need to be ‘upgraded’, or over what period an upgrade would be necessary (if at all), or, in termsof how a system owner, engineer/architect or AHJ should evaluate a system that is installed with a safety factor of lessthan 1.6 that would now require a 1.6 safety factor.The unique handling of class C hazards that is proposed is in sharp contrast to NFPA 17 and NFPA 750 which are

effectively silent on this issue, and we are not aware of any actions being pursued that would introduce similarlaboratory data for systems covered by these and other standards.

_______________________________________________________________________________________________2001- Log #11


2001-31For inert gas agents, the discharge time required to achieve 95 percent of the minimum design

concentration for flame extinguishment based on a 20 percent safety factor shall not exceed 60 seconds, or asotherwise required by the authority having jurisdiction.

There has been no actual data presented that shows the effect of a 120 second discharge time withrespect to the test fires that are used in this standard. I think it is a mistake to change the standard without data thatsupports the change will not hinder system performance.

_______________________________________________________________________________________________2001- Log #16

_______________________________________________________________________________________________Patrick Sullivan, Kidde-Fenwal, Inc.

2001-30Delete the Committee Action related to 2001-30 (Log #23) in its entirety.

Extending the discharge time of inert gas systems to up to 120 s for Class A hazards will change thenozzle pressure, agent jet characteristic and turbulence characteristics in the enclosure, the effects of which on fireextinguishing effectiveness have not been investigated and reported. Inert gas systems that are currently listed andapproved will have to be retested to verify performance. Further, if there is presently an inert gas system supplieroffering, or ready to offer, a system designed for 120 s discharge, there would be an appearance of restraint of trade tochange the inert gas systems design rules in favor of one manufacturer without allowing an adequate opportunity forother manufacturers to redesign their products and validate their performance.

_______________________________________________________________________________________________2001- Log #17

_______________________________________________________________________________________________Patrick Sullivan, Kidde-Fenwal, Inc.

2001-31Delete the Committee Action related to 2001-31 (Log #24) in its entirety.

Extending the discharge time of inert gas systems to up to 120 s for Class A hazards will change thenozzle pressure, agent jet characteristic and turbulence characteristics in the enclosure, the effects of which on fireextinguishing effectiveness have not been investigated and reported. Inert gas systems that are currently listed andapproved will have to be retested to verify performance. Further, if there is presently an inert gas system supplieroffering, or ready to offer, a system designed for 120 s discharge, there would be an appearance of restraint of trade tochange the inert gas systems design rules in favor of one manufacturer without allowing an adequate opportunity forother manufacturers to redesign their products and validate their performance.


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_______________________________________________________________________________________________Thomas Claessen, MINIMAX GMBH & CO. KG

(1) Pressurized to 2894 psi at 70°F,(2) Pressurized to 20,0 Mpa at 15°C,(1) Pressurized at 4510 psi at 70°F(2) Pressurized at 30,0 Mpa at 15°C

***Insert Figure here***

***Insert table A.4.1.4.1 here***

IG-55 (4443): 4352 psig (30 MPa) and 59°F (15°C)IG-01 (160): 2315 psig (16 MPa) and 59°F (15°C)IG-01 (200): 2894 psig (20 MPa) and 59°F (15°C)IG-01 (300): 4510 psig (30 MPa) and 59°F (15°C)

a Vapor pressure for HFC-23 and HFC-125

***Insert Table A.4.2.3.1(a) here***In proposal NFPA 2001 Log 22 requirements for container pressure and minimum acceptable fittings

are made to cover technical properties of IG-541 300bar systems. The substantiation is that NFPA2001 shall be up todate on technologies and equipment for 300bar IG541 system, that the technology for 300bar IG-541 is available andused in many countries and that in Europe most new IG-541 installations are 300bar systems.IG-01 systems and installations using 200bar and 300bar system pressure are as well acknowledged as state of the

art. Consequently NFPA2001 should also include typical data for such IG-01 systems as described above in chapter 4.of this form.

_______________________________________________________________________________________________2001- Log #13

_______________________________________________________________________________________________Wolfgang Habitzl, Minimax

2001-35Please include the graph for 725 psi system pressure.

For FK-5-1-12 (also HFC-227ea) high pressure systems up to 725 psi are state of the art.As information FK-5-1-12 graph are attached (also HFC-227ea).


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2001_L12_Table 4.2.1.1.1(a)_F2010_ROC_R

IG-01 2370 16,341 2650 18,271 2370

16,341

2964 20,436 3304 22,781 2964

20,436

4510 31,097 5402 37,244 4510

31,097

IG-541 2175 14,997 2575 17,755 2175

14,997

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2001_L12_Table A.4.2.3.1(a)_F2010_ROC_R

2,964 (20,346)

2,964 (20,346) Class 2,000 lb thrd. forged steel

1 in.

Class 3,000 lb thrd./weld F.S.

All

Upstream the pressure reducer

Class 1,500 flanged joint

All

Downstream of the pressure reducer

__d __d

4.510

(31,097) 4.510 (31,097) Class 3,000 lb thrd.

forged steel 1 in.

Class 6,000 lb thrd./weld F.S.

All

Upstream the pressure reducer

Class 2,500 flanged joint

All

Downstream of the pressure reducer

__d _ _d

IG-55

2,175 (14,997)

2,175 (14,997) Class 2,000 lb thrd. forged steel

2 ½ in.

Class 3,000 lb thrd./weld F.S. All Upstream the pressure

reducer Class 1,500 flanged joint

All

Downstream of the pressure __d __d Note: In all comments as shown above previous and subsequent passages as existing in NFPA2001 Ed. 2008 are noted to explain the new passages recommended position. These already existing passages are not underscored.

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FK-5-1-12 725 psi (50 bar)

FK-5-1-12 Pressurized to 725 psi at 68 °F

FK-5-1-12 Pressurized to 50 bar at 20°C

40

HFC -227ea 725 psi (50bar)

HFC-227ea Pressurized to 725 psi at 68 °F

HFC-227ea Pressurized to 50 bar at 20 °C

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_______________________________________________________________________________________________Paul E. Rivers, 3M Fire Protection

2001-26Add new text as follows:

Add reference list to the end of A.5.4.2.5.1 of previously conducted energized fire testing as agreed in committeediscussion at the ROP meeting as follows:Below is a list of papers referencing previous testing conducted on energized fire scenarios.1. Niemann, R., et. al., Halon

Options Technical Working Conference, Albuquerque, NM, 1996.2. Driscoll, M. and Rivers, P., ,

Gaithersberg MD, October, 1996.3. Braun, E., et. al.,

, 1997 Halon Options TechnicalWorking Conference, Albuquerque, NM, May 6-9, 1997.4. Driscoll, M. and Rivers, P., ,

Halon Options Technical Working Conference, Albuquerque,NM, May 6-8, 1997.5. Kelly, A. and Rivers, P., NIST

Conference, Gaithersberg MD, August 1997.6. Smith, D., et. al., , November 1997.7. Niemann, R. and Bayless, H.,

Halon Options Technical Working Conference, Albuquerque, NM, May 12-14, 1998.8. Steckler, K. and Grosshandler, W., ,

November 1998.9. McKenna, L.A., et. al., Halon Options Technical

Working Conference, Albuquerque, NM, May 12-14, 1998.10. Smith, D. and Rivers, P.,

, Halon Options Technical Working Conference, Albuquerque, NM, April 27-29, 1999.11. Smith, D.M., et. al.,

Halon Options Technical Working Conference, 2001,Albuquerque, NM.12. Bengtson, G., et. al.,

, Halon Options TechnicalWorking Conference. April 30-May 2, 2002, Albuquerque, NM.13. Flamm, J., et. al.,

, Proc. 2005 HalonOptions Technical Working Conference, Albuquerque, NM, 2005.14. Bengston, G. and Niemann, R.,

, Halon Options Technical Working Conference, Albuquerque, NM., 2005Captures that work in the Annex via reference so it is not lost. At least fourteen papers produced,

- manufacturers- government researchers- consultant


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