roc tc initial ballot cover memo · 2016-03-07 · fire suppression and extinguishmentfire...

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National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org M E M O R A N D U M TO: NFPA Technical Committee on Road Tunnel and Highway Fire Protection FROM: Stacey Van Zandt DATE: November 6, 2012 SUBJECT: NFPA 502 ROC TC Letter Ballot (A2013) ______________________________________________________________________ The ROC letter ballot for NFPA 502 is attached. The ballot is for formally voting on whether or not you concur with the committee’s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Monday, November 26, 2012. As noted on the ballot form, please return the ballot to Stacey Van Zandt either via e-mail to [email protected] or via fax to 617-984-7056. You may also mail your ballot to the attention of Stacey Van Zandt at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Comments Letter Ballot

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Page 1: ROC TC Initial Ballot Cover Memo · 2016-03-07 · fire suppression and extinguishmentfire protection systemsto supplement existing water supplies. All of the different types of systems

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M TO: NFPA Technical Committee on Road Tunnel and Highway Fire

Protection FROM: Stacey Van Zandt DATE: November 6, 2012 SUBJECT: NFPA 502 ROC TC Letter Ballot (A2013)

______________________________________________________________________ The ROC letter ballot for NFPA 502 is attached. The ballot is for formally voting on whether or not you concur with the committee’s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Monday, November 26, 2012. As noted on the ballot form, please return the ballot to Stacey Van Zandt either via e-mail to [email protected] or via fax to 617-984-7056. You may also mail your ballot to the attention of Stacey Van Zandt at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Comments Letter Ballot

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-1 Log #7

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

502-5Update the dates of the following ASTM standards – No change recommended for any other ASTM

standards.ASTM E136 2011 2012ASTM E2652 2009a 2012

Standards date update.

_______________________________________________________________________________________________502-2 Log #1

_______________________________________________________________________________________________John F. Bender, UL LLC

502-6Revise text to read as follows:

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.ANSI/UL 1685,

, 2007, Revised 2010.ANSI/UL Subject 1724, , 2006.ANSI/UL 2196, , 2001, Revised December 2006 2012.

Update referenced standard to most current edition as indicated.

_______________________________________________________________________________________________502-3 Log #13

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-8Revise text to read as follows:

A structure (s) or space other than the roadway used to house or containoperating, maintenance, or support equipment and functions.

I agree that the definition in 3.3.4 should be "Ancillary Structure" rather than "Ancillary Facility" asexplained in the "Comment on Affirmative" on 502-8. I also agree that changes will need to be made in 4.3.7*, A.4.3.7and 12.3.1.1. In addition, a look needs to be taken at term "Ancillary Areas" is being used

Revise existing text as follows:3.3.4 Ancillary Facility. A structure, or space or area other than the roadway that supports the operation of limitedaccess highways, depressed highways, bridges, elevated highways, road tunnels and the roadway under air-rightstructures that are usually used to house or contain operating, maintenance, or support equipment and functions.

The modified language clarifies the definition of "ancillary facility".

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-4 Log #CC12

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-14Revise existing text as follows:

"Exit" including Emergency exit Doors, egress stairs or egress corridors leading to a point ofsafety; or such as cross-passages leading to an adjacent non-incident tunnel and recognizing that portals. areconsidered emergency exits.

This committee comment clarifies the consistency with the definition of point of safety completed duringthe ROP and further clarifies the differentiation of emergency exits immediately adjacent to the roadway from other exitsaddressed in the NFPA 101.

_______________________________________________________________________________________________502-5 Log #15

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-15Revise text to read as follows:

A limited access highway, road tunnel, roadway beneath and air-right structure, bridge, or elevatedhighway.

I agree that the proposed ROP modified definition for "facility" as shown in 3.3.21 should be furthermodified to replace the phrase "air-right structure" with the phrase "roadway beneath an air-rights structure" thus makingit consistent with the phrasing already present in the title of Chapter 8 "Roadways Beneath Air-Right Structures".

Revise text to read as follows:A limited access highway, road tunnel, roadway beneath and an air-right structure, bridge, or elevated

highway.Editorial clarification.

_______________________________________________________________________________________________502-6 Log #3

_______________________________________________________________________________________________John Chartier, Northeastern Regional Fire Code Development

502-16Revise the definition of “Fire Department Connection” to read:

A connection through which the fire department can pump supplemental water into thefixed water-based fire fighting fire suppression sprinkler system, standpipe system, or other systems furnishing water forfire suppression and extinguishment fire protection systems to supplement existing water supplies.

All of the different types of systems referenced in current language are universally referred to as“water-based fire protection systems” included in NFPA 25.

The Technical Committee has redefined the definition for Fire Dept Connection. SeeCommittee Comment 502-8 (Log #CC1) as their was inconsistency of the definition for the preferred term " firedepartment connection" within other NFPA standards (NFPA 24, Standard for the Installation of Private Fire ServiceMains and Their Appurtenances). We included the term "fixed water based fire suppression system" which is a termunique to this standard.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-7 Log #16

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-16Revise text to read as follows:

connection through which the fire department can pump supplemental waterinto the fixed water-based fire-fighting sprinkler system, standpipe, or other systems, furnishing water for firesuppression and extinguishment to supplement existing water supplies at the required system demand.

While still think that the use of the word supplemental, in the beginning of the sentence is redundantsince at the end of the sentence it is clearly stated that the water being supplied through the Fire DepartmentConnection (FDC) is to supplement existing water supplies, I accept that the existing text appears to be consistent withdefinitions contained in NFPA documents 13, 14 and 24. I believe that all of the systems connected to the FDC, asdefined in NFPA 502, are "automatic systems" as defined in NFPA 14 as they are all receiving water through the FDC tosupplement existing connected water supplies.

The Technical Committee has redefined the definition for Fire Dept Connection. SeeCommittee Comment 502-8 (Log #CC1) as there was inconsistency of the definition for the preferred term " firedepartment connection" within other NFPA standards (NFPA 24,Standard for the Installation of Private Fire ServiceMains and Their Appurtenances). We included the term "fixed water based fire suppression system" which is a termunique to this standard.

_______________________________________________________________________________________________502-8 Log #CC1

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-16

A connection through which the fire department can pump supplemental waterinto the fixed water-based firefighting system, sprinkler system, standpipe system, or other systems furnishing water for fire suppression andextinguishment to supplement existing water supplies.

The definition was clarified because of inconsistency of the definition to the preferred term " Fire DeptConnection" within other NFPA standards (NFPA 24) & the TC included the term "fixed water based fire suppressionsystem" which is a term unique to this standard.

_______________________________________________________________________________________________502-9 Log #17

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-26Revise text to read as follows:

The interface between a tunnel and the atmosphere through which vehicles pass; a connection point toan adjacent structure facility.

NFPA 502 currently defines both "Structure" and "Building" the same as they are defined in NFPA5000. The "Structure", as defined in both 502 and 5000 can be either a building or a non-building structure. I do not seewhy a portal could not possibly occur in a non-building structure thus there appears to be a valid reason to keep theword "structure".

The suggested change has already been revised by proposal 502-26 (Log #CP19) in the ROP.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-10 Log #14

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-8Revise text to read as follows:

A line of non-moving stored vehicles.The 2011 Edition definition of "Queue", as contained in is A line of stored vehicles."

The ROP accepted change to the definition is shown as A line of non-moving stored vehicles.". Whereas theactual ROP change to definition should be shown as A line of non-moving stored vehicles."

_______________________________________________________________________________________________502-11 Log #6

_______________________________________________________________________________________________Adrian Cheong Wah Onn, Land Transport Authority, Singapore

502-36Add new text to read as follows:

Fire Protection, Life Safety and Emergency Systems Reliability. Regardless of the length or type of facility, nopart of the fire protection, life safety or emergency systems critical to the intended function that addresses an emergencyshall be subject to failure as a result of the emergency it is intended to address unless the design of the system catersfor failure by means of design, redundancy or standby.

The original texts are ambiguous and required further clarification/elaboration. If the systems aredesigned for failure by means of design, redundancy or standby, part of the fire protection, life safety or emergencysystems should be allowed to fail as long as the systems are still able to perform it is intended purpose and meet itsperformance criteria during the emergency.

Revise text to read as follows:Regardless of the length or type of facility, no

part the intended function of the fire protection, life safety or emergency systems critical to the intended system functionthat addresses an emergency shall not be subject to failure as a result of the emergency it is that those systems areintended designed to address unless the design of the system caters for failure by means of design, redundancy orstandby when working in combination.A.4.3.2 Fire Protection, life safety or emergency systems systems are comprised of interdependent mechanical,electrical, communications, control, fire protection, structural, architectural and other elements, all of which must functionas a system to achieve the designed result. It is critical that all primary and supporting elements are protected toproduce a similar level of combined system reliability for the design incident exposure. This does not preclude loss ofelements that are compensated for in the design.

The Technical Committee accepted the comment in principle and provided clarification to theoriginal proposal in the ROP. The text required further clarification/elaboration.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-12 Log #CC2

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-42Revise text to read as follows:

4.5(7)* In addition to physical protection from incidents, the method of routing and providing protection to fire-life safetycritical copper and fiber data communication cables and related components shall consider include in the design boththe performance of the thermal protection and the thermal rating performance of the cable and other transmissionrelated equipment.A.4.5(7) Fire rating of separations in U.S. jurisdictions typically includes structural withstand and flame passage

duration requirements. Thermal insulation performance is often omitted. Typically Depending on manufacturer, fiberoptic strands experience excessive attenuation at temperatures ranging from as low as 70°C (158°F) to possibly200°C (392°F) 257°F (125°C), and the fiber ceases to convey signal. No fire rated fiber optic cable is currently available.Similarly, no fire rated category copper Ethernet cable is currently available. It is essential to the continued fire-life safetysystem function during an emergency that the communication system design considers the thermal insulationperformance of fire rated separations for related components and of the embedment for copper and fiber datacommunication cables. Where insulation performance is insufficient for the design fire heat exposure, other meansshould be employed to maintain conditions within the thermal limits of the system cables and components.A.12.1.2 The actual duration required for the circuits to be operative will depend upon the duration required for the

circuits to be operative for the emergency evacuation and rescue phase — and, in some circumstances, incidentmanagement and structural protection. Factors such as the length of the tunnel, evacuation pathways, the use of fixedwater-based fire suppression systems, and the proximity of emergency services may influence this period of time. Seealso A.4.5(7).

These changes retain the intent of the original proposal while addressing the concerns of Comment502- (Log #8).

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-13 Log #8

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

502-42Delete text to read as follows:

In addition to physical protection from incidents, the method of routing and providing protection to fire-life safetycritical copper and fiber data communication cables and related components shall consider the thermal rating of thecable and other transmission related equipment.

Fire rating of separations in U.S. jurisdictions typically includes structural withstand and flame passageduration requirements. Thermal insulation performance is often omitted. Typically, fiber optic strands experienceexcessive attenuation at temperatures ranging from 158°F (70°C) to 257°F (125°C), and the fiber ceases to conveysignal. No fire rated fiber optic cable is currently available. Similarly, no fire rated Category copper Ethernet cable iscurrently available. It is essential to the continued fire-life safety system function during an emergency that thecommunication system design considers the thermal insulation performance of fire rated separations for relatedcomponents and of the embedment for copper and fiber data communication cables. Where insulation performance isinsufficient for the design fire heat exposure, other means should be employed to maintain conditions within the thermallimits of the system cables and components.

The actual duration required for the circuits to be operative will depend upon the duration required for thecircuits to be operative for the emergency evacuation and rescue phase — and, in some circumstances, incidentmanagement and structural protection. Factors such as the length of the tunnel, evacuation pathways, the use of fixedwater-based fire suppression systems, and the proximity of emergency services may influence this period of time. Seealso A.4.5(7).Reject this proposal.

This proposal presents incorrect information, is misleading and is unenforceable.1. Optical fiber cables are listed by UL to UL 1651 (Standard for Optical Fiber Cable), a standard that does not contain

a specification for a temperature rating. Therefore listed optical fiber cables do not have a required temperature ratingand would automatically be prohibited from use in any application in the control and communication system, if thesection were to be attempted to be enforced.2. For Bellcore’s GR-20 (Generic Requirements for Optical Fiber and Optical Fiber Cable) standard, optical fiber cables

are assessed for aging at 85°C for 168 hours as well as for aging with cycling of up to 70°C and down to -40°C severaltimes.3. Searching the web it is pretty easy to find optical fiber cables that are designed to be used at high temperatures. In a

quick search I have found one company that advertises two types of optical fiber cables intended for use at hightemperatures (one for use at 150°C and one for use at 200°C). Another company offers various optical fiber cablessuitable for use up to 302°F (i.e. 150°C). Clearly the statement that the cables have problems when used attemperatures of 158°F (70°C) is incorrect.4. The only location in NFPA 502 (2011) where there is a requirement for any cables to have a particular temperature

rating is in Section 12.2.1.1. It requires that the temperature ratings for the cables be consistent with the conditions ofapplication. That covers everything that is needed with regard to all cables, without introducing new prejudices.5. The proposed requirement in Section 4.5(7) is a blanket statement intended to prejudice users of cables.6. The language is unenforceable as the statement “shall consider” is not something that an authority having

jurisdiction can enforce.

The information added for the original proposal is still valid and the Committee has addedadditional information to 4.5(7) and A.4.5(7) to address this comment. See Committee Comment 502-12 (Log #CC2) forfurther information.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-14 Log #18

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-51

What does the term mean in the 6.6.3 heading since there is now text, related to FireHydrants, in Annex A?Why does it not appear in heading since there is no text in this location?

The term "reserved" in the main body of the standard refers to the annex information as norequirement for Fire Hydrants has been added to the body of the standard.

_______________________________________________________________________________________________502-15 Log #CC14

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-59Revise text to read as follows:

For road tunnels that include either passive fire protection and or fixed water-based fire-fighting systems, or both,the impact of these systems during a fire on the tenable environment within the tunnel and the tunnel ventilation systemshall be evaluated.

The language more clearly sets out the committee’s intent by specifying that it is the impact of passivefire protection and fixed water-based fire-fighting systems on the other measures that should be considered. TheTechnical Committe has added the clarification and intent of "either" and "or" to the existing text.

_______________________________________________________________________________________________502-16 Log #19

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-62Move text of section 7.2 to the annex

"Comment on Affirmative":I believe that the relocation of Table 7.2 from the body of the standard (mandatory) to the Annex (informational) is

necessary. This table was developed and inserted into the NFPA 502 as a reference guide to provide users with a readyguide to the document to assist in locating specific requirements however the words in the standard text would still berepresenting the Standard requirements. This issue was made clear in the Table Note that stated that "If there is anyconflict between the requirements defined in the standard text and this table, the standard text shall always govern."What has happened over the past few years is that this table has become, to some individuals, the final word on the

requirements of this standard. When in the last cycle a proper check of the table was not performed after the ROC wasconcluded therefore the incorrect entries in the table created a real problem. So, I think it is correct procedure to includeTable A.7.2 in Annex A as a Reference Guide and that we continue to rely on the words in the Body of the Standard togovern our planning, design, construction and operational decisions on the facilities affected.

See action on Committee Comment 502-34 (Log #CC10).The Committee has updated & revised this Table based on the changes to the standard

completed during the ROC. We have moved the Table to the annex as it is a reference guide for users. See CommitteeComment 502-34 (Log #CC10) for further information.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-17 Log #11

_______________________________________________________________________________________________Igor Y. Maevski, Jacobs Engineering

502-73Revise text to read as follows:

7.4.1 Tunnels described in categories B, C, and C shall have at least one manual means of identifying and locating afire in accordance with the requirements of 7.4.1.3. Fire identification and location shall be within 2 minutes after ignition,or before fire size reaches 5 MW, whichever comes first.

It is important to identify and locate fire in a timely manner. Resolving this problem will allow formodeling the tenability and to perform egress analysis in accordance with the requirements of 7.15.6. Recent fire testsdemonstrated that this requirement can be accomplished. With the automatic fire detection system fire of 3 MW or lesscan be detected within 1 min 30 seconds.

Renumber accordingly:Tunnels described in categories B, C, and D shall have at least one manual means of identifying and locating a

fire in accordance with the requirements of 7.4.1.3.7.4.1 Tunnels described in categories B, C, and D without 24-hour supervision shall have an automatic fire

detection system in accordance with 7.4.1.4.7.4.1.1* Closed-circuit television (CCTV) systems with traffic-flow indication devices or surveillance cameras

shall be permitted for use to identify and locate fires in tunnels with 24-hour supervision.When water based fire fighting systems are installed in road tunnels an automatic fire detection system shall be

provided in accordance with 7.4.1.47.4.1.2 Ancillary spaces within tunnels defined in categories B, C, and D (such as pump stations and utility

rooms) and other areas shall be supervised by automatic fire alarm systems in accordance with 7.4.1.4.The section 7.4 is renumbered and reorganized as shown. The Committee identified a

committee comment as addressing an incorrect paragraph related to manual means of protection. See CommitteeComment 502-19 (Log #CC3) for further information.

_______________________________________________________________________________________________502-18 Log #12

_______________________________________________________________________________________________Igor Y. Maevski, Jacobs Engineering

502-73Revise text to read as follows:

7.4.1.2 When water-based fire-fighting systems are installed in road tunnels an automatic fire detection system shallbe provided in accordance with 7.4.1.4. Automatic Fire Detection System shall be able to detect fire incidence within 90seconds after ignition, or before fire size reaches 5 MW, whichever comes first.

It is important to detect fire in a timely manner, Resolving this problem will allow for modeling thetenability and to perform egress analysis in accordance with the requirements of 7.15.6. Recent fire tests demonstratedthat this requirement can be accomplished. With the automatic fire detection system fire of 3 MW or less can bedetected within 1 min 30 seconds.

See action on Committee Comment 502-19 (Log #CC3).See action on Committee Comment 502-19 (Log #CC3).

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-19 Log #CC3

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-73Add the following new text:

Automatic Fire Detection System shall be able to provide detection in the early stages of a developing fire within thetunnel under anticipated air velocity.

Automatic Fire Detection System should be able to detect a tunnel fire incident of 5 MW or less within 90seconds or better in a testing environment of 3 m/s (590 fpm) air velocity.

This addresses the intent of ROP Proposal 502-73. The change provides enhanced language toaddress necessary performance parameters required for a reliable automatic fire detection system.

_______________________________________________________________________________________________502-20 Log #CC5

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-72Replace existing text as follows.

*In new and existing tunnels and ancillary structures, wherever necessary for dependable and reliable

communications, a separate radio network capable of two-way radio communication for fire department personnel tothe fire department communication center shall be provided.Two-way radio communication enhancement system shall be installed in new and existing tunnels and ancillaryfacilities where required by the authority having jurisdiction or by other applicable governing, laws, codes, or standards.

A radio network shall be comprised of base transmitters, repeaters and receivers, antennas, mobile transmittersand receivers, portable transmitters and receivers, and ancillary equipmentTwo-way radio communication enhancement system shall be designed, installed, tested and maintained in accordancewith the provisions of NFPA-72,

By adding this information, we are requiring conformance with NFPA 72 for radio enhancementsystems. Therefore we are providing more specific guidance on tunnel radio systems along with the required testingand maintenance requirements.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-21 Log #4

_______________________________________________________________________________________________John Chartier, Northeastern Regional Fire Code Development

502-79aRecommendation: reword the sentence to read as follows,

“Fixed water-based fire-fighting systems shall be conditionally mandatory provided in category C and category Dtunnels.”

The words, “conditionally mandatory” are vague and confusing. The proposed language above makesit clear that the systems are required.

The term conditionally mandatory as used in this standard is clearly defined in 3.3.35Acceptance of this proposal would make provision of fixed fire fighting systems mandatory in category C & D tunnelswhich is not the intent.

_______________________________________________________________________________________________502-22 Log #CC8

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-84Add the following new text as follows and renumber existing text accordingly:

Design, construction, maintenance, and operation of tunnels shall consider the flammable and combustible risksfor both naturally occurring and constructed environmental hazards from outside the road tunnel.

For the indentified hazards, an engineering analysis shall be performed of constructed or naturally occurringenvironmental sources of fire life safety hazards to determine means and methods for mitigation of identified risks totunnel fire life safety.

There are a host of potential constructed and naturally occurring environmental sources of fire life safetyhazards external to road tunnels to be considered. Analysis, design, property acquisition, construction, operation andmaintenance for road tunnels should consider at a minimum the following:(1) Existing, abandoned and planned change in the risk profile from flammable and combustible material intrusion.Thiswould include contaminated soils from past, present or future leakage; and intrusion from other external sources.(2) Intrusion of gases both naturally occurring (such as methane) and introduced (such as natural gas in pipelines).Several challenges arise with hazards emanating from abutting unrelated properties and facilities, either existing beforethe tunnel construction or with a potential to be constructed later. It is advised to include determination of existing orabandoned items such as storage and related piping in the planning phase with respect to tunnel routing andencumbrances on abutting properties. For example, NFPA 30 and 30A address requirements for Flammable andCombustible Liquids Storage Tanks. The requirements for storage tanks and piping may not include consideration of thepotential effects on a tunnel. It is unlikely third parties will consult the standard, be sensitive to the fire life safety risksposed by their activities,or be sensitive to the special risks their activities pose.

This committee comment identifies risks and the annex language is provided to identify additional risksthat may occur. Other than preventative language within the standard preventing flammable or combustible liquid fromentering a ventilation opening, the current 502 language does not provide adequate guidance to prevent flammable orcombustible liquid intrusion into a tunnel or onto a roadway under an air rights structure.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-23 Log #20

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-89Revise text to read as follows:

Where the roadway beneath air-right structure length is 90 m (300ft) or greater, fire hydrants, standpipe, and water supply systems shall be provided in accordance with the requirementsof Chapter 10.

I agree with the "Comment on Affirmative" to retain the term "Fire Hydrants" in the heading as hydrantsare now addressed in 8.9*.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-24 Log #CC9

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-90Revise the following text as follows:

Fixed Wwater-based fire-fighting systems shall be permitted in road tunnels as part of an integrated approach tothe management of fire protection and fire and life safety risks.

Fire control systems shall be designed to stop or significantly slow the growth of a firewithin a reasonable period from system activation such that the.total heat release rate does not substantially increaseover discharge duration. peak heat release rate is significantly less than would be expected without a FFFSAdd the following new annex text as follows:

*Design of a fixed water based fire fighting system should consider any relavent available data resulting from full

scale tunnel fixed fire fighting tests of the type of fixed water based fire fighting systems being used.The fire scenarioused in the design process should use a representative fire curve for the type and use of the tunnel. The type,application rates and coverage design of the fixed water based fire fighting system should be based on the combinationof an engineering analysis, tests results and manufacturer installation guidelines in consultation with the AHJ. Thedesign should be in accordance with applicable NFPA standards.Revise existing text as follows:

System components shall be listed or as approved by the AHJ.Delete the following existing section:9.3.4 If deemed appropriate by the authority having jurisdiction fire test protocols need not be carried out if the design ofthe water-based fire fighting system is in accordance with the test protocol of the full scale fire tests that had alreadybeen satisfactory conducted to demonstrate that the performance objectives as described in 9.2 and the tunnelparameters described in Section 9.4 have been met.Add the following new text & renumber as follows:

For the sizing of the emergency ventilation system in accordance with Section 11.5 the effect of the fixed waterbased fire-fighting system shall be taken into account.

For protection of structural elements the applicable provisions of Section 7.3 shall apply unless evidence of theperformance of the required structural fire protection by a Fixed water-based Fire Fighting System is provided andapproved by the AHJ.

To achieve the design objectives as per Section 9.2.1, discharge device coverage, spacing,positioning, spray characteristics, working pressure and flow rates shall be determined by application of applicablecodes, standards or accepted practices, or where necessary, by an engineering analysis considering relevant availabledata resulting from full scale tunnel fixed fire fighting tests of the type of Fixed water-based Fire Fighting System beingused.Revise existing text as follows:

When a fixed water-based fire-fighting system is included as part of the overall design of a road tunnel, theimpact of this system on other measures being part of the overall safety concept shall be evaluated. At a minimum, thisevaluation shall address the following: (1) Impact on drainage requirements (2) Impact on tenability, including:  (a) Increase in humidity  (b) Reduction (if any) in stratification and visibility (3) Integration with other tunnel systems, including:  (a) Fire detection and alarm system

(b) Tunnel ventilation system  (c) Traffic control and monitoring systems

(d) Visible emergency alarm notification (4) Incident command structure and procedures, including:  (a) Procedures for tunnel operators  (b) Procedures for first responders  (c) Tactical fire-fighting procedures

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Report on Comments – June 2013 NFPA 502 (5) Protection and dependability reliability of the fixed water-based fire-fighting system, including:  (a) Impact events  (b) Seismic events  (c) Redundancy requirements (6) Ongoing system maintenance, periodic testing and service requirementAdd the following new text:

(5) When a FFFS is operated, it is possible to interrupt the fire growth rate, asa result reducing the peak temperatures and their duration occurring at the surface of any exposed structure.

The Technical Committee has modified these sections to include new information and industry trendswith regard to fixed water based fire fighting systems.

_______________________________________________________________________________________________502-25 Log #5

_______________________________________________________________________________________________John Chartier, Northeastern Regional Fire Code Development

502-96Recommendation: revise the wording as follows:

However, if deemed appropriate Where permitted by the authority having jurisdiction, fire test protocols need not becarried out if the design of the water-based fire fighting system is in accordance with the test protocol of the full scale firetests that had already been satisfactory conducted to demonstrate that the performance objectives as described in 9.2and the tunnel parameters described in Section 9.4 have been met.

The word “however” is superfluous and not needed. It adds nothing to the requirement.

Sec. 9.3.4 has been deleted in Committee Comment 502-24 (Log #CC9), therefore there nochange is warranted.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-26 Log #CC15

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-102Revise text to read as follows:

Emergency ventilation shall be sized to meet minimum ventilation requirements with one fan out of service, or,provide operational measures to ensure smoke management ensures life safety is not compromised with one fan out ofservice.

Failure or loss of availability of emergency ventilation equipment shall be considered.Emergency ventilation should be sized to meet minimum ventilation requirements with one critical fan out of

service, or provide operational measures to ensure smoke management ensures life safety in not compromised with onecritical fan out of service.

Currently, no allowance is required for routine or unexpected failure of any emergency ventilation fan.Designing the system to operate with one fan out of service will ensure either there is enough ventilation capacity tomaintain safety in case of unexpected fan failure, a fan out of service for maintenance, or, to reduce the fire load throughoperational constraints to a level where the fire load can be managed with remaining fans.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-27 Log #CC11

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-109Revise the existing text as follows:

12.1.2* Emergency circuits installed in a road tunnel and ancillary areas shall remain functional for a period of not lessthan 1 hour, for the anticipated fire condition, by meeting one of the following methods:(1)* Fire-resistive cables shall be certified or listed as having been listed for 2 hours in accordance with ANSI/UL/2196or other equivalent internationally recognized standards to 950°C (1742°F) when approved by the AHJ. tested in atotally enclosed furnace using the ASTM E-119 time temperature curve and which demonstrate functionality for no lessthan 2 hours as described in the ANSI/UL 2196 test standard and as follows:a) Tested as a complete system of conductors, cables and raceways as applicable, using a sample no shorter than 3.0m (9.84 ft).b) Fire-resistive cables intended for installation in a raceway are tested in the type of raceway in which they areintended to be installed.c) Each fire-resistive cable system have installation instructions that outline the test procedure and only the componentsstated in the test report are acceptable for actual installations.(2) Circuits embedded in concrete are protected by a 2-hour fire barrier system in accordance with UL 1724. Theinsulation for cables or conductors shall be thermoset and shall be suitable to maintain functionality at the temperaturewithin the embedded conduit or fire barrier system.(3) Routing external to the roadway(4) Diversity in system routing as approved (such as separate redundant or multiple circuits separated by a 1-hour firebarrier) so that a single fire or emergency event will not lead to a failure of the system.Add the following annex text as follows:A.12.1.2The actual duration required for the circuits to be operative will depend upon the duration required for the circuits to beoperative for the emergency evacuation and rescue phase — and, in some circumstances, incident management andstructural protection. Factors such as the length of the tunnel, evacuation pathways, the use of fixed water-based firesuppression systems, and the proximity of emergency services may influence this period of time. See also A4.5(7).(1) When selecting a fire-resistive cable, it is important to understand how it will be installed and if it was tested as acomplete system, including splices. Cables that are exposed (not embedded in concrete) should be protected usingeither a metallic raceway or an armor/sheath (see 12.3.1).There are two basic configurations of fire-resistive cables.Cables enclosed by a metallic sheath or armor, such as Type MI or Type MC, are installed without raceways. Cablesthat are installed in a raceway, such as Type RHW-2, Type TC or Type CM are tested as a complete system.Regardless of the fire test standard used to evaluate fire-resistive cables that will be installed in a raceway, it isimportant to consider that the cables are only one part of the system. Other components of the system include but arenot limited to: the type of raceway, the size of raceway, raceway support, raceway couplings, boxes, conduit bodies,splices where used, vertical supports, grounds, and pulling lubricants. Each cable type should be tested to demonstratecompatibility.Only those specific types of raceways tested should be acceptable for installation. Each cable type that is intended to

be installed in raceway should be tested in both a horizontal and vertical configuration while demonstrating circuitintegrity.

The Technical Committee has taken this action to revise Sec. 12.1.2* in order to address the recentmodification of UL pertaining to their standard UL2196. The UL action has invalidated standard requirements inChapter 12 by making the listing requirements unattainable as writtenThe Technical Committee has taken this action torevise Sec. 12.1.2* in order to address the recent modification of UL pertaining to their standard UL2196. The UL actionhas invalidated standard requirements in Chapter 12 by making the listing requirements unattainable as written.Specifically, as of Sept 12, 2012, UL has withdrawn all cable certifications (listings) to this test standard. Recent firetesting has demonstrated failure modes such as hot-dipped galvanized coatings on the interior surface of the racewayspotentially causing premature failure of copper fire-resistive cable systems.NFPA 502 currently allows the use of fire resistive cable listed in accordance with UL2196 Standard for Safety for Testfor Fire Resistive Cables 2012.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-28 Log #9

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

502-111Revise text 12.2.1.3 All wires and cables used in road tunnels shall be resistant to the spread of fire

and shall have reduced smoke emissions by one of the following methods:(1)* All wires and cables shall be listed and shall comply with the FT4/IEEE 1202 exposure requirements for cable char

height, total smoke released and peak smoke release rate of ANSI/UL 1685.(2)* Wires and cables listed as having adequate fire-resistant and low smoke-producing characteristics, by having a

flame travel distance that does not exceed 1500 mm (4.9 ft), generating a maximum peak optical density of smoke of0.5 and a maximum average optical density of smoke of 0.15 when tested in accordance with NFPA 262.(3) Wires and cables complying with the requirements for class B2ca or better and class S2 or better when tested to EN

50399, Common test methods for cables under fire conditions - Heat release and smoke production measurement oncables during flame spread test - Test apparatus, procedures, results.(4) Wires and cables complying with the requirements based on an international fire test and set by the corresponding

authority having jurisdiction tested to equivalent internationally recognized standards approved by the AHJ.A.12.2.1.3(1) Testing in accordance with CSA FT4, Vertical Flame Test, per CSA C22.2 No. 0.3) is identical to testing

in accordance with FT4/IEEE 1202.A.12.2.1.3(2) Testing in accordance with CSA FT6, Horizontal Flame and Smoke Test, per CSA C22.2 No. 0.3) is

identical to testing in accordance with NFPA 262.The language describing “equivalent internationally recognized standard” without associated criteria

puts an undue burden on the AHJ, who must then determine if the recommended test by a submitter is “equivalent”.Thus, the AHJ could be forced into the position of either having to hire experts to determine what is equivalent or toaccept tests that may not properly determine the fire performance required. Therefore the issue should be whether theAHJ considers an alternate test to be acceptable, irrespective of whether it is equivalent.Note also that the language in NFPA 502 states that the wires and cables need to have been tested and it does not

say that they need to “pass” the test. The fact that cables were tested to a particular test standard does not mean thatthe cables have passed the test, particularly since most standards do not contain criteria for “passing”. Therefore, withthe language in the standard, a manufacturer can present cables that were tested to a fire test that manufacturer likes(perhaps because it is inexpensive) and failed the test miserably, but they can be used because the language in thestandard says nothing about “passing” a test or complying with requirements. Consequently, the language included inthe NFPA 502 standard is not enforceable and is potentially misleading.The fact is that no standard fire test exists anywhere in the world that is “equivalent” to the IEEE 1202 version of UL

1685. I have recommended that the European test used for fire testing of cables (EN 50399) be used because it is avery similar cable tray test with the same ignition source. However, the committee rejected that with the rationale that Idid not present data showing the tests to be equivalent, something that is impossible to do without starting a researchprogram with cables tested in both tests (and I don’t have funds for doing something like that, of course).The test proposed (EN 50399) is the test that is used in the European Union for regulating cables, following an

extensive research program conducted primarily at SP in Sweden (known as the FIPEC program). The test was longknown as the “FIPEC” test. The reference to Class B2ca refers to the flame spread (and/or heat release) and thereference to Class S2 refers to the smoke release. See information on the FIPEC project report below.

******Insert Figure Here******

Hardback, 406pp, with 303 illustrations (including 44 color plates) and 93 tables“The European Commission, DG for Research (DGXII) and European Industry have sponsored this 3 year research

project. FIPEC has achieved its target, to develop sensitive methods for measuring the fire performance of electriccables (FIPEC). The methods are based on sound engineering principles rather than prescriptive tests unlike the currentEuropean national cable fire assessment techniques. The latter are not sensitive enough to differentiate between cableswith reasonable fire properties and those with very good properties needed for high hazard installations or for highdensity telecommunication installations. FIPEC's findings have been presented to the EC and the group of European

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A2013/ROC/NFPA 502/Log #9/Figure/Sub 

Fire Performance of Electrical Cables - FIPEC Report

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Report on Comments – June 2013 NFPA 502regulators who are studying them with view to their use as the basis of European-wide regulatory tests for use in theConstruction Products Directive. The test methods developed have been successfully correlated with real scale testsand compared with results from bench scale tests (cone calorimeter). This comprehensive report gives a detailed reviewof the work undertaken during this 3 year project and presents the full findings, including draft standards guidancedocuments. This report will be available later in the summer and should be of interest to all those active in the wire andcable industries either as a manufacturer, supplier or end-user.”See also information on 3 publications associated with that project available from SP in Sweden:

Final report on the European Commission SMT programme sponsored research project SMT4-CT96-2059 2000(External scientific book)

Grayson, Steve, Van Hees, Patrick et al.315-373

0-9532312-5-9London

InterScience Communications

Interflam ´99. Proceedings of the eight international Interflam conference. Vol. 1 1999 (External scientific book)van Hees, Patrick et al.379-391 0-95163-122-4

LondonInterscience Communications

Fire and Materials. Proceedings of the 6th international conference and exhibition, San Antonio, Febr. 22-23, 1999.1999 (External scientific book)

van Hees, Patrick et al.23-27

LondonInterscience Communications

With regard to the EN 50399 test it is important to explain to the committee that the cables that comply with the bestcategory in the test are cables that also comply with the US plenum cable requirements [as per NFPA 502, 12.2.1.3(2)],because the cables chosen for the research program were obtained in the US and shown to be plenum cables. Thesubsequent (lower) categories will be somewhat less fire safe and will be similar to those in lower categories, includingthose in NFPA 502, Section 12.2.1.3(1).Throughout the world there are only relatively few fire tests applicable to cables. In the US, the National Electrical

Code (NEC, NFPA70), recognizes 5 cable fire tests: NFPA 262, for plenum cables, UL 1666, for riser cables, UL 1685(UL protocol) or UL 1685 (IEEE 1202 protocol), both for tray cables or general purpose cables and UL VW1 (for X-ratedcables, with minimal fire safety). NFPA 262, UL 1666 and UL 1685 are all fairly large scale tests with a severe ignitionsource input. NFPA 262 requires 24 foot long specimens in the horizontal orientation (and a 90 kW flame), UL 1666requires 17.5 foot long specimens in the vertical orientation (and a flame of 145 kW), UL 1685 requires 8 foot longspecimens in the vertical orientation (and a 20 kW flame). On the other hand the VW1 test requires a 6 inch sample anda Bunsen burner flame of 0.5 kW. Originally NFPA 262 was issued as UL 910, but UL 910 has been withdrawn someyears ago to avoid duplication of fire test standards as it was identical to NFPA 262. In Canada cable tests are CSAFT4, identical to UL 1685 (IEEE 1202 protocol) and CSA FT6, identical to NFPA 262. In Europe, the EN 50399 is also avertical cable tray test (like UL 1685) with a 20 kW flame and a 3.5 meter long specimen. It is a variation of thetraditional European fire test IEC 60332-3 (formerly IEC 332-3), which had the same flame ignition source and the samecable length. Both UL 1685 and IEC 60332-3 originate with the concept of vertical cable tray tests. There were severalof them and they gradually coalesced into 3 tests. The original work at Ontario Hydro, in Canada resulted in CSA FT4,which is identical to IEEE 1202 and to UL 1685 (IEEE 1202 protocol). The work at IEEE resulted in IEEE 383 which thenbecame UL 1581 and UL 1685 (UL protocol). In Europe the cable tray test became IEC 60332-3 and then also EN50399. ASTM has issued two cable tray test standards ASTM D5424 and ASTM D5537. They are identical to UL 1685(with both protocols) except that ASTM D5537 measures heat and smoke release and ASTM D5424 measures onlysmoke release. The only other known cable tray fire test is ICEA T-29-520, which is identical to UL 1685 (UL protocol)except that the flame is 60 kW instead of 20 kW.With regard to small scale cable tests, both the IEC and Canada have tests that are similar to the UL VW1 test in the

US: CSA FT1, CSA FT2, CSA FT5, IEC 60332-1 and IEC 60332-2.The following are some references regarding fire testing of cables, for committee information.

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Report on Comments – June 2013 NFPA 502"Testing of electrical cables using full scale and small scale test methods", M.M. Hirschler, in Fire Safety in Electrical

and Electronic Applications and Composites, Proc. Fire Retardant Chemicals Association Fall Tech. Mtg, San Diego,CA, Oct. 20-23, 1991, FRCA, Lancaster, PA, p. 167-94 (1991)."Survey of fire testing of electrical cables", M.M. Hirschler, Fire and Materials, 16(3), 107-18 (1992)."Can heat release testing really predict flame spread of electrical cables?", M.M. Hirschler, Fire and Materials, 2nd. Int.

Conf. and Exhibition, Crystal City, VA, Sept. 23-24, 1993, pp. 181-90."A set of fire tests on 21 electrical cables in a large and a small scale", M.M. Hirschler, in Customer Demands for

Improved Total Performance of Flame Retarded Materials, Proc. Fire Retardant Chemicals Association Fall Tech. Mtg,Tucson, AZ, Oct. 26-29, 1993, FRCA, Lancaster, PA, p. 129-48 (1993)."Comparison of large scale and small scale heat release tests with electrical cables", M.M. Hirschler, Fire and

Materials, 18, 61-76 (1994)."Correlation Between Various Fire Tests for Electrical Cables and Their Implications for Fire Hazard Assessment",

M.M. Hirschler, Fire Risk & Hazard Assessment Symposium, National Fire Protection Research Foundation, June27-28, 1996, San Francisco, CA, pp. 210-230."Analysis of and Potential Correlations Between Fire Tests for Electrical Cables, and How to Use This Information for

Fire Hazard Assessment", M.M. Hirschler, Fire Technology, 33, 291-315, (1997)."Fire Test to Assess Flame Spread and Smoke Obscuration of Plenum Cables. Background and Issues", M.M.

Hirschler, in "Fire Safety and Technology", Fire Retardant Chemicals Association Fall Mtg, Newport, RI, Oct. 4-7, 1998."International Fire Test for Electrical Cables", M.M. Hirschler, 29th Int. Conf. Fire Safety, Jan. 10-13, 2000, Product

Safety Corp., San Francisco (CA, U.S.A.), Ed. C.J. Hilado, pp. 138-62 (2000), San Francisco, CA"Fire Testing of Electrical Cables in Transportation Environments: Trains, Ships and Aircraft", M.M. Hirschler, Business

Communications Company Eleventh Ann. Conference on Recent Advances in Flame Retardancy of PolymericMaterials, May 22-24, 2000, Stamford, CT, Ed. M. Lewin, pp.281-297, Norwalk, CT, 2000.“Fire Testing of Electrical and Optical Fiber Cables For Ships, Trains, Subways and Airplanes", M.M. Hirschler, ASTM

Committee D09 Symposium on Recent Developments in Fire Properties and Other Properties of Electrical and OpticalFiber Cables, October 4, 2004, Washington, DC.“Fire Testing of Electrical and Optical Fiber Cables for Transportation Vehicles, Especially in North America”, M.M.

Hirschler, Journal of ASTM International, Vol. 2 (10), Paper ID JAI12851, Online ISSN: 1546-962X, Published online 24August 2005.“Fire Losses, Fire Hazard & Fire Risk Associated with Plenum Cables”, M.M. Hirschler, Proc. Interflam 2007, pp.

1129-37, London, UK, September 3-5, 2007, Interscience Communications, London, UK.

12.2.1.3 Revise existing text as follows:(1) wWires and cables listed as having fire-resistant and low smoke-producing characteristics, by having All wires andcables shall be listed and shall comply with the FT4/IEEE 1202 exposure requirements for a cable char height of notgreater than 1.5 m (4 ft, 11 inches) when measured from the lower edge of the burner face, a total smoke releasedover the 20 minute test period no greater than 150 m2, and a peak smoke release rate of no greater than 0.40 m2/s,when tested as a minimum in accordance with of the FT4/IEEE1202 method described in ANSI/UL 1685 or CSA FT4,Vertical Flame Test, per CSA C22.2 No. 0.3.(2)Wires and cables listed as having adequate fire-resistant and low smoke-producing characteristics, by having a flametravel distance that does not exceed 1.500 mm (4.9 ft), generating a maximum peak optical density of smoke of0.5 and a maximum average optical density of smoke of 0.15 when tested, as a minimum in accordance with themethods described in NFPA 262 or CSA FT6, Horizontal Flame and Smoke Test, per CSA C22.2 No. 0.3.

The Committee accepted the addition to the CSA standards, however we moved them into themain body of the text instead of an annex note. The Committee added the minimum requirements necessary for fireresistance and smoke production to the main body of the standard. We did not include the reference to the EN50399standard.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-29 Log #CC4

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-112Revise the following text & renumber accordingly as follows:

12.3.1 All Cables and conductors shall be protected by means of metallic armor/sheath, metal raceway, electrical ductbanks embedded in concrete, or other methods approved by the AHJ unless otherwise permitted by 12.3.1.1 or 12.3.1.2or 12.3.1.312.3.1.1 All Cables and conductors wiring installed in ancillary facilities shall not require additional physical protection asdescribed in 12.3.1 provided that they are installed in a cable tray and are listed for riser use or for plenum use for cabletray use.12.3.1.2 Non-metallic raceways shall be permitted when installing cables and conductors installed on limited accesshighways, bridges, elevated highways and depressed highways.

In the ROP, the Technical Committee accepted the addition of 12.3.1.2 & 12.3.1.3 for the use ofnon-metallic raceways for areas other than road tunnels. The Technical Committee rejects the addition of "riser cables"as an equal to FT4. There are distinctly different test protocols and they are not proven to be equal.

_______________________________________________________________________________________________502-30 Log #22

_______________________________________________________________________________________________William A. Wolfe, Steel Tube Institute of North America

502-112Combine New 12.3.1.2 with existing 12.3.1.1 to read as follows and delete new 12.3.1.3.

12.3.1.1 All wiring installed in ancillary facilities shall not require additional physical protection as described in 12.3.1provided that they are installed in a cable tray, and are listed for cable tray use. or are listed for riser or plenum use.12.3.1.1 All wiring installed in ancillary facilities shall not require additional physical protection as described in 12.3.1

provided that they are installed in a cable tray and are listed fro riser use or for plenum use.12.3.1.3 Non-metallic raceways shall be permitted when installing cables and conductors installed on limited access

highways, bridges, elevated highways and depressed highways.Combining the new 12.3.1.2 with 12.3.1.1 clarifies the types of cables that are permitted. As it reads

now, it could appear that the cables must be listed for cable tray use and also be listed for riser or plenum use.It is not clear why the TC decided to include nonmetallic raceways in new 12.3.1.3. There is no substantiation for

doing so and the new requirement does not read well: “Non-metallic raceways shall be permitted when installing cablesand conductors installed . . . “There are several types of nonmetallic raceways. Is the intent to allow all type of nonmetallic raceways – Schedule 40,

Schedule 80, NUCC, RTRC, HDPE, utility duct, nonmetallic surface raceways, etc? NFPA 502 requires that“installations shall conform to NFPA 70 except as herein modified in this standard”. Is this a modification of therequirements related to nonmetallic raceways covered in the NEC or do all the requirements of NFPA 70 apply? It is notclear.

It was never the Committee's intention to restrict the type of raceways for other areas otherthan tunnel roadways. See Committee Comment 502-29 (Log #CC4) for more information.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-31 Log #23

_______________________________________________________________________________________________William A. Wolfe, Steel Tube Institute of North America

502-113Revise the original proposal as follows:

(1) Combustible Nonmetallic coatings of any type shall not be permitted on exposed metallic armor/sheath, wiring,raceways, equipment, or supports.(2) PVC Combustible Nonmetallic conduits shall be permitted when covered with a minimum of 100 mm (4 in.)

concrete when approved by the AHJ. All conduit ends inside of pull boxes and junction boxes shall be fire stopped.(3) All insulated cables and conductors installed in supply air duct shall be enclosed in a metal raceway, or be Type MI

cable, or Type MC cable employing a smooth or corrugated impervious metal sheath. PVC Nonmetallic coatings of anytype shall not be permitted.

Since the committee does not accept the use of “combustible” as the submitter of this proposalrequested, change “PVC” to “nonmetallic”. Why require testing to a MIL standard? The National Electrical Code NFPA70 uses the term “nonmetallic” to describe these coatings that can be applied to metal products. The use of this term inthe Electrical Requirements section of NFPA 502 will be consistent with terms used in the National Electrical Code.12.3.2.(3) should not have been deleted. This requirement needs to be included since it is important to clarify that

conduit, metal-clad cables and raceways cannot have nonmetallic coverings when installed in these locations. Thesubmitter of the proposal is correct that combustible cables and conductors are allowed to be used inside metalraceways, conduits and metal-clad cables but the requirement that these raceways, conduits and metal-clad cablesthemselves cannot have “an overall nonmetallic covering” in spaces used for environmental air is important to retain.These products are all available with nonmetallic coatings or jackets which are not allowed to be used in environmentalair spaces per NFPA 70.

The comment does not address the original action on the ROP proposal. The wording in theproposal was accepted in principle and modified by the committee. The submitter used the incorrect reference ofproposal 502-113.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-32 Log #10

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

502-115Revise text to read as follows:

All wiring and cables installed in supply air ducts shall meet one of the following:(1)* Shall be listed as having adequate fire-resistant and low smoke-producing characteristics when tested in

accordance with NFPA 262 or equivalent international recognized standard and approved(2) Shall be installed in nonmetallic conduits that are embedded in concrete with all conduit ends fire stopped where

they enter pull boxes or splice boxes(3) Shall be installed in intermediate metal conduit, or rigid metal conduit without an overall nonmetallic covering, or

flexible metallic tubing no longer than 6 ft in length(4) Shall be Type MI cable, or Type MC cable employing a smooth or corrugated impervious metal sheath without an

overall nonmetallic coveringOne method of defining a cable that is low smoke–producing cable and fire-resistant cable is that the cable

exhibits a maximum peak optical density of 0.5 or less, an average optical density of 0.15 or less, and a maximum flamespread distance of 1.52 m (5 ft) or less when tested in accordance with NFPA 262. Testing in accordance with CSAFT6, Horizontal Flame and Smoke Test, per CSA C22.2 No. 0.3) is identical to testing in accordance with NFPA 262.

As explained at length in the comment to NFPA 502-111, no equivalent standard to NFPA 262 exists.In Canada, CSA FT6 is a test that is identical to NFPA 262 and to the withdrawn UL 910. An added sentence isproposed for that clarification, in the annex.

Revise text to read as follows:* All wiring and cables installed in supply air ducts shall meet one of the following:

(1)* Shall be listed as having adequate fire-resistant and low smoke-producing characteristics exhibiting a maximumpeak optical density of 0.5 or less, an average optical density of 0.15 or less, and a maximum flame spread distance of1.5 m (4.9 ft) or less when tested, as a minimum, in accordance with NFPA 262 or with CSA FT6, Horizontal Flame andSmoke Test, per CSA C22.2 No. 0.3. or equivalent international recognized standard and approved(2) Shall be installed in nonmetallic conduits that are embedded in concrete with all conduit ends fire stopped where

they enter pull boxes or splice boxes(3) Shall be installed in intermediate metal conduit, or rigid metal conduit without an overall nonmetallic covering, or

flexible metallic tubing no longer than 6 ft in length(4) Shall be Type MI cable, or Type MC cable employing a smooth or corrugated impervious metal sheath without an

overall nonmetallic coveringOne method of defining a cable that is low smoke–producing cable and fire-resistant cable is that the cable

exhibits a maximum peak optical density of 0.5 or less, an average optical density of 0.15 or less, and a maximum flamespread distance of 1.52 m (5 ft) or less when tested in accordance with NFPA 262.

The Technical Committee decided to move the mandatory requirements to the main body tobetter address the performance parameters.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-33 Log #21

_______________________________________________________________________________________________Arthur G. Bendelius, A&G Consultants, Inc.

502-131Move Table 7.2 to Annex A and renumber as Table A.7.2.

In response to "Comment on Affirmative":I believe that the relocation of Table 7.2 from the body of the standard (mandatory) to the Annex (informational) is

necessary. This table was developed and inserted into the NFPA 502 as a reference guide to provide users with a readyguide to the document to assist in locating specific requirements however the words in the standard text would still berepresenting the Standard requirements. This issue was made clear in the Table Note that stated that "If there is anyconflict between the requirements defined in the standard text and this table, the standard text shall always govern."What has happened over the past few years is that this table has become, to some individuals, the final word on the

requirements of this standard. When in the last cycle a proper check of the table was not performed after the ROC wasconcluded therefore the incorrect entries in the table created a real problem. So, think it is correct procedure to includeTable A.7.2 in Annex A as a Reference Guide and that we continue to rely on the words in the Body of the Standard togovern our planning, design, construction and operational decisions on the facilities affected.

See action on Committee Comment 502-34 (Log #CC10).The Committee has updated and revised this Table based on the changes to the standard

completed during the ROC. We have moved the Table to the annex as it is a reference guide for users. See CommitteeComment 502-34 (Log #CC10) for further information.

_______________________________________________________________________________________________502-34 Log #CC10

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-63Update existing Table 7.2 and move to annex as Table A.7.2

********************insert 502_CC10_Table A.7.2 revised ***********************

The Technical Committee has updated & revised this Table based on the changes to the standardcompleted during the ROC. We have moved the Table to the annex as it is a reference guide for users.

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NFPA 502 Log #CC10 Rec A2013 ROC

 

Changes to ROP Version of Table A.7.2 for NFPA 502 2014 Edition

Table A.7.2 Minimum Road Tunnel Fire Protection Reference Table Guide

Fire Protection Systems  NFPA 502 Sections 

Road Tunnel CategoriesX A B  C D

See 7.2(1)

See 7.2(1)

See 7.2(3)

See 7.2(4)

See 7.2(5)

Engineering Analysis Engineering analysis 

4.3.1  MR MR MR MR MR

Fire Protection of Structural

Elements (a) Fire protection of structural elements 7.3 MRCMR MRCMR MR MR MR Fire Detection Detection, identification, and location of fire in tunnel Manual fire alarm boxes

CCTV systems (b)

Automatic fire detection systems (b) Fire alarm control panel  

7.4

7.4.1.3 7.4.1.1 7.4.1.4 7.4.2 

- - - - - - - - - - - - - - - 

- - - - - - - - - - - - - - - 

MR MR

CMR CMR MR 

MR MR

CMR CMR MR 

MR MR

CMR CMR MR 

Emergency Communications Systems (c) Radio Emergency communications systems Telephone  

7.5

4.5 / 7.5 

- - -

CMR 

- - -

CMR 

MR

CMR 

MR

CMR 

MR

CMR 

Traffic Control Stop traffic approaching tunnel portal Stop traffic from entering tunnel’s direct approaches 

7.6.1 7.6.2 

MR - - -

MR - - -

MR MR 

MR MR

MR MR

Fire Protection

Fire apparatus (d) Fire standpipe Water supply Fire department connections Hose connections

Fire pumps (e) Portable fire extinguishers

Fixed water-based fire-fighting systems (f)

Emergency ventilation system ( g )

Tunnel drainage system (h)

Hydrocarbon detection (h)

Flammable and combustible environmental hazards (i) 

7.7

7.8 / 10.1 7.8 / 10.2

10.3 10.4 10.5 7.9

7.10 / 9.0 7.11 / 11.0

7.12 7.12.7 7.15 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - MR MR MR MR

CMR - - - - - - - - -

CMR CMR - - - 

- - - MR MR MR MR

CMR MR - - -

CMR MR MR

CMR 

- - - MR MR MR MR

CMR MR

CMR CMR MR MR

CMR 

- - - MR MR MR MR

CMR MR

CMR MR MR MR

CMR 

Means of Egress Emergency egress Exit identification Tenable environment Walking Surface Doors

Emergency exits (includes cross-passageways) (j)  

7.16.1 7.15.1

7.16.1.2 7.15.1.2 7.16.2 7.15.2 7.16.4 7.15.4 7.16.5 7.15.5

7.16.6/7.16.7 7.15.6/7.15.7 

- - - - - - - - - - - - - - - - - -

CMR- - - CMR- - - CMR- - - CMR- - - CMR- - - CMR- - -

MR MR MR MR MR MR 

MR MR MR MR MR MR 

MR MR MR MR MR MR 

Electrical Systems (k) General Emergency power Emergency lighting Exit signs Security plan  

12.1 12.4 12.6

12.6.8 12.7 

- - - - - - - - - - - - - - - 

CMR CMR CMR CMR CMR 

MR MR MR MR MR 

MR MR MR MR MR 

MR MR MR MR MR 

Emergency Response Plan Emergency response plan  

13.3

MR

MR

MR 

MR

MR

MR: Mandatory requirement (3.3.35): CMR: Conditionally mandatory requirement (3.3.35.1):. NMR: Non-mandatory requirement (3.3.35.2). Note: The purpose of Table A.7.2 is to provide guidance assistance in locating minimum road tunnel fire protection requirements contained within this standard. If there is any conflict between the requirements defined in the standard text and this table, the standard text shall always govern. (a) Determination of requirements in accordance with Section 7.2. (b) Determination of requirements in accordance with Section 7.4.1. (c) Determination of requirements in accordance with Sections 4.5 and 7.5. (d) Not mandatory to be at tunnel; however, they must be near to minimize response time. (e) If required, must follow Section 10.5. (f) If installed, must follow Section 7.10 and Chapter 9. (g) Section 11.1 allows engineering analysis to determine requirements. (h) If required, must follow Section 7.12. (i) Determination of requirements in accordance with Section 7.15.2. (i) Emergency exit spacing must be supported by an egress analysis.in accordance with 7.15.6.

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NFPA 502 Log #CC10 Rec A2013 ROC

 

(j) If required, must follow Chapter 12.

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-35 Log #CC6

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-133Add new annex text as follows:

A.7.15.6.3.1 The maximum travel distance should be computed as the distance to the next available exit as well asconsideration for the width of the roadway. Exit availability should consider exit capacity, obstructions due to traffic orincident conditions, and tenability.

In computing the maximum travel distance, adding the width recognizes both the more conservativemaximum travel distances in NFPA 101. More importantly, passengers leaving their vehicles may well have to weavebetween cars and trucks, rather than simply traveling a nominally clear diagonal path from their car to the nearest exit.This approach is consistent with NFPA 101. The fact that the exit spacing includes both length and width, follows thenormal convention of the minimum distance to the nearest available exits. By definition this rule will have a significantlygreater impact on wider tunnels.

23Printed on 11/5/2012

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-36 Log #CC7

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-138Add revised Table A.11.5.1 & Revise text as follows:

Representative Experimental fire heat release rates (HRR) and representative HRR that correspond to thevarious vehicle types are provided in Table A.11.5.1. The fire test data is obtained from experiments experimental HRRin the first column, obtained from fire tests carried out in various full scale tunnels or fire laboratories. Therepresentative HRR given in the second column are typically suggested as design fire sizes.Each engineering objective should have an appropriate design fire curve adapted to take into account project-specificfactors directly relating to the engineering objective to be achieved, and these may include:(1) Tunnel geometry , including aspect ratio (height, width and cross-sectional profile)(2) Traffic and vehicle type characteristics such as percentage of heavy goods vehicles, fire load, fuel containment, andfuel type, geometric configuration of the vehicle, body material type, existence of vehicle fire suppression system andvehicle mix.(3) Tunnel operational philosophy such as bidirectional flow and congestion management

(4) Fire protection systems(5) Fire properties and characteristics(6) Environmental conditionsThe design fire is not necessarily the worst fire that may occur. Engineering judgment should be used to establish theprobability of occurrence and the ability to achieve practical solutions. Therefore, different design scenarios are oftenused for various safety systems.

*********************insert revised 502_Table A.11.5.1_10_02_12********************************

The annex reference should be recognized as providing test results of heat release rate data. Somenumbers have been updated based on recent full scale test results and additional information has been added to assistthe user in selecting an appropriate design fire size based on available data.

_______________________________________________________________________________________________502-37 Log #2

_______________________________________________________________________________________________John Chartier, Northeastern Regional Fire Code Development

502-102Revise to read as follows:

When operational measures for smoke management are not in place to ensure adequate life safety, considerationshould be given to sizing emergency ventilation should be sized to meet minimum ventilation requirements even whenwith one critical fan is out of service, or provide operational measures to ensure smoke management ensures life safetyis not compromised with one critical fan out of service.

This wording seems clearer.

The proposed text does not add any additional clarity.

24Printed on 11/5/2012

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NFPA 502 Log #CC7 Rec A2013 ROC

Table A.11.5.1 Representative Heat Release Rate Data from Fire Tests Fire Data for Typical

Vehicles Experimental HRR Representative HRR Vehicles Peak HRR Time to Peak

HRR Peak HRR Time to Peak

HRR

(MW) (min) (MW) (min)

Passenger car

5 - 10 0 - 54 a) 5 10

Multiple passenger cars

10 – 20

10 – 55b)

15

20

Bus 25 – 34c) 7 - 14 30 15 Heavy goods truck

20 – 200d)

7 – 48e)

150

15

Flammable / Combustible Liquid Tankers

200 – 300

---

300

---

a) Experiments show that 60 % of the tested individual passenger cars reach peak HRR within 20 minutes and 83 % within 30 minutes. b)Experiments show that 70 % of the tested multiple passenger cars reach time to peak HRR within 30 minutes. c)Very few tests have been done with buses, but real fires indicate that these experimental values may be higher. d)The range of peak HRR and the rate of fire growth are affected by the type and amount of cargo and the container type protecting the cargo. All type of covers of the cargo will delay the fire growth rate. The peak heat release rate is determined by the fire exposed surface area of the cargo. For most solid cargo materials it varies from 0.1 MW/m2 for wood to 0.5 MW/m2 for plastics. In experiments involving 14 tests, in 85 % of the tested cases the peak heat release rate was equal to or less than 130 MW, and in 70 % of the tested cases the peak heat release rate was equal to or less than 70 MW. e)Experiments show that 85 % of the tested truck loads reached peak HRR within 20 minutes. Source: Ingason and Lönnermark ,Heat Release in Tunnel Fires: a Summary, Tunnel Safety Handbook 2nd Edition 2011. Ingason, “ Design Fires in Tunnels”, Safe and Reliable Tunnels, 2006 Add new note #5 under existing note #4: 5) If a FFFS is installed in accordance with Chapter 9 the AHJ can reduce values for HRR for design purposes based on an engineering analysis. Items to consider in doing this are: · Activation time · Resilience · Reliability *Maximum registered for open truck:

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Report on Comments – June 2013 NFPA 502_______________________________________________________________________________________________502-38 Log #CC16

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-146Revise text as follows:

Fixed water-based fire-fighting systems should be considered a as part of a package of fire and life safetymeasures in long or busy tunnels where an engineering analysis demonstrates that an acceptable level of safety can beachieved. By the use of water-based fire-fighting systems which are themselves . The tunnel operator and the local firedepartment or authority having jurisdiction should consider the advantages and disadvantages of such systems as theyapply to a particular tunnel installation.

The technical committee clarifies and amends the intent of the accepted proposal with the added text.

_______________________________________________________________________________________________502-39 Log #CC13

_______________________________________________________________________________________________Technical Committee on Road Tunnel and Highway Fire Protection,

502-57Add the following new reference material as follows

PIARC, Working Group 4, Air Quality, Fires and Ventilation.“Design Fires in Road Tunnels”, Synthesis 415, National Cooperative Highway Research Program, TransportationResearch Board, National Academy of Sciences. (Last Modified 9/21/2011).

Current language provides limited references relative to the required analysis. Following direction fromROP, we are adding this reference per 502-57 (Log #CP51).

25Printed on 11/5/2012