il [rt] hague - nfpa...have ul listed 1 percent afff. its fire-fighting capabilities are similar in...

NOTE: Since the revision of NFPA 11 slipped from the 1997 Annual Meeting revision cycle, the ROP is reprinted here on pages 53-60.

Report of the Committee on

Foam

Christopher P. Hanauska, Chair Hughes Assoc., Inc., MN [SE]

Laurence D. Watrous, Secretar 3 HSB Professional Loss Control Inc., TN [I]

William M. Carey, Underwriters Laboratories Inc., IL [RT] Salvatore A. Chines, Industrial Risk Insurers, CT [I]

Rep. Industrial Risk Insurers W. D. Cochran, Montgomery, TX [SE] Gene DiClementi, Glen,dew Fire Dept., IL [E] Arthur R. Dooley, Jr. Dooley Tackaberry, Inc., TX [IM]

Rep. Nat'l Assn. of Fire Equipment Distributors Inc. Francis X. Dunigan, Jr. ~Smgus Fire North America, NC [M] John A. Frank, Kemper Nat'l. Insurance Cos., GA[I] Robert A. Green, Public Service Electric & Gas Co., NJ [U]

Rep. Edison Electric Inst. LarryJesclarcL Engineered Fire Systems, Inc., AK [IM]

Rep. Fire Suppression Systems Assn. Dennis C. Kennedy, RolfJensen & Assoc. Inc., IL [SE] John A. Krembs, M&M Protection Consultants, IL [I] John Lake, Fire Protection Industries Inc., PA [M]

Rep. Nat'l Fire Sprinkler Assn. D. N. Meldrum, Malvern, PA [SE] Robert C. Merritt, Factory Mutual Research Corp., MA [I] Richard F. Murphy, Cranford, NJ [SE] Edward C. Norman, Aqueous Foam Technology, Inc., PA [SE] Keith Olson, Ansul Inc, WI [M]

Rep. Fire Equipment Mfrs. Assn. Inc Richard E. Ottman, 3M, MN [M] Fay Purvis, Nat'l. Foam, Inc, PA[M] Niall Ramsden, Resource Protection Int'l., England [SE] Steven F. Vieira, Grinneil Corp., RI [M] Klaus Wahle, U.S. Coast Guard, DC [E] B. J. Walker, Walker & Assoc., MO [SE] Michel Williams, Ultramar Canada, Inc., PO~ Canada [U]

Rep. NFPA Industrial Fire Protection Section Jack Woycheese, Gage-E~abcock & Assoc. Inc., CA [SE]

Alternates

Tony Cash, Angus Fire, England [M] (Alt. to F. X. Dunigan)

William M. Cline, Factory Mutual Research Corp., MA [I] (Alt. to R. C. Merritt)

Dennis L. Doherty, Industrial Risk Insurers, CT [I] (AlL to S. A. Chines)

Peter E. Getchell, Kemper Nat'l. Insurance Cos., PA [I] (AlL to J. A. Frank)

Matthew T. Gustafson, U.S. Coast Guard, DC [E] (AlL to K. Wahle)

Kevin P. Kuntz, M & M Protection Consultants, NJ [I] (Alt. to J. A. Krembs)

Norbert W. Makowka, Nat'l Assn. of Fire Equip. Distributors (NAFED), IL [IM]

(Alt. to A. R. Dooley, Jr.) Francisco N. Nazario, Exxon Research & Engr, NJ [U]

(Voting alt. to API Rep.) David K. Riggs, SOTEC, LA JIM]

(AlL to L. Jesclard) Joseph L. Scheffey, Hughes Assoc. Inc., MD [SE]

(Ah. to C. Hanauska) Bruce S. Shipley, Nat'l. Foam, Inc., PA[M]

(AlL to F. Purvis) Christopher h Vollman, RolfJensen & Assoc. Inc., TX [SE]

(Alt. to D. C. Kennedy) Kenneth W. Zastrow, Underwriters Laboratories Inc., Northbrook, IL [RT]

(Air. to W. M. Carey)

Staff Liaison: David R. Hague

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A ke~ to classifications is found at the front of the book.

Committee Scope: This Committee shall have primary responsibility for documents on the installation, maintenance, and use of foam systems for fire protection, including foam hose streams.

The Report of the Technical Committee on Foam is presented for adoption.

This Report was prepared by the Technical Committee on Foam and proposes for adoption amendments to NFPA 11-1994, Standard for Low-Expansion Foam. NFPA 11-1994 is published in Volume 1 of the 1996 National Fire Codes and in separate pamphlet form.

This Report has been submitted to letter ballot of the Technical Committee on Foam, which consists of 28 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

53

NFPA 11 - - F97 R O C (Reprinted from A97 ROP)

(Log #8) 11- 1 - (Entire Document): Reject SUBMITI'ER: Robert L Markle, United States Coast Guard, G- M Ms-4 RECOMMENDATION: Develop a new chapter to address design and installation requirements for low expansion foam systems aboard commercial ships. The chapter should address deck foam systems on tank ships carrying hydrocarbons and polar solvents; machinery space foam systems; and other foam equipment applications on commercial vessels. SUBSTANTIATION: There does not currendy exist industry developed consensus guidance for foam systems and equipment used aboard commercial vessels. A task group shouldbe formed to develop the proposed new chapter. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: No proposed wording. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesclard, Lake, Nazario

(Log #CP8) 11- 2 - (1-l(b), (c), (e), (f), and (g)): Accept SUBMITTER: Technical Committee on Foam RECOMMENDATION: Revise text to add reference to appropriate standards as follows:

(b) Foam-water deluge sprinkler or spray systems see, NFPA 16 "Standard for the Installauon of Deluge Foam-Water Spinkler and Foam-Water Spray Systems" (1995).

(c) Foam-water closed-head sprinkler systems see, NFPA 16A "Standard for the Installation of Closed-Head Foam-Water Sprinkler Systems" (1994).

(e) Mobile Foam Apparatus see, NFPA 11C "Standard for Mobile Foam Apparatus" (1995) and, NFPA 1901 "Standard for Pumper Fire Apparatus" 0991).

(f) Medium- and high-expansion foam systems see NFPA I 1A "Standard for Medium- and High-Expansion Foam Systems" (1994).

(g) Class A foam see, NFPA 298 "Standard on Fire Fighting Foam Chemicals for Class A Fuels in Rural, Suburban, and Vegetated Areas" (1994). SUBSTANTIATION: The Committee feels that reference to the , ate s dard is in order.

ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITrEE ACTION:


(Log #CP2) 11- 3 - (1-1(g) (New)): Accept SUBMITTER: Technical Committee on Foam RECOMMENDATION: Add sub-paragraph (g) to exclude class "A" foams as follows:

(g) Class "A" foam and systems. SUBSTANTIATION: The requirements and testprocedures for class "A" foam is presently covered in NFPA 298 "Standard on Fire Fighting Foam Chemicals for Class A Fuels in Rural, Suburban, and Vegetated Areas" (1994). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITI'EE ACTION:


(Log #4) 11- 4 - (1-4 Concentration): Accept in Principle SUBMITTER: Gary R. Mitchell, FMCJetway Systems RECOMMENDATION: Add new text as follows:

"A 1 percent concentrate is mixed with 99 parts water to 1 part foam concentrate." SUBSTANTIATION: Several foam concentrate manufacturers have UL listed 1 percent AFFF. Its fire-fighting capabilities are similar in nature to 3percent and 6 percent solutions. Use of 1 percent permits a smaller bladder tank and minimizes space requirements. COMMITTEE ACTION: Accept in Principle.

Revise the definition of concentration as follows:

Concentration. The percent of foam concentrate contained in a foam solution. The type of foam concentrate used determines the ~ercentage of concentration required. For example, a 3 percent roam concentrate is mixed in the ratio of 97 parts water to 3 parts foam concentrate to make foam solution. COMMITTEE STATEMENT: The definition is not meant to restrict the percent of concentration used, it is meant to define concentration. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #7) 11- 5 - (1-4 Concentration): Reject SUBMITTER: James Devonshire, Chemguard, Inc. RECOMMENDATION: At the end of the current paragraph add the following wording:

"A 1 percent concentration is mixed with 99 parts water to 1 part foam concentrate." SUBSTANTIATION: With developments in both foam concentrates and hardware it seems that this particular paragraph is limiting the standard in scope. There are 1 percent AFFF concentrates from several manufacturers listed by U.L. through various proportioning and discharge devices. The fire performance is similar in nature to both the 3 percent and 6 percent AFFF products. Due to space and weight limitations, several end users of foam concentrates have noted this omission and requested that we address this issue with the committee. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action for Proposal 11- 6 (Log#CP3). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #CP3) 11- 6 - (1-4 Foam Concentrate (c), 1 Aqueous Film-Forming Foam (AFFF) Concentrates): Accept SUBMITrER: Technical Committee on Foam RECOMMENDATION: Revise definition of Aqueous Film Forming Foam concentrates as follows:

Aqueous Film Forming Foam (AFFF) Concentrates. These concentrates are based on fluorinated surfactants plus foam stabilizers and usually diluted with water to a 1 percent, 3 percent or 6 percent solution° The foam formed acts as a barrier both to exclude air or oxygen and to develop an aqueous film on the fuel surface capable of suppressing the evolution of fuel vapors. The foam produced with AFFF concentrate is dry chemicalcompatible and thus is suitable for combined use with dry chemicals. SUBSTANTIATION: The standard should recognize the existence of one percent foam. [See Proposal 11- 4 (Log #4) and Proposal 11- 5 (Log #7)] COMMITrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 3 Jesdard, Lake, Nazario

(Log #5) 11- 7 - (3-3.3.2.2): Accept SUBMITTER: Keith Olson, Ansul Fire Protection RECOMMENDATION: Revise text as follows:

3-3.3,.2.2 Below-the Seal or Weather Shield System. The design

~ arameters for the application of fkxed foam discharge outlets elow the seal (or weather shield) to protect open-top floating roof

tanks shall be in accordance with Table .~-3..~.2.2. The requirements given in the table apply to tanks containing hydrocarbons, or, flammable and combustible materials requiring alcohol-resistant foams. The required minimum application rates given in Table 3-3.3.2.2 apply unless listing for specific products require higher application rates when Type II fixed foam discharge outlets are used. (See Figure 3-3.3.2.2.)

Note that the only changes above are underlined compared to what is currently in NFPA 11. Table 3-3.3.2.2 follows with changes corresponding to Details A-D of Figure 3-3.3.9.2.

54

NFPA 11 - - F97 ROC (Reprinted from A97 ROP)

Table 3-3.3.2.2 Below-the-Seal F'med Foam Discharge protection for Open-Top Floating Roof Tanks (See Figure 3-3.3.2.2)

Seal Type

Appl icable Minimum Application Rate- Illustration Detail g p m / f t 2 [ ( L / m i n ) / m 2]

Minimum Discharge)Time(min Maximum Spacing Between

Discharge (Outlets)

Mechanical Shoe Seal A 0.5 (20.4) 10 130 ft (39 m) - Foam darn no t requi red

0.5 (20.4) 10 60 ft (18 m) - Foam dam not requi red

0.5 (20.4) 10 60 ft (18 m) - Foam dam required

Tube Seal with more than 6 in. B (152 ram) between top of tube and top of p o n t o o n

Tube Seal with less than 6 in. (152 C mm) between top of tube and top of pon toon

*Tube Seal with foam discharge D below metal secondary, seal

0.5 (20.4) 10 60 ft (18 m) - Foam dana no t requi red

*A metal secondary seal is equivalent to a foam dam.

SUBSTANTIATION: None. COMMITTEE ACTION: Accept. NUMBER OF COMM1TrEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #6) 11- 8 - (3-3.3.3.4): Accept SUBMITTER: Richard F. Murphy, Exxon Research & Engineer ing RECOMMENDATION: Revise paragraph to read as follows:

"The foam dam shall be at least 1 ft (0.3 m), but no t more than 2 ft (0.6 m), f rom the tank shell." SUBSTANTIATION: "lqae foam dam should be d imens ioned f rom the tank shell, no t the edge of the floating roof. This is consistent with the d imensioning shown in Figures ~-3(d), A-3- 3.3.1.1 (a), and A-3-3.4. COMMITTEE ACTION: Accept. NUMBER OF COMMITIT.E MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #9) 11- 9 - (~b4.1 (New)): Accept in Principle SUBMITTER: F.L. Blumquist, PETREX, Inc. RECOMMENDATION: Add new text as follows:

3-4.1 Types of Fires Ant idpa ted . Where a covered floating roof is o ther than described in 3-4 a design for full surface protect ion shall be used. For a covered floating roo f as described in 5-4 a design for seal area protect ion shall be permit ted. SUBSTANTIATION: (1) The problem is that these paragraphs require foam protect ion to cover the full liquid surface when the internal floating is no t rnade f rom steel.

The underlying assumption appears to be that f l i t is no t made f rom steel, the internal floating roof will be consumed by a fire and expose the full liquid surface.

(2) Recently, PETREX conducted fire tests witnessed by Professional Service Industries, Inc., Pittsburgh Testing Laboratory Division which seem to refute the idea that a luminum would be quickly consumed by fire.

NOTE: Support ing material is available for review at NFPA Headquar ters .

(3) The first test was with an a luminum honeycomb panel, with a 6-in. hole in the center, floating on gasoline. The gasoline in the hole was ignited and allowed to burn for 90 minutes. The a luminum a round the hole was no t consumed and the panel cont inued to float.

(4) The second test was with an a luminum honeycomb panel with a per imeter extrusion at tached and floating on gasoline. The per imeter extrusion is used to attach the seal to the floating roof. In the test the panel was posi t ioned so the per imeter extrusion was 6 in. f rom the test tank wall, which is typical construction.

The rim space between the test tank ad panel was ignited and allowed to burn for 12(? minutes. The panel was buckled in a few places and there was one small burn through. The a luminum was no t consumed and the panel con t inued to float.

(5) A third test was conducted by PETREX, but without an outside witness. This test was similar to the first test except the hole as 12 in. in diameter and burned for 120 minutes as required by U. S. Army Gorps of Engineers specifications.

The fire did no t grow beyond the 12-in. hole, the a luminum was not consumed and the panel cont inued to floaL

(6) In all three tests inheren t features of the a luminum honeycomb panel contr ibuted to the outcome of the tests. These features are:

(a) Aluminum is an excellent thermal conductor. The gasoline in the tank kept the a luminum panel cool and prevented distortion that could have exposed a greater gasoline surface for burning.

(b) Aluminum is non-combustible. (c) The honeycomb panel is inherent ly buoyant due to

thousands of l iquid tight cells (pontoons.) (d) The honeycomb aluminum panel floats in the liquid with

the bot tom surface displaced approximately 5 /16 in. above the liquid, similar to a foam blanket. A p u n c t u r e or void does no t permit liquid fuel to flow on top of the panel, as with a steel f loadng roof, being below the liquid level; nor does i t p e r m i t the escape of t rapped vapors, as with a skin and pon toon tloating roof, being above the liquid level. See Sketch A below.

!

. . . . '

. : . . .... - . . .

(7) We recognize that no internal floating roof will absolutely prevent a fire or no t sustain some damage during a fire. We submit that our tests have demonst ra ted that the a luminum honeycomb full surface contact internal floating roof has fire safety characteristics equivalent to a steel internal floating roof. An additional feature of the honeycomb roof is that it will no t sink when punc tured or t ipped.

NOTE: Support ing material is available for review at NFPA Headquar ters . COMMITTEE ACTION: Accept in Principle.

Revise text to read: 3-4.1 The following types of roof construction shall be considered

suitable for seal area protect ion systems: (a) steel double deck

55

NFPA 11 - - F97 ROC (Reprinted f rom A97 ROP)

I b) steel pon toon (c) full liquid surface contact, closed cell honeycomb, of metal

construction conforming to API 650 Appendix H requirements . All other types of roof construction shall require full surface

protect ion. COMMITTEE STATEMENT: The Commit tee feels that the performance of Type C roofs is acceptable based on fire test data submitted. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #CP6) 11- 10 - (3-7.1, 3-7.1(a) and (b), and Table 3-7.1.1): Accept SUBMITTER: Technical Commit tee on Foam

I RECOMMENDATION: 1. In 3-7.1, 3-7.1(a), and Table 3-7.1.1 revise by removing the word "fixed."

2. 3-7.1(b) add "Foam Hose Lines" to read as follows: (b) Foam moni tors or Foam Hose Lines.

SUBSTANTIATION: This section should include a reference to foam hose protect ion. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMM1TI'EE ACTION:


(Log #3) 11- 11 - (5-3.2): Reject $UBMITTER: Emilio R. Nieves, Oxy Peru RECOMMENDATION: Replace existing section 5-3.2 by the following new s t a t emen t

"As far as it is practical, the supply of foam concentrate, should no t d e p e n d on energy source o ther than its own." SUBSTANTIATION: In remote locations, where fire water systems are diesel engine driven and the electrical supply is self generated, a failure in the generator(s) will result in the impai rment of the foam fire f ighting equipment .

The use of electrical driven pumps to propor t ion foam concentrate-water should be considered improper , if no t dangerous, and will make necessary the use of portable electrical generator to drive the electrical pump.

In my opinion, foam equ ipment should be bladder balanced pressure or n i t rogen /a i r driven type. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The reliability of power supplies is addressed in 5-3.1 NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #CP7) 11- 12 - (Chapter 6 (New)): Accept SUBMITTER: Technical Commit tee on Foam RECOMMENDATION: Add new Chapter 6 on Marine Applications, and r enumber existing Chapters 6 and 7 as Chapters 7 and 8.

Chapter 6 Marine Systems 6-1 GENERAL. 6-1.1 All requi rements of NFPA 11, "Standard for Low-Expansion

Foam shall apply to merchan t vessel foam systems, except as modif ied by this chapter.

5-2 Fixed Low Expansion Foam Systems Protect ing Machinery Spaces

6-2.1 Low expansion foam systems for fire extinguishing systems protect ing machinery spaces shall be capable of discharging a sufficient quantity of foam to provide a foam depth of at least [5 in. (152.4mm) over the largest single area over which fuel oil is likely to spread within 3 to 5 minutes. The system shall be capable of generat ing foam suitable for extinguishing hydrocarbon fires. Means shall be provided for effective distribution of the foam th rough a pe rmanen t system of piping a n d control valves to suitable discharge outlets and for the foam to be effectively directed by fixed foam oudets onto o ther fire hazards in the protec ted space.

6-2.2 System controls shall be readily accessible, simple to operate and grouped together in as few locations as possible at positions no t likely to be cut off by a fire in the protec ted space.

6-3 FIXED DECK LOW EXPANSION FOAM SYSTEMS 6-3.1 The foam system shall be capable of delivering foam to the

entire cargo tanks deck area, as well as into any cargo tank, the deck of which has been ruptured.

6-3.2 The main control station for the system shall be located outside the cargo area, adjacent to the accommodat ion spaces and readily accessible and operable in the event o f fire in the main area ~rotected. 6-3.3 Operat ion of a deck foam system at its maximum foam

solution flow rate shall still permi t the simultaneous use of other devices operating f rom the main system.

6-3.4 The rate of application of foam solution for spill fires on deck shall no t be less than the greatest of the following:

A. For Hydrocarbon Fuels (1) 0.16 gpm/ sq f t (6.52 l /min/m2) over 10 percent of cargo

tanks deck area, where cargo tanks deck area is the maximum breadth of the ship multiplied by the total longitudinal extent of the cargo tank spaces or,

(2) 0.24 g p m / s q f t (9.78 l /min/m2) of the horizontal sectional area of the single tank having the largest such area (Note: This is for a single tank incident, ff more than one tank can be involved in an incident, the application rate should be applied over the total number of tanks that can be involved.) or,

(3) 0.07 gpm/sclf t (28.52 l / r a in /m2) of the area protec ted by the largest monitor, such area being entirely forward of the monitor, but no t less than 330 gpm (12501/min) .

B. For Polar Solvent Fuels (1) 10 percent of the highest foam application rate for the polar

solvent fuel that can be t ranspor ted by the ship times the cargo tanks deck area, where cargo tanks deck area is the maximum breadth of the ship multiplied by the total longitudinal extent of the cargo tank spaces or,

(2) 45 Percent of the highest foam application rate times the area pro tec ted by the foam moni tor or,

(3) the highest foam application rate for the polar solvent fuel that can be u-ansported times the area of the largest tank. (Note: This is for a single tank incident. If more than one tank can be involved in an incident, the application rate should be applied over the total number of tanks that can be involved.)

6-3.5 Discharge Duration - Sufficient foam concentrate shall be supplied to ensure at least 30 minutes of operation.

6-4 Foam Outlet Devices - At least 50 pe r cen t of the foam solution supply rate shall be delivered f rom each monitor .

Exception: On tankers less than 4000 tons dead weight, hand hoselines only may be installed provided that the capacity of each hand hoseline is at least 25 percent of the total foam solution flow rate.

6-5 Monitors. 6-5.1 The capacity of any moni tor shall be at least 0.07 gpm/sq f t

(2.85 l / r a i n / m 2 ) of the deck area protec ted by that monitor, with such area be ingen t i re ly forward of the monitor . The capacity of each moni tor shall be no t less than 330 g p m (1250 lpm).

6-5.2 The distance f rom the moni tor to the furthest extremity of the protected area forward of the moni tor shall be not more than 75 percen t of the moni tor throw in still air conditions.

6-5.3 A foam moni to r and hand hoseline connect ions shall be situated both por t and starboard at the f ront of the accommodat ion spaces facing the cargo tanks deck.

Exception: On tankers of less than 4000 tons dead weight, hand hoseline connect ions only may be situated both por t and starboard at the front of the accommodat ion spaces facing the cargo tanks deck.

6-6 Hand Hoselines. 6-6.1 Hand hoselines shall be provided to ensure flexibility of

action dur ing firefighting operat ions and to cover areas obstructed from the monitors. The capacity of any hand hoseline shall be not less than 110 gpm (416.4 Ipm) and the h a n d hoseline throw in still air conditions shall be no t less than 50 feet (15.3 meters). The number of foam h a n d hoselines provided shall be not less than four. The number and location of foam solution outlets shall be such that foam from at least two h a n d hoselines can be simultaneously directed onto any part of the cargo tanks deck area.

6-7 Isolation Valves. 6-7.1 System control valves shall be provided in the water, foam

concentrate and foam solution mains where this is an integral part I of the deck foam system, immediately forward of any moni tor aPdOSition, to isolate damaged sections from those mains. In

dition each moni tor and hose station shall have an isolation valve.

6~ Hangers, Supports, and Protection of Pipe Work 6-8.1 Where there is a possibility of explosion, pipework shall be

routed to afford the best protect ion against damage. 6-8.2 All hangers and piping supports shall be designed for

marine applications. Attachments can be made to steel members and equ ipment supports subject to review and approval by the Authority Having Jurisdiction.

56

NFPA 11 m F97 ROC (Reprinted f rom A97 ROP)

SUBSTANTIATION: The Commit tee feels that there is a need for mar ine applications and wishes to address this subject in the standard. COMMITIT, E ACTION: Accept. NUMBER OF COMMrlWEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrITEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 1 ABSTENTION: 1 NOT RETURNED: $ Jesclard, Lake, Nazario

EXPLANATION OF NEGATIVE: PURVIS: Information in Chapter 6 draft is inadequate and in

certain areas contradicts the existing U.S. Coast Guard regulations. For example the operating time for a hydrocarbon type system has no t b e e n defined. As stated the proposed design criteria is based on a spill fire. However in actual applications the fire scenario will likely be much worse th2~ a spill fire on the deck area. In br ief the chapter need fur ther rewrite and has too many discrepancies and errors to make it acceptable. EXPLANATION OF ABSTENTION:

MELDRUM: My reasola for abstention was simply because I did no t have an opportuni ty to compare the proposed Chapter 6 with the current requi rements of the of the US Coast Guard, so I was reluctant to vote ei ther for or against the proposal.

(Log #2) 11- 13 - (6-3.3(0): Accept in Principle SUBMITTER: Fred M. Linde, National Foam Inc. RECOMMENDATION: Delete (f) entirely

"foam quality (expansion and 1 /4 drain time)" SUBSTANTIATION: I note with interest requi rement (f) for testing foam systems foam quality.

This particular test has in the past been referred to as a laboratory type test in the appendix.

eference 1988 edit ion paragraph A-5.2.4 W h e n used as a laboratory type test under tightly controlled test

field conditions it is a very useful tool in the design of discharge devices and foam concentrate formulations. It also relates very well to compare full size devices against miniature devices used for fire testing.

However this particular test is at best extremely difficult to control under field conditions. Appendix C even alludes to this and indicates sampling variations that may create up to several hund red percen t error in the recorded results. In addit ion to sampling variations of this magni tude there are no specified criteria to meet.

Paragraph 6-3.3 specifically defines the requ i rement for acceptable ranges of foam concentrat ion but no requ i rement for expansion and drainage (1 /4 life). How can a test be required with no criteria to adhere to?

I f ind it very difficult to justify the cost to the ultimate end user of

~ erforming this test thai; produces nebulous results and doesn ' t ave to mee t any specific requirements . I can foresee all kinds of

problem being created by this test r equ i rement during acceptance and rout ine testing of foam systems.

It is also becoming more and more environmentally demanding to collect all discharge f rom fire protect ion systems. Whatever me thod is used to collect this discharge from the system may very well impact the character o f the f inished foam such that expans ion /dra inage results no longer represent what came out of the discharge device. COMMITTEE ACTION: Accept in Principle.

Delete last sentence arid revise (f) as follows: (f) Foam quality (expa.nsion and 1 /4 drain time) shall be

conduc ted or the foam discharge shall be visually inspected to ensure that it is satisfactory for the purpose in tended. COMMITTEE STATEMENT: The Committee feels that a discharge test is necessary. NUMBER OF COMMrI'FEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTFE ACTION:


(Log 05a) 11- 14 - (Appendix B): Accept in Principle SUBMITTER: Keith Otson, Ansul Fire Protect ion RECOMMENDATION: The following changes should be made to Appendix B Storage Tmak Protect ion Summary as follows:

I Hydrocarbon Not Applicable Top-of-seal protect ion with foam dam Applicat ion at 6.30 gpmTfd (12.2 I p m / m ~) Rates o f annular r ing area. All below-the

-seal with or without foam dam at 0.50 g p m / f C (20.4 l p m / m ~)

SUBSTANTIATION: None. COMMITTEE ACTION: Accept in Principle.

All applications below the seal with or without a foam dam 0.5 gpm/sqf t . COMMITTEE STATEMENT: Meets the in tent o f the submitter. NUMBER OF COMMITIT.E MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: $ Jesclard, Lake, Nazario

(Log #CP4) 11- 15 - (Appendix B): Accept SUBMITTER: Technical Commit tee on Foam

I RECOMMENDATION: Change head ing Append ix B for floating roof tanks to:

"Applicable floating roo f tanks (Open Top or Covered) Annular Seal Area." SUBSTANTIATION: Floating roof tanks are defined in 3-4.1 COMMI'VI'EE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACqYION:

AFFIRMATIVE: 24 NEGATIVE: 1 NOT RETURNED: 3 Jesclard, Lake, Nazario

EXPLANATION OF NEGATIVE: OLSON: I do no t feel the heading for Appendix B can be

changed to "Applicable Floating Roof Tanks (open top or covered) Annular Seal Area" because this summary table covers all types of tanks. I believe the current title "Storage Tank Protection Summary" is correct.

(Log #GP5) l l - 16 - (Appendix B): Accept SUBMITrER: Technical Commit tee on Foam RECOMMENDATION: Revise Appendix B, Top Side Foam Application, Hydrocarbon Applicat ion Rates, Floating Roof Tanks, as follows:

"0.3 g p m / s q f t (12 .2L/min / sq m) of annular r ing area, above seal, between tank wall and foam dam. (see 3-3)" SUBSTANTIATION: Further clarification of above seal PGrotection is needed.

OMMrrrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #GP1) I1- 17 - (Appendix E (New)): Accept SUBMITTER: Technical Commit tee on Foam RECOMMENDATION: Add Foam Environmental Issues Repor t to appendix E, rename existing appendix E to appendix F.

Appendix E Foam Environmental Issues E-1 Overview. Fire Fighting foams as addressed in this standard

serve a vital role in fire protect ion th roughout the world. Their use has proven to be essential for the control of f lammable liquid fire threats inheren t in airport operations, fuel farms and pe t ro leum processing, highway and rail t ransportat ion, mar ine applications, and industrial facilities. The ability of foam to rapidly extinguish f lammable liquid spill fires has undoubtedly saved lives, r educed proper ty loss, and he lped minimize the global pollut ion which could result f rom the uncontro l led burn ing of f lammable fuels, solvents, and industrial liquids.

However, with the ever increasing environmental awareness, recent concern has focused on the potential adverse environmental impact of . . . . . foam solution d i scharges . .The primary concerns are fish toxicity, blodegradab]hty, treatability m waste water t rea tment plants, and nut r ient loading. All of these are of concern when the end-use foam solutions reach natural or domest ic water systems. Additionally, the US Environmental Protection Agency has highlighted a potential p rob lem with some foam concentrates by placing glycol ethers and ethylene glycol, common solvent constituents in some foam concentrates, on the list of hazardous air pollutants under the 1990 Clean Air Act Amendments .

The purpose of this appendix is to: (a) Provide foam users with summary information on foam

environmental issues, (b) Highlight applicable regulatory status, (c) Offer guidelines for coping with regulations and provide

suggested sources for addit ional information, and (d) Encourage p lanning for foam discharge scenarios (including

pr ior contact with local waste water t rea tment plant operators). It should be emphasized that it is no t the intent of this appendix to

limit or restrict the use of fire f ighting foams. The foam committee

57

NFPA 11 m F97 R O C (Reprinted f r o m A97 ROP)

believes that the fire safety advantages of using foam are greater than the risks of ~otential environmental problems. The ultimate goal of this section Is to foster use of foam in an environmentally responsible harmer so as to minimize risk f rom their use. E-2 Scope. The information provided in this section covers foams

~or Class B combustible and f lammable liquid fuel fires. Foams for his purpose include prote in foam, f luoroprote in foam, fi lm-forming luoropro te in foam (FFFP), and synthetic foams such as aqueous i lm forming foam (AFFF). Some foams contain solvent consti tuents which may require

• eport ing under Federal, State, or Local environmental regulations. in general, synthetic foams, such as AFFF biodegrade more slowly b a n pro te in based foams. Prote in based foams may be more prone

to nu t r ien t loading and t rea tment facility ~shock l o a d i n g due to their h igh ammonia ni t rogen content and rapid biodegradat ion respectively.

This section is primarily conce rned with the discharge of foam solutions to waste water t rea tment facilities and to the environment . The discharge of foam concentrates, while a related subject, is a nuch less com m on occurrence. All manufacturers of foam concentrate deal with clean-up and disposal of spilled concentrate in their MSDS sheets and product literature.

E-3 Discharge Scenarios. A discharge of foam water solution is most likely to be the result o f one of four scenarios: manual fire f ighting or fuel blanketing operations, training, foam equ ipment system tests, or f ixed system releases. These four scenarios include events occurr ing at such lflaces as aircraft facilities, fire fighter t raining facility, and specml hazards facilities (which include f l ammable /hazardous warehouses, bulk f lammable liquid storage facilities and hazardous waste storage facilities). Each scenario is cons idered separately below:

E-3.1 Fir e Fighting Operations. Fires occur in many types of ocat ions and unde r many different circumstances. In some cases it is possible to collect the foam solution used, and in others, such as in marine fire fighting, it is not. These types of incidents would include aircraft rescue and fire f ighting operations, vehicular fires (cars, boats, train cars), structural fires with hazardous materials, and f lammable liquid fires. Foam water solution which has been used in fire f ighting operat ions will probably be heavily contaminated with the fuel or fuels involved in the fire. It is also likely to have been diluted with water discharged for cooling purposes.

In some cases, the foam solution used during fire depa r tmen t operat ions can be collected. However, it is no t always possible to control or contain the foam. This can be a consequence of the location of the incident or the circumstances sur rounding it.

Event4nit iated manual con ta inment measures are the operat ions usually executed by the responding fire depa r tmen t to contain the flow of foam water solution when condit ions and manpower permit . Those operat ions include the following measures:

(a) Blocking sewer drains. This is a common practice used to prevent contaminated foam water solution f rom enter ing the sewer system unchecked. It is then diverted to an area suitable for conta inment .

(b) Portable dikes. These are generally used for land-based operations. They can be set up by the fire depa r tmen t personnel d u r i n g o r after ext inguishment to collect run-off.

(c) Po r t ab l e booms. These are used for marine based operat ions which are set up to contain foam in a def ined area. These generally involve the use of floating booms within a natural body of water.

E-3.2 Training. Training is normally conduc ted under circumstances conducive to the collection of spent foam. Some ftre training facilities have had elaborate systems des igned and constructed to collect foam solution, separate it f rom the fuel, treat it and, in some cases, reuse the t reated water. At a minimum, most fire training facilities collect the foam solution for discharge to a waste water t rea tment facility. Training may include the use of special training foams or actual fire f ighting foams.

Training facility design should include a conta inment system. The waste water t rea tment facility must first be notified, and give permission for the agent to be re leased at a prescr ibed rate.

E-3.3 System Tests. Testing primarily involves engineered, f ixed foam fire extinguishing systems. Two types of tests are conducted on foam systems: acceptance tests, conduc ted pursuant to installation of the system, and maintenance tests, usually conduc ted annually to ensure the operability of the system. These tests can be ar ranged to

I pose no hazard to the environment . It is possible to test somesys tems ] using water or o ther non-foaming, environmentally acceptable liquids [ in the place of foam concentrates if the Authority HavingJ ] jurisdict ion permits such substitutions. [ In the execution of both acceptance and main tenance tests, only a ] small amoun t of foam concentrate should be discharged to verify I the correct concentra t ion of foam in the foam water solution.

Designated foam water test ports can be des igned into the piping system so that the discharge of foam water solution can be directed

to a control led location. The controlled location can consist of a portable tank which would be t ranspor ted to an approved disposal site by a licensed contractor. The remainder of the acceptance test and main tenance test should be conducted using only water.

E-3.4 Fixed System Releases, This type of release is generally uncontrolled, whether the result of a fire incident or a malfunction in the system. The foam solution discharge in this type of scenario may be deal t with by event-initiated operations or by engineered con~oainment systems. Event-initiated operat ions encompass the same temporary measures that would be taken dur ing fire depa r tmen t operations; portable dikes, floating booms, etc. Engineered conta inment would be based mainly on the location a n d type of facility, and would consist of holding tanks or areas where the contaminated foam water solution would be collected, t reated and sent to a waste water t rea tment facility at a prescribed rate.

E-4 Fixed Systems. Facilities can be divided into those without an engineered conta inment system and those with an engineered conta inment system.

E-4.1 Facilities Without Engineered Containment. Given the absence of any past requirements to provide containment , many existing facilities simply allow the foam water solution to flow out of the building and evaporate into the a tmosphere or percolate into the ground. The choices for conta inment of foam water solution at such facilities fall into two categories: event-initiated manual conta inment measures, and installation of engineered conta inment systems.

Selection of the appropriate choice is d e p e n d e n t on the location of the facility, the risk to the environment, the risk of an automatic system discharge, the frequency of automatic system discharges and any applicable rules or regulations.

"Event-initiated manual con ta inment measures" will be the most likely course of action for existing fadlities without engineered conta inment systems. This may fall under the responsibility of the responding fire depa r tmen t and include such measures as blocking storm sewers, constructing temporary dikes, and deploying floating booms. The degree of such measures will primarily be dictated by location as well as available resources and manpower .

The "installation of en${ineered conta inment systems" is a possible choice for existing facilities. Retrofitting an engineered conta inment system is costly, and may adversely affect facility operations. There are special cases, however, which may warrant the design and installation of such systems. Such action is a consideration where an existing facility is immediately adjacent to a natural body of water and has a high f requency of activation.

E-4.2 Facilities With Engineered Containment . Any engineered conta inment system will usually incorporate an oi l /water separator. During normal drainage condit ions (i.e., no foam solution runoff), the separator funct ions to remove any fuel particles from drainage water. However, when foam water solution is flowing the oil /water separator must be bypassed so that the solution is diverted directly to storage tanks. This can be accomplished automatically by the installation of motorized valves set to open the bypass line upon activation of the fixed fire extinguishing systems at the protected property.

The size of the conta inment system is d e p e n d e n t on the duration of the foam water flow, the flow rate, and the maximum anticipated rainfall in a 24-hour period. Most new conta inment systems will probably only accommodate individual buildings. However, some conta inment systems may be des igned to accommodate multiple buildings d e p e n d e n t upon the topography of the land and early identification in the overall site p lanning process.

The sps ecific type of con ta inment system selected will also be d e p e n d e n t upon location, desi red capacity and funct ion of facilities

l in question. They include ear then re tent ion systems, below ground tanks, open- top inground tanks, and sump and p u m p designs (i.e., lift stations) p iped to aboveground or inground tanks.

I The ear then retent ion designs consist o f open-top ear then berms, which usually rely upon gravity fed d r a i n a g e # p i n g from the pro tec ted building. They may simply allow the foam water solution to percolate into the ground, or may include an impermeable liner. Those containing an impermeable liner may be connec ted to a waste water t rea tment facility or may be suction p u m p e d out by a l icensed contractor.

Closed-top, below ground storage tanks may be the least environmentally acceptable design approach. They usually consist of a gravity-fed piping arrangement , and can be suction p u m p e d out or p iped to a waste water t rea tment fadUty. A potential and often f requent problem associated with this design is the leakage of g round water or unknown liquids into the storage tank.

Open-top, below ground storage tanks are generally l ined concrete tanks which may rely on gravity-fed drainage piping or a sump and pump arrangement . These may accommodate individual or muluple buildings. They must also accommodate the maximum

58

NFPA 11 - - F97 ROC (Reprinted from A97 ROP)

ant ic ipated rainfall in a 24-hour period. These are usually p iped to a waste water t r ea tmen t facility.

Aboveground tanks im:orporate a s u m p a n d p u m p a r r a n g e m e n t to closed, aboveg round tanks. Such des igns usually incorpora te the use o f one or m o r e submers ib le or vertical shaft, large capacity pumps . These may a c c o m m o d a t e individual or mul t ip le buildings.

E-4.3 New Facilities. T h e decision to design and install a f ixed foam water solut ion c o n t a i n m e n t system is d e p e n d e n t on the location of the facility, t he risk to the env i ronment , possible i m p a i r m e n t of facility operat ions, the design c.f the f ixed foam system (i.e., automatical ly or manual ly activated), the ability of the r e spond i ng fire d e p a r t m e n t to execute event-init iated c o n t a i n m e n t measures and any per t inen t regulat ions .

New facilities may no t warrant the expense and problems associated with c o n t a i n m e n t systems. Where the location of a facility does no t e n d a n g e r g r o u n d water or any natural bodies of water, this may be an acceptable choice, provided the fire d e p a r t m e n t has p l anned emergency manua l c o n t a i n m e n t measures .

Where condi t ions warrant the installation of eng inee red con t a inmen t systems, there are a n u m b e r of considerat ions. They include size of conta inment , design a n d type of c o n t a i n m e n t system, and the capability of the conta i r tment system to hand le individual or mult iple bui ldings .

Eng ineered c o n t a i n m e n t systems may be a r e c o m m e n d e d protective measu re where foam ex t inguish ing systems are installed in facilities that are immedia te ly adiacent to a natural body of water. These systems may also be p r u d e n t at new facilities where site condi t ions pe rmi t to avoid i m p a i r m e n t of facility operat ions.

E-5 Disposal Alternatives. T he uncon t ro l l ed release of foam solutions to file e n v i r o n m e n t shou ld be avoided. Alternative disposal opt ions are as follows:

(a) Discharge to a wastewater t r ea tmen t plant with or without pre treatuaent,

(b) Discharge to the env i ronmen t after pre t rea tment , (c) Solar evaporation, and (d) t ranspor ta t ion to a wastewater t r ea tmen t p lan t or hazardous

waste facility. Foam users, as part of their p l ann ing process, shou ld make

provisions to take the actions necessary to utilize whichever of these ! alternatives is appropr ia te for thei r si tuation. T he section below describes the act ions which may be taken, d e p e n d i n g on the disposal alternative which is chosen.

E-6 Collection a n d Pre t r ea tmen t of Foam Solutions Prior to Disposal .

E-6.1 Collection a n d Conta inment . T h e essential first step in employing any of these alternatives is collection of the foam solution.

A s no ted above, facilities tha t are protected by foam systems normal ly have systems to collect and ho ld fuel spills. These systems may also be used to collect a n d hold foam solution. Tra in ing facilities are, in i~llleneral, des igned so that foam solut ion may be collected and held.

refighters r e spond ing to fires which are at o ther locations should a t tempt , insofar as it is practical, to collect foam solution run-off with temporary dikes or o ther means.

E-6.2 Fuel Separation. Foam solut ion which has been d ischarged on a fire and s u b s e q u e n d y collected will usually be heavily con tamina ted with fuel. Since mos t fuels p resen t their own envi ronmenta l hazards a n d will in terfere with foam solut ion pre t rea tment , an a t t empt shou ld be made to separate as m u c h fuel as possible f rom the foam solution. As no ted above, the t endency of foam solut ions to form emuls ions with hydrocarbon fuels will interfere with the opera t ion of convent ional fuel-water separators. An alteruatave is to hold the collected foam solut ion in a p o n d or lagoon unti l the emuls ion breaks and the fuel may be separa ted by skimming. This may take f rom several hour s to severaldays . Dur ing this time, agitat ion shou ld be avoided to prevent the ,emulsion f rom reforming.

E-6-3 Pre t r ea tmen t Prior to Discharge. E-6-3.1 Dilution. Foam manufac tu re r s and foam users r e c o m m e n d

di lut ion of f oam solut ion before it enters a wastewater t r ea tmen t plant. The re is a range o f opin ion on the o p t i m u m degree o f dilution. I t is general ly cons idered tha t the concent ra t ion of foam solut ion in the p lan t in f luen t shou ld no t exceed 1700 p p m (588 gallons of p lan t mf luen t pe r gallon of f oam solut ion). This degree of di lut ion is normal ly sufficient to p reven t shock loading a n d foami ng in the plant. However, each w a s t e ~ t e r t r e a t men t p lan t m u s t be cons idered as a special case, and those p lann ing a discharge of foam solut ion to a wastewater t r ea tmen t facility shou l d discuss this subject with the opera tor of the facility in advance.

Dilut ing waste f oam solut ion 588 to 1 with water is an impractical task for mos t facilities, ,especially when large quant i t ies of foam solut ion are involved. The r e c o m m e n d e d p rocedure is to di lute the foam solut ion to the m a x i m u m a m o u n t practical a n d t h e n me te r the d i lu ted solut ion into the sewer a t a rate which will, based on the total vo lume of p l an t influent , p roduce a f oam solut ion concen t ra t ion of 1700 p p m or less.

For example , if t he discharge is to be made to a 6 mil l ion ga l /day t r ea tmen t plant, f oam solut ion could be d ischarged at the rate of 7 g p m (6,000,000 ga l / day divided by 1440 m i n u t e s / d a y divided by 588 equals 7 gpm) . T h e difficulties of me te r ing such a low rate of discharge can be overcome by first di lut ing the foam solut ion by 10 or 20 to 1, permi t t ing discharge rates o f 70 or 140 g p m respectively.

Dilution shou ld also be cons idered if the foam solut ion is to be d ischarged to the env i ronmen t in order to min imize its impact .

E-6-3.2 Defoamers. The use of de foamers will decrease, b u t no t el iminate, f oaming of the foam solut ion dur ing pumping , di lut ion and t rea tment . The foam m a n u f a c t u r e r should be consul ted for r e c o m m e n d a t i o n s as to the choice of effective de foamers for use with a part icular foam concentra te .

E-6-3.3 Othe r Pre t rea tments . Several chemical a n d mechanica l pre t r ea tments such as precipitat ion, coagulat ion, absorpt ion on activated carbon a n d ultra fi l tration (reverse osmosis) have been s tudied experimentally. The re was no known instance of these processes having been used in the field at the t ime of the prepara t ion of this documen t . Foam users shou ld contact the fo am manufac tu r e r for up-to-date in format ion on this subject.

E-7 Discharge of Foam Solut ion to Wastewater T rea tmen t Facilities. Biological t r e a tmen t of f oam solut ion in a wastewater t r ea tmen t facility is an acceptable m e t h o d of disposal. However, foam solutions have the potential to cause p lan t upsets and o ther p rob lems if no t carefully handled . The re are several reasons for this:

E-7.1 Fuel Contamina t ion . Foam solut ions have a t endency to emulsify hydrocarbon fuels a n d some polar fuels which are only slightly soluble in water. Water-soluble polar fuels will mix with foam solutions. T h e format ion of emuls ions will upse t the opera t ion of fue l /wate r separators and potentially cause the carryover of fuel into the waste s t ream. Many fuels are toxic to the bacteria in wastewater t r ea tmen t plants.

E-7.2 Foaming. The active ingredients in foam solut ions will cause copious foaming in aera t ion ponds , even at very low concentra t ions . Aside f rom the nuisance value of this foaming, the foaming process t ends to su spend activated s ludge solids in the foam. These solids can be carried over to the ouffall of the plant. Loss of activated s ludge solids can also reduce the effectiveness of the wastewater t rea tment . This could cause water quality p rob lems such as nu t r i en t loading in the water way to which the ouffall is discharged. Because some surfactants in foam solut ions are highly resistant to b iodegradat ion, nu i sance foaming may occur in the ouffall waterway.

E-7.3 BOD (Biological Oxygen Demand) . Foam solut ions have high BOD's compared to the normal inf luent of a vrastewater t r ea tment plant. If large quanti t ies of foam solut ion are d ischarged to a wastewater t r e a tmen t plant, "shock loading" can occur, caus ing a p lan t upset.

Before d ischarging foam solutions to a wastewater t r ea tmen t plant, the p lan t operator shou ld be contacted. This shou ld be done as part of the emergency p lann ing process. The plant operator will require, at a m i n i m u m , a Material Safety Data Sheet on the foam concentrate , an est imate of the five day BOD con ten t of the fo am solution, an est imate of the total vo lume of foam solution to be discharged, the t ime per iod over which it will be d i scharged and, if the foam concent ra te is p ro te in-based , an estimate of the a m m o n i a n i t rogen con ten t of the foam solution.

The foazn manufac tu r e r will be able to provide BOD and a m m o n i a n i t rogen data for the foam concentrate , f r om which the values for foam solut ion may be calculated. The o ther requi red informat ion is site-specific and mus t be developed by the operator of the facility f rom which the discharge will occur.

E-7.4 Foam concent ra tes or solut ions may have an adverse effect on microboilogically based oily water t r ea tmen t facilities. Th e en d user shou ld take due accoun t of this before d ischarging foam systems dur ing testing or training. E-8 Foam Produc t Use Repor t ing Federal (U.S.), State a n d Local env i ronmenta l jur isdic t ions have certain chemical repor t ing requ i rements , which apply to chemical const i tuents within foam concentra tes . In addi t ion there are also r equ i rements which apply to the f l ammable liquids to which the foams are be ing applied.

For example , according to the U.S. Envi ronmenta l Protect ion Agency (EPA) T h e following guidel ines mus t be adhe red to. E - 8 . 1 Releases of ethylene glycol in excess o f 5,000 p o u n d s are repor table u n d e r U.S. EPA Comprehens ive Envi ronmenta l Response Compensa t ion & Liability Act (CERCLA) Sect ions 102(b) & 103(a). Ethylene glycol is general ly used as a freeze po in t suppressan t in foam concentra tes .

E-8.2 As of J u n e 12, 1995 the EPA issued a final rule 60 CFR 30926 on several broad categories of chemicals , inc lud ing the glycol ethers. The EPA has no repor table quant i ty for any of the glycol ethers. Thus foams conta in ing glycol ethers (butyl carbitol) are n o t

59

NFPA 11 - - F97 R O C (Reprinted f r o m A97 ROP)

subject to EPA report ing. Consult the foam manufacturers MSDS to de termine if glycol ethers are conta ined in a particular foam concentrate.

E-8.$ The EPA does state that CERCLA liability continues to apply to releases of all compounds within the glycol e ther category, even if repor t ing is no t reqmred . Parties responsible for releases of glycol e thers are liable for the costs associated with cleanup and any natural resource damages resulting f rom the release.

E-8.4 The end user should contact the relevant local regulating authority regarding specific current regulations.

E-9 Environmental Propert ies of Fluorochemical Surfactants. Some fire f ighting agents contain surfactants. Two examples are AFFF agents and f luoroprote in foams. Fluorochemicals are organic (carbon-containing) compounds in which a por t ion of the hydrogen atoms have been r e p l a c e d b y f luorine atoms. Unlike chlorof luorocarbons (CFC's) and some o the r volatile f luorocarbons, f luorochemical surfactants are no t ozone deplet ing and are no t restricted by the Montreal Protocol or related regulations. Fluorochemical surfactants also have no effect on global warming or climate change.

Surfactants or surface active agents are compounds that have both a strongly "water-loving" por t ion and a strongly %cater-avoiding" port ion. Soaps and detergents are surfactants commonly used in cleaning products. Surfactants concentrate at the surface or boundary between two phases and they lower the surface tension of liquids in which they are dissolved. The water-avoiding part of f luorochemical surfactants is the f luorocarbon port ion.

Fiuorochemical surfactants have a proper ty that makes them uniquely suited for use in foams used to prevent or extinguish fires of f lammable liquids. They create the lowest surface tension of any ~nown class of surfactant. This low surface tension allows aqueous

films or foams containing these surfactants to spread over and seal the surface of hydrocarbon liquids, extinguishing the flames and preventing evaporation of the f lammable liquids. No other type of surfactant can do this as effectively. Thus, if all o ther factors are equal, fire f ighting agents containing f luorochemical surfactants can extinguish f lammable liquid fires more quickly and with smaller amounts of extinguishing agent than agents without f luorochemical surfactants. The many environmental advantages of this and the potential benefits to life and property are obvious.

There are environmental concerns with fluorochemical surfactants which must be kept in m i n d when using these products for extinguishing fires or for fire ext inguishment training, such as listed below:

(a) Fluorochemicai surfactants, like all surfactants, have toxicity. (b) Like o ther surfactants, they cause foaming. (c) Like some surfactants, they are persistent; in fact, the

f luorochemical port ions of these surfactants are no t known to fully b iodegrade .

(d) Also like some o ther surfactants, they are mobile in the environment . They can move with water in aquatic systems and leach th rough soil.

(e) In some cases, f luorochemical surfactants may have some affinity for living systems.

In the following paragraphs, we will explain what each of these propert ies mean and what this means in terms of how these compounds should he handled.

E-9.1 Toxicity of Fluorochemical Surfactants. Firefighting agents, used responsibly and following label and material safety data sheet instructions, pose little toxicity risk to people. However, some toxidty does exist. The toxicity of the surfactants in fire f ighting foams, including the f luorochemical surfactants, is a reason to prevent unnecessary exposure to people and to the environment. It l"s a reason to contain and properly treat AFFF wastes whenever feasible. One should always make plans to contain wastes f rom

!training exercises and to treat t hem following the supplier 's disposal : r ecommenda t ions as well as the requi rements of locSal authoriti-es.

Water that foams when shaken due to contamination f rom I firefighting foam should no t be ingested. Even when foaming is no t present, it is p ruden t to evaluate the likelihood of drinking water supply contaminat ion, and to use al ternate water sources until one is certain that surfactant concentrat ions of concern no longer exist. Suppliers o f firefighting foams should be able to assist in evaluating the hazard and r ecommend ing laboratories that can do appropriate analysis when necessary.

E-9.2 Fluorochemicai Surfactants and Foaming. Fluorochemical surfactants can cause foaminl~ at very low concentrations. This can cause aesthetic problems in rivers and streams, and both aesthetic and operat ional p roblems in sewers and wastewater t rea tment systems. When too much firefighting foam is discharged at one time to a wastewater t rea tment system, serious foaming can occur. The

i bubbles of foam that form in the t rea tment system trap and bring flocks of the activated sludge that treat the water in the t rea tment

i system to the surface. If the foam blows o f f t h e surface of the

t rea tment system, it leaves a black or brown sludge residue where the foam lands and breaks down.

If too much of the activated sludge is physically removed from the t rea tment system in foam, the operat ion of the treamaent system can be impaired. Other waste passing th rough the t reatment system will be incompletely t reated until the activated sludge concentrat ion again accumulates. For this reason, the rate of firefighting foam discharge to a t rea tment system has to be controlled. For this reason, the rate of f ireflghting foam discharge to a t rea tment system has to be controlled. Somewhat h igher firefighting foam discharge rates may be possible when anti-foaming agents are used. Foam concentrate suppliers should be cont rac ted for guidance on discharge rates and effective anti-foaming agents.

E-9.3 Persistence of F1uorochemical Surfactants. The f luorochemical port ions of f luorochemicai surfactants are known to be very resistant to chemical and biochemical degradation. This

i means that while the non-f luorochemical p o r t i o n of these sur fac tan t s may break down, a persistent f luorochemical por t ion will remain. The persistent f luorochemicai por t ion is most likely to still be a surfactant. This means that after f luorochemical surfactant containing firefighting waste are fully treated, the waste residual could still fo rm some foam when shaken. It could also still have some toxicity to aquatic organisms if it is no t sutficientiy diluted. Some non-fluorochemical surfactants are resistant to t rea tment too. The most desirable t rea tment methods for large volume firefighting waste streams containing f luorochemical surfactants are physical chemical pre t reatments that remove most o f the f luorochemical surfactant prior to discharging the residual waste to a wastewater t rea tment system.

E-9.4 Mobility of Fluorochemical Surfactants. Tests and exper ience have shown that some fluorochemical surfactants can leach through at least some soil types. The resistance of f luorochemical surfactants to biodegradat ion makes the mobility of such surfactants a potential concern. While a readily degradable c o m p o u n d is likely to degrade as it leaches th rough soil, this won ' t happen to a f luorochemical surfactant. Thus, if allowed to soak into the ground, f luorochemical surfactants that d o n ' t become b o u n d to soil components may eventually reach g round water or flow out of the ground into surface water. If adequate dilution has no t occurred, they may cause foaming or concerns about toxicity. Therefore, it is inappropriate to allow training waste to continually seep into soil especially in areas where water resources could be contaminated.

Fluorochemical surfactants that enter aquatic environments may b ind to solid materials, but this b inding would be reversible and temporary. Fluorochemical surfactants are thus expected to move with the flowing water in aquatic environments until they reach and dilute to extremely low concentrat ions in the oceans.

E-9.5 Fluorochemical Surfactants and Living Systems. Fluorochemical surfactants or their persis tent degradat ion products are likely to be anionoic or negatively charged compounds. As such, they could form strong ion pairs with positively charged molecules. Since positively charged molecules are frequently found in living organisms this could be a mechanism of affinity for living systems. The release of f luorochemical surfactants back into non- living port ions of the envi ronment could be slow because these ionic associations could be strong. SUBSTANTIATION: With ever mcreasing environmental awareness, recent concern has focused on the potential adverse environmental impact o f foam solution discharges. It is the Foam Commit tee 's in tent to include this appendix to provide foam users with summary information on foam environmental issues, highlight applicable, regulatory, status, offer guidelines for.cop.gin with - regulauons, prowde suggested sources for additaonal information, and encourage p lanning for foam discharge scenarios (including contact with local waste water t rea tment plant operators). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NEGATIVE: 1 NOT RETURNED: $ Jesclard, Lake, Nazario

EXPLANATION OF NEGATIVE: MELDRUM: My reason for the negative vote on the proposed

Appendix E, Foam Environmental Issues, relates to page 4 with the paragraph beginning "FIourochemical surfactants have a property ... and ending ... and property are obvious."

This paragraph is inappropriate even as appendix material in an NFPA Standard. It is too "selly', o ther foam compounds have no similar t reatment , and it is irrelevant to the discussion. In addition, it is not entirely technically correct, inasmuch as the film is not an effective vapor suppressant on some aromatic hydrocarbons.

60

NOTE: This portion of the Report contains the Comments on the Report on Proposals that appears on the preceding pages regarding NFPA 11.

Report of the Committee on

Foam

Christopher P. Hanauska, Chair Hughes Assoc. Inc., MN [SE]

Laurence D. Watrous, Secretary HSB Profe~,~ional Loss Control Inc., TN [I]

William M. Carey, Underwriters Laboratories Inc., IL, [RT] Salvatore A. Chines, Industrial Risk Insurers, CT [I]

Rep. Industrial Risk Insurers W. D. Cochran, Houston, TX [SE] Gene DiClementi, Glenview Fire Dept., IL [El Arthur R. Dooley, Dooley Tackaberry, Inc., TX [IM]

Rep. Nat'l Assn. of [~re Equipment Distributors Inc. Francis X. Dunigan, AngusFire North America, NC [M] John A, Frank, Kemper Nat'l Insurance Cos., GA [I] Robert A. Green, Public Service Electric & Gas Co., NJ [U]

Rep. Edison Electric Inst. LarryJesclard, Engineered Fire Systems, Inc., AK [IM]

Rep. Fire Suppression Systems Assn. Dennis C. Kennedy, RoffJensen & Assoc. Inc., IL [SE] John A. Krembs, M&M Protection Consultants, IL [I] John N. McConnell, Chemguard, Inc., TX [M]

Rep. American Fire Sprinkler Assn., Inc. Robert C. Merritt, Factory Mutual Research Corp., MA [I] Richard F. Murphy, Cranford, NJ [SE] Francisco N. Nazario, Exxon Research & Engr Co., NJ [U]

Rep. American Petroleum Inst. Edward C. Norman, Aqueous Foam Technology, Inc., PA [SE] Keith Olson, Tyco Int'l Ltd., WI [M] Richard E. Ottman, 3M, MN [M] Fay Purvis, Nat'! Foam, In~, PA [M] Niall Ramsden, Resource Protection Int'l, England [SE] Tom Reser, Edwards Mfg. Inc., OR [M] Howard L. Vandersall, Lawdon Fire Services, Inc., CA [SE] Klaus Wahle, U.S. Coast Guard, DG [El B. J. Walker, Walker & Assoc., MO [SE] Joseph O. Welch, Emergency One, Inc., FL [M] Michel Williams, Ulmimar Ganada, Inc., Canada [U]

Rep. NFPA Industrial Fire Protection Section Jack Woycheese, Gage-Babcock & Assoc. Inc., CA [SE]

Alternates

William M. Cllne, Factory Mutual Research Corp., MA [I] (Alt. to IL C. Merritt)

Donald IL Coy, 3M/Performance Chemicals, MN [M] (Alt. to R. E. Ottman)

Dennis L. Doherty, Industrial Risk Insurers, CT [I] (Alt. to S. A. Chines)

Brian IL Foster, HSB Professional Loss Control, FL [I] (AlL tO L. D. Watrous)

Peter E. Getehell, Kemper Nat'l Insurance Cos., PA[I] (Alt to J. A. Frank)

Brian IL Foster, HSB Professional Loss Control, FL [I] (Alt. to L. D. Watrous)

Peter E. Cetehell, Kemper Nat'l Insurance Cos., PA [I] (Alt to J. A. Frank)

Matthew T. Gustafson, U.S. Coast Guard, DC [El (Alt. to IL Wahle)

Kevin P. Kuntz, M & M Protection Consultants, NJ Ill (Alt. to J. A. Krembs)

Norbert W. Makowka, Nat'l Assn. of Fire Equipment Distributors (NAFED), IL [IM] (Alt to A. R. Dooley)

Terry Planck, Emergency One, Inc., FL [M] (Alt. to J. o . Welch)

David K. Riggs, SOTEC, LA [IM] (Alt. to L Jesclard)

Joseph L. Scheffey, Hughes Assoco Inc., MD [SE] (Alt. to C. Hanauska)

Steven F. Vieira, Tyco Int'l, Ltd., RI [M] (AlL to K. OIson)

Christopher L. Vollman, RolfJensen & Assoc. Inc., TX [SE] (Alt. to D. C. Kennedy)

Edward A. Watson, Exxon Research & Engr Co., NJ [U] (Alt. to F. N. Nazario)

Kenneth W. Zastrow, Underwriters Laboratories Inc., IL [RT] (Alt. to W. M. Garey)

Nonvoting

D. N. Meldrnm, Malvem, PA (Member Emeritus)

Staff Liaison: David R. Hague

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the back of this document.

Committee Scope: This Committee shall have primary responsibility for documents on the installation, maintenance, andnse of foam systems for fire protection, including foam hose streams.

This portion of the Technical Committee Report of the Committee on Foam is presented for adoption.

This Report on Comments was prepared by the Technical Committee on Foam and documents its action on the comments received on its Report on Proposals on NFPA 11-1994 edition, Standard on Low-Expanslon Foam as published in the Report on Proposals for the 1997 Annual Meeting.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Foam, which consists of 29 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

61

N F P A 11 - - F 9 7 R O C

(Log #1 ) I1- 1 - (3-4.1(,3) ): Reject SUBMITTER: Millard H. Jones, Jr., HMT, Inc. COMMENT ON P R O P O S A L N O : 11-9 R E C O M M E N D A T I O N : D e l e t e 3 4 . 1 ( c ) . S U B S T A N T I A T I O N : By way o f i n t r o d u c t i o n , m y n a m e is Mi l lard Jotms, p r e s i d e n t of H M T , Inc. H M T , Inc. is involved in file repair and ren,~,'.ttiol, of ahovegrourld storage hulks featuring patented products such as internal steel and ahmtinum floating roofs. We arc cllrrenl nmml)ers of die NFPA listed under Gary E. Tesch. I h;tvt: personally I)ceu in tile tank husiness for over 95 years and anl sh , , ked t,, find that the NFPA is on the verge of classifying tim Petrex h ,me~c .mh roof iii tim same fire resistant category as tile pl)lltOOtl Slt'ci I'l~ot".

()vet the past 16 or 17 years I have watched ,as Petrex, with very liulr succ~ess, has taken their fire test film to different organizations :tn,t , ust,:,mers in an effort to convince people that tbeir honeycomb r . , , f win help prevent or reduce fires on internal floating roof tanks. '~.qw all -1 a sudden has tile NFPA decided to endorse diis roof? Thee inf, wnlati,nl that they have carried a round in tile past has riot ch:tuged. ~mr h ~ their roof prevented umk fires.

Tltrrc has Hevt:l beer| a tank fire in any t~ulk that has our alullfinUln l~Ollh,tJll or steel pan floatirlg roofs. However, HMT ,I,~cs liot advertise that these r o o t will prevent or help to prevent t:mk fires. It is in 12tct well recognized, witltin die entire petroleum i tJ,tustry, dial tile prohability of a tank catching fire with an internal fl .ating r . o f is extremely remote. If an internal floating roof tank catches iire, it is usually caused hy an outside source such as [i!4hting, which in turn causes an explosion that no roof can withstand.

Tim pr~d~ahility of an explosion in an internal floating roof tank is more likely wherl the tank is out of service and hot work is being ih~lle t itlltq" ~tl bx~,, ~ r a ) (ve tile roof. Roofs tilat can trap and hide val,,,rs, such as tile honeycomh arid tile steel pontoon, present a Lu ~l cater ,lallger than steel pan or ~duminum pontoon roofs tilat ,::tit easily I ,e ,I lecke(l for vapors with a meter.

I have i:onducted an internal survey widl managers mid cuq)loyecs of ttMT that have a mininmm of 15 years experience in the tank busim:ss. None of these surveyed know of any tarik fires with internal floating roots tilat occurred witb tile tank in service unless iguited by art outside source, such ,as lighming. All of file cases resuht:d in an explosion. Gulf Oil in Toledo, Ohio had two tmlks struck hy lightning in the late 70's. In both cases they lost their intertml tloatirJg roofs due to the m.xs.sive explosion. Since lit;t! time, ahhough thet'e may have been isolated instances, we do n~! ktlt~w of any tank fires involving internal floating roofs with the tank in service. However, we do know of tilree incidents where expIosiotis happened while tile tank was out of service undergoing repairs |hat involved hot work.

[n c(,n( lusi(~th 1 feel that the NFPA is endorsing a specific ~ .mpany ' s pr,,dm:t with inconclusive evidence concerning a pr.l~lem Iha[ is athnost non-existent. I'm certain your response will he that the NFPA is not endorsing a particular company's product, hut is simply givillg tile honeycond) roof :m equal fire resistance ratiug as the it~ternal steel pontoon roof. I would counter by saving that most uninformed people that turu to file NFPA st;U~dar, t and glance at it while writing a specific~ltion would mistake this :is an enclorsement ~md I can assure you that Petrex wmthl flo.,I tht ~ market widl literature dial highlights that section ot the NFPA.

Please li)rward to me, at yottr earliest convenience, .all of the int0rmation that ha.s led the NFPA to dlis conchtsion. Tile only tests that are sightecl in you submittals are controlled tests sponsored by Petrex. Do you have statistical data that illustrates actual tank fires where die Petrex roof has minimized or prevented a fire? How does the NFPA propose to check the honeycomb panels for vapor p~Sor to hot work being perfomled in a tank? COMMITTEE ACTION: Reject. COMMITTEE S T A T E M E N T : There was considerable discussion concerning the fire tests conducted by tile roof manufacturer, tile potential for sinking and leaking of die roof in question and the characteristic ~f full surface liquid surface contact of the roof. The roof could be cnusidered equal to the pontoon roof but it did have different characteristics. Additional considerations were its bouvaney, its ability to snpress vapor be~xuse of its full surface coil{act al,:l its behavior when exposed to explosions caused by lightning. N U M B E R O F C O M M I T T E E M E M B E R S E L I G I B L E T O V O T E : 29 V O T E O N C O M M I T T E E A C T I O N :

,M:FIRMATIVE: 29

(Log #2) 11- 2 - (Chapter 6): Accept in Principle in Part S U B M I T T E R : P. F. Weber, SeaRiver Maritime, Inc. C O M M E N T O N P R O P O S A L N O : 11-12 R E C O M M E N D A T I O N : 1. In its current form, Chapter 6 Marine Systems should be reconsidered in its entirety.

2. NFPA should defer file revision cycle on NFPA 11 for a year until a marine industry consensus can be reached.

3. NFPA should reconsider file NFPA 301 committee's decision to have tile marine foam standards in NFPA 11. S U B S T A N T I A T I O N : In explaining our comments, it is necessary to explain our position. The Coast C, uard is encouraging tile incorporation of a significant body of rules into commercial standards. In tile past, the incorporated staxldards were either existing standards for commerci,'d components or were st,'mdards whose content duplicated information in the Code of Federal Regulations (CFR). Examples of tile former were ANSI and MSS standards for piping components and examples of tile latter were tile portions of ASME Boiler and Pressure Vessel Code, ANSI B31.1 arid die National Electrical Code.

Changes to Coast Guard rules in tile CFR are made d~rough a formalized federal rulemaking process. As part of this process, tire Coast Guard publishes its rule changes for public conmaent. After reviewing dre public's comments, tile Coast Guard completes tbe final rule.

When tile Coast Cuard incorporates a commercial standard by reference, it leaves die revision process for the standard in tile hands of the standard's publisher. It then becomes incumbent on tile industry to track all of tile potential changes from a wide range of standards organizations. Unfortunately, by the time tile Coast Guard adopts tile latest revision of a standard, it is well beyond tile revision cycle of tile standard, and die public is only left with commenting on tile reference i not tile changes to dm referenced documents .

At tbe sub-committee meeting, the Coast guard representative presented a draft of Chapter 0 for NFPA 11. His intention was that we would revise it as a committee to be presented at the next NFPA 11 committee meeting to finalize tile chapter. In die course of out meeting, bowever, we determined dial dlere was no real consensus on what situations should require protection. In addition, fllere were some (including our representative) who felt that if tile Coast Guard was going to limit file use of odler technology permitted under NFPA to that which met additional Coast Guard requirements, there would he no advantage to die industry to move tilese requirements out of" tile CFR.

Furthermore, the Coast Guard intended NFPA 301 to be a unified code incorporating tile information cont:fined in a number of subchapters ill die CFR. Much of this information is stated nmltiple times in these suhchapters and a single, concise code would probably be a very good idea. (Once the NFPA 801 dr~fft is completed, we expect to bare extensive comments but that is not for tlliS forum). Based on what we were told at file 8 August meeting, the NFPA 301 Committee has cbosen to incorporate certain codes, induding NFPA 11, by reference t id ie r than write chapters for NFPA 301.

We believe that dlis decision should be reconsidered. The following reasons apply not only to NFPA 11 but to any other code to which file NFPA 301 Committee intends to have a marine chapter added.

- There is no tanker (or marine) industry representation on NFPA I I. Tile only representative who are at ,all marine related are tile foam manufacturers who have different interests.

- There has already been significant discussion by tile NFPA i 1 Committee that, perhaps, fire proposed marine chapter does not reflect die same stand~trd of care as die rest of the standard. Even though marine interests may believe that die special situations of shipboard firefighting warr~mt tire current level of protection, outsiders may overrnle us and impose significantly stricter stanckxrds. In this case, the Coast Guard may decide not to incorporate die standard an all of this effort will be rendered fruitless.

- NFPA 11 (and others) will become another layer removed from the core Coast Guard rnlemaking process which will require marine interests' attention to revision cycles.

If tile committee has filrther questions regarding our comments, we would be pleased to discuss them in person at file upcoming committee meeting. C O M M I T T E E A C T I O N : Accept in Principle in Part.

Items l and 2 are Accepted in Principle. item 3 was Rejected because die Marine chapter belongs in

NFPA 11.

62

N F P A 11 - - F9 7 R O C

COMMITTEE STATEMENT: The Committee agreed to slip cycle by 6 months to allow input from the Marine Community. A Task Group was formed and. met in Houston, TX in February to further develop the proposed chapter. See Committee Comment 11-3 (Log #CC2). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 29 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 29

(Log #CC2) 11- 3 - (Chapter 6): Accept SUBMITTER: Technical Committee on Foam COMMENT ON PROPOSAL NO: 11-12 RECOMMENDATION: Revise Chapter 6 as follows:

Chapter 6 Marine Chapter

6-1" General: This cha~pter covers design information for the use of low expansion foam systems that are necessary for marine applications where required by NFPA 301 or by the Authority Having Jurisdiction. The provisions of Chapters 2, 3, 4, and 5 of this standard are not applicable unless specifically referenced.

6-1.1 * All components shall be suitable for their intended application andshall be approved for use in a marine environment.

6-1.1.1 Each manufacturer shall maintain a system design manual describing basic acceptable system design arrangements and denoting each of the manufacturer's products within the system.

6-1.2 Foam concentrates shall be approved.

6-1.2.1 The concentrate used in a foam system for protecting a flammable or combustible liquid shall be approved for hydrocarbons in accordance with a test method equivalent to the 100 sq ft (9.29 m ~) hydrocarbon method given in appendix F.

Four consecutive fire tests shall be completed, two using sea water and two using fresh water.

6-1.2.2" Concentrates intended for use on polar solvent systems shall be approved for hydrocarbons in accordance with 6-1.2.1 and approved for use on polar solvents in accordance with a method equivalent to Underwri~:ers Laboratories Standard for Safety, UL 162.

6-1.3 Foam Supply. The foam supply shall be in accordance with 2-3.2.2.

6-1.4 Water Supply Characteristics. The water supply shall be in accordance with 2-2.1.1, 2-2.1.9, and 2-2.1.3.

6-1.5 The foam system shall be capable of being actuated, including introduction of foam solution into the foam main within three minutes of notification of a fire.

6-9 Fixed Low Expansion Foam Systems for Machinery Spaces.

6-2.1 * Where installed, or required by NFPA 301, systems protecting machinery spaces shall be capable of discharging a sufficient quantity of expanded foam to provide a foam depth of at least 6 inches (150 mm) over the largest area over which oil is likely to spread. The minimum foam solution application rate shall be 0.16 gpm/sq ft (6.5 l / rn in /m ~) for a minimum of 5 minutes. The system shall be capable of generating foam suitable for extinguishing hydrocarbon fires. Means shall be provided for effective distribution of the foam through a permanent system of piping and control valves to suitable discharge outlets and for foam to be effectively directed by fLxed foam oudets. The foam expansion ratio shall not exceed 12 to 1.

6-2.1.1 Where a deck foam system is also installed, the foam supply and proportioning system need not be separate. The quantity of foam concentrate shall be that required to meet the single largest requirement.

6-2.2 System controls shall be readily accessible, simple to operate and ~rouped together in a location accessible during fire conditions in the protected area. Instructions in clear and permanent lettering shall be affixed to the equipment or in a position adjacent thereto. Remotely controlled devices shall have local mechanical override.

6-3 Fixed Low Expansion Foam Systems On Deck For Petroleum And Chemical Tankers.

6-3.1 * Purpose. The purpose of this section is to provide guidance for the design and arrangement of deck foam systems that are expected to provide the following performance:

• Extinguish deck spill fires and maintain a foam blanket while hot metal cools.

• Control or suppress cargo manifold fires except those involving three dimensional pressurized liquidfires.

• Suppress or control tank fires involving a portion of the cargo area assuming that the top of the tank(s) within the design area are open to weather and the trajectory of the foam is not obstructed.

• Provide protection for the crew while arrangements are being made to abandon ship.

• During lightering operations the deck foam system flowing water should protect the exposed vessel from fire on an adjacent ship while preparations are made to get the exposed vessel under way.

• The deck foam system is not intended to provide extinguishment, suppression or control of incidents resulting f rommajor explosions or collisions which cause the fire to exceed the area of the single largest tank.

• The deck foam system shall be designed and arranged to withstand the effects of weather, vibration, corrosion, strain and impact expected during the ship's operation..

• Suppress vapors from an unignited spill on deck.

6-3.2 Control Station.

6-3.2.1 Control Station Placement. The main control station for the system shall be located aft of the cargo area and readily accessible and operable in the event of fire in the main area protected.

6-3.2.2* Operating instructions and diagrams of piping systems and valves shall be provided in clear and permanent lettering and shall be armed to the equipment or in a position near thereto. The diagrams shall show which valves are to be opened in the event the system must be activated. The diagrams should explain thoroughly and clearly all the steps necessary to put the system into operation. Each valve shall be labeled describing it's function.

6-3.2.3 The control station shall be provided with emergency lighting.

6-3.3" Fire Main Capacity. Operation of a deck foam system at its required foam solution flow rate shall still permit the simultaneous use of the required number of streams of water and other services provided by the fire main system.

6-3.4* Rate of Application. The rate of application of foam solution for fires on deck shall not be less than the greatest of the following:

A. For Hydrocarbon Fuels

1. Deck Spill Calculation: 0.16 gpm/sq ft (6.50 1/min/m 2) over 10 percent of the cargo block deck area, where the cargo block deck area is the maximum breadth of the ship multiplied by the total longitudinal extent of the cargo tank spaces.

2. Largest Tank Calculation: 0.24 gpm/sq ft (9.78 I / m i n / m ~) of the horizontal sectional area of the single largest tank.

3. Largest Monitor Calculation: 0.074 gpm/sq ft (3.00 l / m i n / m ) of the area protected by the largest monitor, such area being entirely forward of the monitor, but not less than 330 gpm (1250 lpm).

63

N F P A 11 - - F 9 7 R O C

B. Polar Solvents

Since requi red foam appl icat ion rates may vary, polar solvents are placed in representat ive groups based u p o n fire pe r fo rmance tests. Fire tests are used to de t e rmine the m i n i m u m foam des ign applicat ion rate for the g roup and are conduc ted usinl~ one or more solvents r ep resen t ing the mos t difficult ext inguis lament case or the actual polar solvent. These m i n i m u m foam design applicat ion rates and polar solvent g roupings shall be specif ied in the foam manufac tu re r ' s system des ign manua l and shall be approved.

Rate of Application: The rate of appl icat ion of foam solut ion for fires on deck shall n o t be less t h a n the greatest of the following.

1~ Deck Spill Calculation: The h ighes t requi red foam appl icat ion rate for any polar solvent that can be t ranspor ted by the ship, appl ied over 10 pe r cen t o f the cargo block deck area where the cargo block deck area is the m a x i m u m bread th of the ship mul t ip l ied by the total longi tudinal ex ten t of the cargo tank spaces.

2. Most D e m a n d i n g T ank Calculation: 150 percen t of the h ighes t requi red foam appl icat ion rate, for any po67 lar solvent tha t can be t ranspor ted by the ship, appl ied over the horizontal sectional a rea of the single largest tank.

Except ion: W h e r e dedica ted cargo tanks are specifically des igned for a part icular polar solvent and such solvent canno t be carried in o ther tanks, the foa m system des ign can take into considera t ion this l imitation.

3. Largest Moni tor Calculation: 45 pe rcen t of the h ighes t requi red foam applicat ion rate for any polar solvent that can be t ranspor ted by the ship, appl ied over the area pro tec ted by the foam moni tor , such a rea be ing entirely forward of the moni tor , bu t no t less than 330 g p m (1250 lpm).

6-3.5 Discharge Durat ion.

6-3.5.1" Foam concent ra te shall be provided to supply the system for 30 minutes . Exception: For ships tha t are bo th t ranspor t ing only hydrocarbons and us ing gas iner t ing of cargo vapor spaces, the discharge dura t ion shall be pe rmi t t ed to be 20 minutes .

6-3.5.2 Allowance shall be made to fill all foam solut ion a n d concent ra te p ip ing a n d still provide the requi red durat ion.

6-3.5.3* M i n i m u m discharge dura t ion shall be based on the actual capacity of the installed equ ipment .

6-4* Foam Out le t Devices. 100 pe r cen t of the requ i red foam appl icat ion shall be by us ing one or two moni to r s located immedia te ly aft o f the protec ted area. Exception: O n tankers less than 4000 tons dead weight, h a n d hose lines only may be installed provided that the capacity of each h a n d hosel ine is at least 25 pe rcen t of the total foam solut ion flow rate.

6-5 Monitors.

6-5.1 The capacity of any mon i to r shall be at least 0.074 g p m / s q ft of the deck area pro tec ted by tha t moni tor , with such area be ing entirely forward of the moni tor . T h e capacity of each mon i to r shall be no t less than 50 pe rcen t of the requ i red foam applicat ion rate and no t less than 330 g p m (1250 Ipm).

6.5.2 The distance f rom the moni to r to the fur thes t extremity of the protec ted area forward of the mon i t o r shall be no t more than 75 percen t of the mon i to r throw in still air condit ions.

6.5.3 Foam moni to rs a n d h a n d hose line connect ions shall be si tuated both por t a n d s tarboard at the f ront of the a c c o m m o d a t i o n space facing the cargo tanks deck. These moni tors shall be located at least 8.2 ft (2.5 m) above the main deck and shall be directly accessible to the deck above the f reeboard deck.

Exception: Monitors are no t requi red on tankers less t han 4000 metr ic tons dead weight.

6-5.4 Placement . The foam system shall be capable of delivering foam to the entire cargo block deck area.

6-5.4.1 Ships fi t ted with bow or s t e m loading and un loading a r r angemen t s shall be provided with one or m o r e addit ional moni to rs located to p ro tec t the bow or s tern a r rangements . The area of the cargo line fore or aft of the the cargo block area should be provided with mon i to r protect ion.

6-5.5 Foam Moni tor Platforms. Foam moni to r s shall be m o u n t e d on substantial platforms. Platforms shall peml i t 360 degree access a r o u n d the moni tors . Platforms shall be raised to allow the moni to rs an unobs t ruc ted throw insofar as practical. The moni tor isolation valve shall be accessible f rom the mon i to r platform. Platforms h igher than 6.5 ft (2 m) shall be provided with h an d rails or chain rails. Access to the mon i to r p la t form shall be via walkway or p e r m a n e n t ladder. Provisions shall be m a d e for secur ing moni to rs while at sea.

6-5.6 Monitors over 1000 g p m (3785 lpm) shall be provided with two opera tor h a n d holds or one handwhee l for each swivel. Monitors shall be des igned to prevent unwan ted m o v e m e n t due to react ion forces. Moni tors s h a l / b e capable of be ing locked into posi t ion while opera t ing at full flow.

6-6 H a n d Hose Lines.

6-6.1 H a n d hosel ines shall be provided to ensu re flexibility of act ion du r ing f i ref ight ing operat ions and to cover areas obst ructed f rom monitors . T h e capacity of any h a n d hosel ine shall be n o t less than 106 g p m (401 lpm) a n d the h a n d hose l ine throw in still air condi t ions shall be no t less than 50 ft (15.0 m) . The n u m b e r and location of foam solut ion oudets shall be such that foam f rom at least two h a n d hosel ines can be s imul taneous ly directed onto any part of the cargo block deck area.

6.6.2 H a n d hose lines and hydrants shall be m o u n t e d on moni to r platforms or at deck level.

6-7 Hydraul ic Calculations. Hydraul ic Calculat ions shall be pe r fo rmed in accordance with NFPA 15. Foam solut ion shall be cons idered to have the same hydraul ic characteristics as water.

6-7.1 Foam concent ra te hydraul ic calculat ions shall be in accordance with the foam concent ra te manufac tu re r ' s system des ign manua l .

6-7.2 Orifices shall be pe rmi t t ed to balance flows to moni tors an d f ixed foam oudets .

6-8 Isolation Valves.

6-8.1 Isolation valves shall be provided in the water, f o am concentra te , a n d foam solut ion mains , immedia te ly forward of any mon i to r posit ion, to isolate d a m a g e d sections. In addi t ion each mon i to r and hose station shall have an isolation valve. Isolation valves shall be operable f rom readily accessible locations. Moni tor isolation valves shall be in accordance with 6-5.5. All isolation valves shall be installed with the b o n n e t above the horizontal.

6-8.2 Isolation valves shall be provided with a ready m e a n s for visual indicat ion of valve position.

6-9 Hangers , Supports , and Protect ion of Pipe Work .

6-9.1 Pipework shall be rou ted to afford protec t ion against damage.

6-9.2* All hange r s and p ip ing suppor ts shall be des igned for mar ine applications.

6-9.3 * Deck foam solut ion p ip ing shall be i n d e p e n d e n t of fire ma in piping. Where the fire ma in and foam main are connec ted to a c o m m o n moni tor , s top check valves shall be installed.

6-9.4* Protect ion From Freezing. The system shall be a r ranged to prevent the possibility of freezing. Port ions of the system exposed to weather shall be self dra ining. Wet or pressur ized por t ions of the system shall be protec ted against freezing.

6-10 Test ing and Inspect ion.

6-10.1 * Foam systems shall be inspec ted a n d tested in accordance with Chapter 6 and Chapter 7. Annua l test ing shall inc lude tests conduc t ed in accordance with 7-3.3.

64

N F P A 11 - - F97 R O C

6-10.2 The system supplier or owner shall make available to the ship's crew a system use, inspection and testing video tape.

6-11 Foam System Concentrate Storage.

6-i 1.1 Foam concentrate storage shall be in accordance with 2- 3.,~.4. ?

\ •

6-t 1. l .l * The primary deck foam concentrate storage tank shall ,be located ozi or alcove the freeboard deck levelin the space containing the system control station described in 6-3.2. All foam corlcetltl-ate shall be stored in an accessible location unlikely to be cut off in the e,)ent of fire or explosion and not having direct openin.g or exposure to the cargo area.

6.11.2 Foam concentrate tanks shall be in accordance with 2-3.2.3.

6-11.2.1" Tanks shall have expansion domes. Tanks shall be fi t ted with baffles to prevent sloshing. Each concentrate storage tank shall be provided with a brass, stainless steel or oilier corrosion resistant pressure ~tcUum (PV) vent, Each tank shall have a substantial > support stl?ucture suitable fi)r tnounting d~e'taiak to d~eMfip's - structure, Each tank shall have a sump or other means to ~revent ctoggiug of the foam congentrate suctiofi pipe in the event of '~ sedime~ltati0n or odler foreigri-materials in tlxe,tank. The foam " conc, entrate suction pipe shall tal~e, Suetion, above 'the bo{:tomof die " "::rap. - . . . . ',: . . . . ' ' ' ,,

• 0-Yl ,., Tanks shall be of adeai~n.and'materials proven to be "< "" [ suitable for use with constant sloshing of die liquid against the tank

s t r t l ( ; t / l r e . , , . , - ,

] 6-11,4 Each umk Shall have a manway or opening~ for in ternal l inspectlon.and access,, - - _ ' " : ,

1 6-11.5 Tafik suctiori a n d return' connections sliall terminate near l the bot~orn "of.the rang.so.as to reduce '~le chance;of premature .

¢ ' ' t m i n g d u e t o agitation dti/qhg system operation,

16-11.6 Atmospheric tanksshall b e peovlded.witli me:ms f b ( -° I continnous refilllng,of d~e rank. . . .

]'6-11.,7" Foam concen~ate storage shall be Within die foam ncentrate manufacturer 's recommerlded temr~eratnre I|nMtatlnne

] Storage s 3aces sh:al be provided with heat to pre'vent'~eezi'ng-o~f~t];e I foam concentrate and piping, Storage ~hall be in accordance with

2-3.2.4. and 2-3.~.4.1.

7 " " I !~1

: ' SerVice Se:~ w:~ter 8~, fo~,m solution " (rip to 225 psig and 350OF) - ,

7" ' -

Foam: concentrate (in the l~azard iirea)

1

I I

I " i I II I l l I I /

. ' , - g ! p e , ~ Carb;n steel 'seamless or" electric resistance Weld,

stand,'/rd wall, galwmized Zs. A,STM A53, Type E or S, Gr. A or AI06, Gr. A Schedule 40 minimum.

ca rbon steel,!"seamless Or" electric resistance weld, stan&lrd wall. ASTM A53, Type E or S, Gr, A or,, A106, Gr. A" ""

• OR Stainless steel, seamless, stint, Lard wall pipe P~STM A312 Gr. TP304L or TP316L

I I I I III

i 6-11.8 Foam concentrate comj3atibility shall be in accordance with i Sections 24.1 and 2-4.2. The loam concentrate storage tank shall be provided with a labeJ specifying foam manufacturer, foam type anaquant i ty .

0-11.9 Only one type of foam concentrate shall be carried on board.

6-12 Supply Arrangements~

0-12.1 * Foam proportioning shall be by the balanced pressure prop0rtioning method employing a dedicated foam concentrate pump.

Exception: O.ther types of systems acceptable to the authority having jurisdiction sfiall be permitted,

6-12.2" Foam concentrate pumps shall be in accordance with 2-6.

6-12.3" Foam and water pump motors and controllers shall compl Y with IEEE standard 45 or equivalent.

6q2.4 Foam and water pumps shall be capable of operation during loss of the haa!n power system. "

6-12.~ Eiectri 9 power for foam pumps, water pumps, and other electrical components of the foam system shall be in accordance with th~ provisions o f SOt,AS Regulations 11-2/4,3 and 4.5.5 -- applicable to fire pumps. ,

6q2,6 Where dlesel pumps are prodded, they shall be connected to a listed d!esel pump'controller.

642.7 The deck foam system piping shall no t be routed through, ixmmediatelyadjacent to, or immediately above fire cargo pump

6:13 P ip ing Materials.,

6-13.1 Piping shall be4n accordance with Table 6-13. Other materials may be used provided they have physical properties and corrosion reslstanee equivalent to tire piping ident i f iedin Table 6-

113 and are approved by the anthority having jurisdiction.

Tnbje ~!3

~.o~: G~b0n steet;'mTM A216 Gro WOB or~ Ductile from ASTM A395 ,

Bronze or316 SS Flanged ANSI B16,5

Class 150

C ~ b o n steei, ASTM A216 Gr. WCB or AI05 ~2iI~: 304L or 316L SS Ends. ) Flafiged ANSI B16.5 Class 150 or screwed

OR • JLQ.d~ F0rged stainless steel ASTM A182 Gr. F304L or F316L !r.L~: 304L or 316L SS Ends.. Flanged ANSI B16.5 Class 150 or screwed

Notes: I 2. 3.

'- F~ttings ' ' Takedown ,5 in. and lar~ter:' ' 3 i n . and largerv Slip-

On or buttweld flange 2 in. and smaller: Socket weld flange ANSI B16.5 Class 150, ASTM A105

Wrought steel, standard wall, galv,~ized per ANSI B16.9¢ 1501b minimum 2 in. and smaller: Socket weld steel, 2000#,

~ll lvanized per ANSI 6.11

ASTM A234 Gr. WPB

Socket weid or threaded carbon steel, 2000# per ANSI B16,11 ASTM A234 Gr. WPB

OR s Socket weld or threaded stainless steel, 2000# per ANSI B16.11 ASTM A182 Gr. F304L or F316L

Standards shown are minimum acceptable Equivalent foreign standards ma be used t f a r v d System may, be assemhled using black Steel pipe arid fittinlzs, ]aot dio vamzeYd after abn PffPt ~ e . ,~ l e re pipe and fittings are g~dvanized, all aisturbed m'e,'L~ are to b e reg~alred using stl~tabl~ ~'~i(~ galvanizing product.

Screwed or socket weld flange per ANSI B16.5 Class 150 ~STM AI05 or ASTM A182 Gr. 304L or Gr. - 316L

OR s Screwed or socket weld union, 2000# per ANSI B]6.11 ASTM A105 or ASTM A182 Gr. 304L or Gr. $16L

NFPA 11 -- F97 ROC

6-13.2 Pipe in areas subject to fire exposure, i ndud ing radiant and conducted heat, shall be of steel or o ther alloy suitable for the pressure, possible fire tempera ture exposure, and environmental condit ions expected.

6-13.3 Foam concentrate piping shall be constructed of material compatible with, and no t affected by, the concentrate° Foam concentrate piping shall no t be galvanized.

6-13.4" Pipe th read jo in t sealants used for foam concentrate lines shall be in accordance with the foam concentrate maanufacturers r ecommenda t ions .

Appendix F Test Method for Marine Firefighting Foam Concentra tes Protect ing Hydrocarbon Hazards

Introduction:

The following test me thod has been spedfically developed for use in demand ing marine applications. It is derived f rom Federal Specification O-F-555C which is no longer in print. It spedfically incorporates a large surface area of 100 sq ft (9.99 m~), sealability testing, and a bumback test conducted 15 minutes after fire extinction. The test m e t h o d given here incorporates a high free board that is subject to h igh temperatures, both conditions add to the difficulty of this test method. This test me thod uses gasoline, a highly challenging test fuel and requires that fresh fuel be used for each test. This test utilizes a square pan. The geometry of the pan ' s corners bet ter simulates the complex steel shapes found in ship's cargo holds and bilges than r o u n d fire test pans used in o ther test methods. The test me thod employs a f ixed nozzle, thus removing any bias caused by an operator applying foam at the test facility.

I Test Facili W.

The test should be conducted at a test facility acceptable to the authority having jurisdict ion.

II Test Apparatus:

1. Pan. The test pan should be of 10 gage steel min imum construction measuring 10 ft (3 m) long x 10 ft (3 m) wide

x 3 ft (.9 m) deep. The sides of the pan should be properly reinforced to prevent warpage due to heat genera ted during the test.

2. Nozzle. The test nozzle should be as shown in figure F- l. Alternate nozzles shall be approved by the authority having jurisdiction. The nozzle should flow 6.0 gpm (92.7 L/ra in) at 100 psi (689.5 kPa) inlet pressure.

-~ ~ - ~ ' ~ " * m ' ~ n ' ~ '1

lr6kl , % k , . . ~ 3 ~

4 e U l ~ l , ~ ~.#.~, ~ t g g ~ S & S

3. Fuel. A min imum of 75 gal (284 L) of gasoline shall be floated on a suff ident quantity of potable water so that the fuel surface is 2 ft (.6 m) below the top edge of the tank. For each succeeding test the pan sha l l be completely empt ied of the fuel and foam residue f rom the previous test. The gasoline shall be commercial unleaded regular motor fuel with an octane rating between 82 and 93 per Federal Specification W-G-T6. The fuel temperature should be not less than 70°F (91°C). An alternate test fuel may be used provided thaat it has equivalent propert ies to the unleadd fuel specified above and has been approved by the authority having jurisdiction.

4. Synthetic Sea Water. The composi t ion shall be as described in ASTM Dl141-52.

III Test Procedure:

1. Fire Extinguishment. Foam Concentrate shall be subjected to four consecutive fire tests by discharging through a 6 gpm (99.7 L / mi n ) nozzle at an inlet pressure mainta ined at 100 (689.5 kPa) + 2 psig (13.8 kPa), and a

water temperature of 68 + 8°F. (90 + 5°C,) The concentrate should be at approximately the same tempera ture as the water. Two of the tests should be conducted with fresh water and two of the tests should be conducted with salt water descr ibed above. The foam liquid solut ion shall be

~ remixed and applied at a rate of 3.0 percent by volume for percent foams, 6.0 percen t for 6 percent foams, etG The

nozzle should be posi t ioned in the middle of one side of the test pan with the nozzle tip 16 inches directly above the top edge of the test pan. The fire should be permit ted to burn freely for 60 seconds before foam application. The foam should be directed across the fire to strike the approximate center of the back side of the pan, 12 inches above the fuel level and shall be applied for a 5 minute period. (If pr ior to the test, foam is discharged into the pan to align the nozzle for p rope r foam stream impact position on the back side o f the pan, such foam shall be removed f rom the pan prior to the tes t )

Observations: 1. Record the per iod after start of foam application required for the foam to spread over the fuel surface as "coverage" time. 9. Record the per iod for the fire to be extin~luished except for licks of flame at the edges of the foam blanket as "control" time. 3. Record the per iod for complete ext inguishment as "extinguishment" time.

Record: Record the name of the manufacturer, foam type, trade name, batch number and date of manufacture.

~--.A(QS4)~ I~-|I~ 1111~ilt lhd. ~ (.147) (k. \ f~r~ kI'14 ~i~d" und°i~Qt ~Mt llJ~ ~in. 18 ~lhd- ~ilL '4'''

~, / ~k-2B \mmalm ~ I . ~ , ~ / (4}Y~mmwe \

. - 7 t ~ I i \ \ , ~ _ ~ _ ~ l / ~ , ~ \ ~o \ [ I ~,r~

_ . / . : . - - ' . .~ -*-------g=~li~'~,-~ " % . : £ ~ . ~'~i ~ i "~'~'~ .! ~-~,~ ~ . l l- . ' ~ , ~ , . ~ - ~ I I.I.I~ H I~ ~ "~"

• , , .~ " I'~'~: I ~ - ~ o Cots)

N F P A 11 - - F9 7 R O C

2. Sealability. A l ighted torch shou ld be passed cont inuously over the foam blanket s tar t ing 10 minu te s after the e n d o f f . a m discharge. Four teen minu te s after comple t ion of f o a m application, the l ighted torch shou ld be appl ied over the foam blanket for 1 m i nu t e with the to rch touch ing the foam blanket bu t no t pene t ra t ing the foam blanket by m o r e t h a n 1 / 2 inch. T he torch shou ld touch the b lanket at least every 2R (.6 m) a long the sides of the test pan , at poin ts where the foam blanket appears significantly le~ t han the average thickness, in all four corners of the pan, a n d at r an t lom points in the ma in area of the pan. T h e torch shou ld no t be d ragged t h r o u g h the foam however.

3. Burnback.

A. Method 1: Fifteen minu te s after comple t ion of the foam application, a n open ing 6 in . sq (38.7 cm ~) should be m a d e in the foam blanket approximate ly 2 ft (.6 m) f rom the the side of the pan. T he exposed fuel shou ld be reigni ted with a torch and permi t ted to b u r n for 5 minutes . After the 5 m i n u t e b u r n i n g period, the area involved in f lames shou ld be de te rmined .

B. Method 2: As an al temative to Method 1, two 1 ft (.3 m) d iameter stove pipes shou ld be placed in the foam blanket du r ing the sealability test, at least 2 ft (.6 m) f rom the sides of the pan, and the foam inside the stove pipes shou ld be removed. At fif teen minu tes after the end of the foam discharge, the exposed fuel inside the stove pies shou ld be igni ted by torch and pe rmi t t ed to bu rn for 1 minute . T h e first stove pipe shou ld t hen be removed. After an addit ional 4 minu te bu rn ing period, the area involved in f lames shou ld be de te rmined . If, u p o n removal of the pipe, foam covers the exposed fuel area and ext inguishes the fire, the fuel inside the second stove pipe shou ld be ignited and allowed to b u r n freely for one minute . The second stove pipe shou ld t h e n be removed and the area involved at twenty minu te s after the end of foam discharge shou ld be de te rmined . If, u p o n removal o f the second pipe the foam again covers the exposed fuel a n d ext inguishes the fire, no fu r the r bu rnback tests are necessary.

IV Acceptance Criteria:

1. Fire Performance. The foam as received should have a coverage t ime of no t more than 2 minutes , a control t ime of no t m o r e than 5 minutes , and comple te fire ex t ingu i shmen t in no t more than 5 minu tes after start of f oam application. 2. Sealability. The foam blanket shall protect the fuel below the foam f rom reignit ion by a l ighted torch for a per iod of no t less t h a n l 5 minu te s after the end of foam application. Aaay ignit ion of fuel vapors above the foam blanket m u s t resul t in comple te self ex t i ngu i shmen t pr ior to the end of the test period. Record in detail the type, location, and dura t ion of any b u r n i n g observed.

3. Burnback:

A. Me thod 1: The foam blanket shall p revent the spread of fire beyond an area approximate ly 20 in. sq (129 cm ).

B. Method 2: The area involved in f lames is no t to exceed 400 sq in. (.25 m~).

V. Foam Quality. Fomn quality tests shall be conduc ted us ing the same batch of p r emix as used du r ing the fire tests. Foam expans ion and 25 pe rcen t dra inage tests shou ld be pe r fo rmed as given in Append ix C.

VI. Procedures in C~se of Failure. Four consecutive successful tests are required. Failure of any one test will require ano the r series of four consecutive successful tests.

Helpful Convers ion Factors:

l p m / s q m = 0.0147 g p m / s q ft

6 l p m / s q m = 0.147 g p m / s q ft

3 l p m / s q m = 0.0735 g p m / s q ft

g p m / s q ft = 6.5 l p m / s q m

0.24 g p m / s q ft = 9.78 l p m / s q m

Chapter 6 Append ix

A-6-1 The provisions of this mar ine chapter were developed based on knowledge of practices of NFPA 11, SOLAS, the IBC Code, an d USCG regula t ions and guidance. In order to ha rmon ize the requ i rements of this chapter with the practices of these o ther standards, the values given in the metr ic conversions in Chapter 6 shou ld be cons idered the requ i red value.

A-6-1.1. Approvals of specialized foam e q u i p m e n t c o m p o n e n t s are typically based on compl iance with a s t andard equivalent to Underwri ters Laboratories S tandard for Safety ULI fi2o C o m p o n e n t review shou ld include:

: Fire suppress ion effectiveness Reliability

• Mechanical s t rength • Corrosion resis tance • Material compatibil i ty

Proper opera t ion Stress, shock and impac t

• Exposure to salt water, sunlight , t empera tu re ext remes an d other envi ronmenta l elements . P ropor t ion ing system test da ta demons t r a t i ng acceptable injection rate over the i n t ended flow range of the system. • Foam s t ream range data based on still air test ing with moni to r a n d nozzle combinat ions . • Foam quality test data demons t r a t i ng satisfactory per fo rmance co r respond ing to small scale fire test nozzle foam quality,

Quality control of specialty f oam propor t ion ing a n d applicat ion e q u i p m e n t as well as f oam concent ra tes shou ld be achieved t h rough a listing p rog ram that includes a m a n u f a c t u r i n g follow-up service, i n d e p e n d e n t certification of the product ion process to ISO 9001 and ISO 9002, or a similar quality control p rog ram approved by the author i ty having jur isdict ion.

A-6-1.2.2 Foams for polar solvents are first tested for hydrocarbon e r fo rmance us ing a test derived f rom Federal Specification O-F- 5C tha t was publ i shed f rom 1969 t h r o u g h 1990. The foams are

fu r ther tested for polar solvent system applicat ion on the basis of 50 2 sq ft (4.6 m ) fire test pe r fo rmance in accordance with UL

Standard 162. Approved manufac tu re r ' s deck system design applicat ion rates and opera t ing t imes incorpora te design factors which are applied to the fire test appl icat ion rates and times. A-6-.2.1 This system is i n t ended to supp lement , no t replace, any requi red total f looding mach ine ry space fire suppress ion system. Foam systems compris ing a por t ion of requi red pr imary mach ine ry space protec t ion may require longer appl icat ion times.

A-6-3.1 A l though sh ipboard foam systems share many similarities with tank farm foam systems on land, there are impor tan t differences between sh ipboard and land based fire protection. These differences, identif ied below, result in foam system designs and a r r angemen t s tha t differ f rom systems used in what may appear to be similar land based hazards.

• Foam fire tests of the type descr ibed in Append ix F are very severe. • The re is l imited data regard ing use of systems m e e t i n g USCG or IMO requ i rements on actual fires.

There is little or no separa t ion between tanks. The vessel may be widely separa ted f rom other hazards or may

be a long side ano the r vessel or a terminal . * The vessel may no t have access to immedia te f i ref ighting assistance. • Fires resul t ing f rom catas t rophic events such as explosions and collisions historically are beyond the on-board f iref ighting capabilities of the involved vessels necessi tat ing use of outside fire f ight ing assistance. Many large fires have taken several days to ext inguish. • The n u m b e r of f i ref ighting pe rsonne l is l imited to the available crew. • Fires no t substantially control led within the first 20 m i n may exceed the capability of the crew and the onboa rd system.

67

N F P A 11 - - F 9 7 R O C

• Ships are subject to rolling, pitching,, and yawing which can cause sloshing of the burn ing hquid and reduced per formance of the foam blanket. • Application of foam to the fire is likely to be much faster than on land because the deck foam system is in place and can be activated simply by starting a p u m p and open ing certain valves. There is litde or no set-up time. • Tank fires d o n ' t seem to occur tmless p receded by an explosion. • Explosions can cause substantial damage to foam systems. They can have unpredictable results on the vessel structure including bend ing deck plat ing in such a way so as to obstruct foam application. They may also cause involvement of any number of tanks or spaces. * Most tankers use iner t gas systems to reduce vapor spaces above cargo tanks to less than 8 percen t oxygen thereby reducing the l ikelihood of an explosion. • Ships pay the cost of t ransport ing their fire suppression systems on every voyage. • There is a finite amoun t of space on each ship design. Tanker deck foam moni tors are located at or above the elevation of top of the tank as contrasted with typical tank farm arrangements where monitors must project foam up and over the rim of a tank.

A-6-3.2.2 Color coding the valves aids in identification. For example, all valves that are to be opened may be painted some distinctive color.

A-6-3.3 A fire main system may provide other services in addit ion to fire protection. Other services which could be left open d u d n g a fire, n e e d to be included in calculations.

A-6-3.4

(a) Differences Between this Section and SOLAS or the IBC Code. The application rates prescr ibed in this sect ion for hydrocarbon fuels are higher than the rates given in the International Maritime Organization's International Convention for the Safety of Life at Sea (SOLAS) Chapter 2/2 Regulation 61 as follows:

Deck Spills: This section requires 0.16 g p m / s q ft (6.5 L / m i n / m ~) applied over the 10 percent of the cargo block versus 0.14'7 g p m / s q / f t (5.98 L / m i n / m 2) in SOLAS. This difference i sba sed on a long history of fire ext inguishment exper ience using 0.16 g p m / s q ft (6.5 L / m i n / m 2 ) . It is also unders tood that the value 0.16 g p m / s q ft (6.5 L / m i n / m ~) is generally regarded as the m i n i m u m foam application rate for industrial hazards and reflects the min imum application rate on the fuel surface, no t at the discharge device. Thus, loss of foam due to wind, obstructions, etc~, should be compensa ted for to provide 0.16 g p m / s q ft (6.5 L / m i n / m ~) on the l iquid surface.

Single Largest Tanlc This sect ion requires 0.24 K~pm/sq ft (9.77 L / m i n / m ~ ) over the singleVl-argest hydrocarbon tank versus 0.147 g p m / s q ft 03.98 L / m i n / m ~) in SOLAS. This difference is based on the the n e e d to deliver a minimum of 0.16 g p m / s q ft (6.54 L/min/m ~) onto the surface of the burn ing fuel and takes into consideration the impact of wind, evaporation, and thermal updrafts. This value is consistent with recent exper ience with the ext inguishment of shore based storage tanks using mobile foam equ ipment similar to the monitors used in deck foam systems.

Polar Solvents: The International Bulk Chemical Code (IBC Code) provides two design methods. The first me thod requires a foam application rate of 0.5 g p m / s q ft (20.3 L / m i n / m z ) without restriction to the type of chemicals that may be carried or where on the ship's cargo block they may be carried. The second me thod allows arrangements with application rates lower than 0.5 g p m / s q ft (20.3 L / m i n / m ~ ) . This me t hod is allowed if the country where the vessel is registered has de te rmined through fire tests that the actual foam application rate at each cargo tank is adequate for the chemicals carried in that tank. The design pract ices given in this section comply with the second m e t h o d of the IBC Code. (Reference 1994 IBC Code Regulation 11.3.13.)

(b) Reliance on Monitor Application. It is recognized that for land applications this s tandard generally restricts moni tor app.lication . . . . . of foam according to tank diameter and surface area. A stgulficant difference between m o m t o r apphcataons on land and those on tank ships is that the monitors on tank ships are located at or above the elevation of the top of the tank. Therefore, shipboard systems do no t suffer losses of agent associated with long throws gett ing foam up and over tank tams. Additionally, tank ship monitors can be placed in operat ion immediately after an incident as there is little or no set-up time and each moni tor is required to be sized to deliver at least 50 percent o f the required foam application rate.

c. Design Factors The application rates given in this section incorporate design factors that allow the results of small scale fire tests to be applied to full scale fires. Design factors include scaling factors that allow the results of small scale tests to be extrapolated to large scale. In addit ion, compensat ion factors are inc luded to account for losses expected f rom wind, thermal updraft , s t ream break-up, plunging and other adverse conditions. The application rates and incorporated design factors are as follows:

Fuel

Hydro-carbon

Hydro-carbon

Polar

Polar

Scenario i00 sq.ft. Test Fire

Deck Spill 0.06 g p m / s q . f t .

Single Largest 0.06 g p m / s q . f t . Tank

Deck Spill

Single Largest Tank

Rate ~ 0.06

~p m / s q . f t . as e te rmined by

test Rate > 0.06 ~ p m / s q . f t .

e te rmined ~Sy test

Scaling Design Factor 2.67 (8/3)

2.67

2.67

2.67

Fuel Surface A~plication Rate 0.16 g p m / s q . f t .

0.16 g p m / s q . f t .

Test rate x 2.67 ~ 0.I 6 gpm/sq,f t .

Test rate x 2.67 _> 0.16 gpm/sq . f t

Compensa t ion Desi~rn Factor 1.0

1.5

1.0

1.5

Required Application Rate 0.16 g p m / sq. ft. 0.24 gpm/sq. f t .

>_ 0.16 gpm/sq.f t .

>_ 0.24 gpm/sq.f t .

68

N F P A 11 - - F 9 7 R O C

(d) Moni tor Design Philosophy. The design phi losophy given in this s tandard reflects that out l ined in US Coast Guard Navigation and Vessel Inspect ion Circular (NVIC) 11-82, Deck Foam Systems for Polar Solvents. NVIC 11-82 assumes that the min imum single tank design application rate will be 0.16 g p m / s q ft. It then allows moni tors to be calculated using 45 percent o f the single tank rate. SOLAS and the IBC Code require the moni to r to be calculated at 50 percent of the single tank rate. However, SOLAS starts with a single tank application rate of 0.147 g p m / s q ft (fi l pm/ sq m) so that 50 percent of that rate exactly equals 0.0735 g p m / s q ft (3 l p m / s q m) which is 45 percent of the NVIC 11-82 min imum application rate of 0.16 g p m / s q m (6.5 L / m i n / m 2 ) . The IBC code also requires monitors to be sized for 50 percent of the single tank flow rate.

A-6-3.5.1 Foam application durations given in this section are nerally lower than those given in o ther sections of this standard. is difference is based on historically quick deployment of marine

deck foam systems and also takes into account all of the factors listed in A-6-3.1.

A-6-3.5.3 The flow rates dur ing an actual system discharge will generally be greater than the min imum rates calculated during system design because pumps, eductors, and nozzles are typically no t available in sizes for the exact min imum flow rate needed. Therefore, this equ ipment will typically be selected at the next larger commercially a~ailable size. Because the system, built of components larger than the min imum required, will flow foam at a rate greater than the ra inimum calculated, the foam concentrate will be used faster than the min imum usage rate. Since the concentrate will be used at a rate higher than the minimum, the storage quantity must be sized to provide the actual delivery rate during the entire required discharge duration.

A-6-4 Although foam handlines are required for supplementary protect ion, it is not practical to rely on handlines for primary flrefighting. Therefore, all required foam application must be provided by monitors lahat cover the protectect area.

A-6-9.2 Pipe should be uniformly suppor ted to prevent movement due to gravity, heaving of the vessel in heavy weather, impact, and water hammer . Pipe should be suppor ted by steel members.

A-6-9.3 Deck foam system piping is no t a substitute for any port ion of a vessel's fire main system. Conversely, the requ i rement is in tended to darify that foam injected into the ship's fire main is no t a substitute for a dedicated foam system on the weather deck. The requi rement is no t in tended to prevent the propor t ioning of foam into a ship's fire main. Such a capability may be of great value dur ing a machinery space fire or any other f i re involving f lammable liquids.

A-6-9.4 The system should be ar ranged to prevent ice from forming in any por t ion of the system. Sloped piping and manual low point drains are considered to meet the requi rement that the system be self draining.

A-6-10.1 Refer to the environmental repor t (Appendix E) for fur ther informat ion related to environmental issues when per forming system discharge tests.

A-6-11.1.1 The primary foam concentrate tank is the tank containing the supply calculated to satisfy the requirements of 6- 3.5. T h e l o c a t i o n of emergency back-up supplies and supplies of concentrate for refilling the primary tank are no t subject to the storage location restrictions of 6-11.2. However, all foam concentrate storage is subject to o ther provisions of this chapter such as those regarding prevent ion of freezing and foam compatibility.

A-6-11.2.1 Corrosion occurs at the a i r / f o a m / t a n k interface. Therefore, the small surface area of this interface in tank dome results in less corrosion than if the interface occurs in the body of the tank. Tank domes are also used to reduce the available free surface subject to sloshing. Sloshing causes premature foaming and adversely affects foam proport ioning. In addition, sloshing can cause cracking or o ther damage to the tank. Also foam evaporates so the use of a pressure vacuum (PV) vent is necessary. A PV vent allows air to en te r the tank as l iquid is discharged, air to leave the tank as liquid fdls the tank, and the PV valve prevents evaporation of the concentrate.

A-6-12.1 Example acceptable arrangements are shown in figures A- 1-40) and A-1-4(j). Consideration should be given to the need for spare or r edundan t critical equipment .

A-6-12.2 Where foam concentrate pumps are f lushed with sea water, the pump should be constructed of materials suitable for use with sea water.

A-6-12.3 Portions of Canadian Standard TP 127 are generally considered equivalent to IEEE 45.

A-~13.4 Some pipe jo in t sealants are soluble in foam concentrate. SUBSTANTIATION: The Commit tee sl ipped cycle to allow fur ther work by the Marine Task Group in developing a more concise comment based on the original proposal and including industry representation. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 29 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 28 ABSTENTION: 1

COMMENT ON AFFIRMATIVE: NORMAN: Modify Chapter 6 Appendix F Items II 2. and II 3. as

follows: 2. Nozzle. The test nozzle used, when operated at the inlet

pressure which produces a solution flow of 6 gpm (22.7 lpm) , shall p roduce foam of similar quality to that p roduced by the full scale discharge devices used in the system design. The foam quality p roduced by the full scale discharge devices shall be measured at the min imum and maximum design in le tpressures and in each case shall match the foam quality p r o d u c e d b y the test nozzle within the ranges specified in UL 162 Section 13.

3. Third sentence - The gasoline shall be the standard test gasoline available f rom Phillips Petroleum under the trade name RF-A (WITHOUT ADDITIVES) or equivalent.

SUBSTANTIATION: Nozzle - The test nozzle required is no longer manufactured, and

the graphic is not sufficiendy detailed to allow its manufacture. In any event, there is no assurance that the foam quality produced by the required test nozzle is similar to that p roduced by the full scale discharge devices used in the system design. If the foam quality p roduced by the full scale equ ipment is significantlv different f rom that p roduced by the test nozzle, its fire performance will also be significantly different. UL 162 rightly addresses this issue, and the requirements of this s tandard relative to matching test nozzle foam quality with that p roduced by the full scale discharge devices should be incorpora ted in Chapter 6.

Fuel - Federal Specification W-G-76 permits a b road range of gasoline composit ions and properties. It is a basic scientific

c rinciple that all materials used in a test, o ther than the material e ing tes ted , should be as s tandard and closely specified as

possible. W-G-76 does no t accomplish this aim. Standard test gCasoline is available f rom Phillips and others. A sample

ertificate of Analysis, with specifications, f rom Phillips is included with this comment . In the interest o f making this test scientifically valid, the use of a s tandard fuel should be required. If there is a problem with using the Phillips trade name, Phillips' specifications could be incorpora ted instead.

EXPLANATION OF ABSTENTION: KREMBS: Abstain on C ommen t 11-3 (Log #CC2) because I was

unable to a t tend the meeting.

(Log #CC1) 11- 4 - (Appendix E): Accept SUBMrITER: Technical Commit tee on Foam COMMENT ON PROPOSAL NO: 11-17 RECOMMENDATION: Proposed new text is as follows:

E-9 Environmental propert ies of Hydrocarbon Surfactams and Fluorochemical Surfactants.

Most fire f ighting foam agents contain surfactants. Surfactants or surface active agents are compounds which reduce the surface tension of water. They have both a strongly "water loving" port ion and a strongly "water avoiding" portion.

Dish soaps, laundry detergents and personal heal th care products such as shampoos are common household products which contain hydrocarbon surfactants.

Fluorochemical surfactants are similar in composit ion to hydrocarbon surfactants; however a por t ion of the hydrogen atoms have been replaced by f luorine atoms. Unlike chlorofluorocarbons (CFC's) and some o ther volatile

69

N F P A 11 - - F9 7 R O C

f luorocarbons , f luorochemica l surfactants are no t ozone dep le t ing a n d are no t restr icted by the Montreal Protocol or related regulat ions. F luorochemical surfactants also have no effect on global warming or climate change . AFFF, F luoropro te in Foam a n d FFFP are f oam liquid concen t ra tes which con ta in f luorochemica l surfactants .

The re are env i ronmenta l concerns with use of surfactants which m u s t be kept in m i n d when us ing these products for ex t inguish ing fires or for fire training. These concerns are listed below:

(a) All surfactants have a certain level of toxicity. (b) Surfactants used in fire f igh t ing foams cause foaming. (c) Surfactants used in fire f ight ing foams may be persistent.

This is especially t rue of the f luor ine funct ional g roup of f luorochemica l surfactants .

(d) Surfactants m a y be mobi le in the env i ronment . They may move with water in aquat ic ecosystems and leach t h r o u g h soil in terrestial ecosystems.

In the following paragraphs , we will explain what each of these proper t ies m e a n and what this m e a n s in te rms of how these c o m p o u n d s shou ld be hand led .

E-9.1 Toxicity of Surfactants. Fire f ight ing agents, used [ responsibly a n d following mater ia l safety da ta shee t instructions, po ! ose little toxicity., risk to people . However,. some. toxicity does exist- T h e toxlclty of the surfactants tn fire f ight ing foams, inc lud ing the f luorochemica l surfactants, is a reason to p reven t unnecessary exposure to people a n d to the env i ronment . I t is a reason to conta in a n d t rea t all fire f ight ing foam wastes whenever feasible. O n e shou ld always make plans to conta in wastes f r om t ra ining exercises a n d to treat t h e m following the supplier 's

] disposal r e c o m m e n d a t i o n s as well as the r equ i r emen t s of local autiaoritles.

Water tha t foams when shaken due to con tamina t ion f rom fire f ight ing foam shou ld no t be ingested. Even when foaming is no t present , it is p r u d e n t to evaluate the l ikelihood of dr ink ing water supply con tamina t ion and to use a l ternate water sources unt i l one

: is certain that surfac tant concent ra t ions of concern no longer exist. Suppliers of f i ref ight ing foams shou ld be able to assist in evaluat ing the hazard and r e c o m m e n d i n g laboratories that can do

a p p r o p r i a t e analysis when necessary. E-9.2 Surfactants a n d Foaming. Many surfactants can cause foaming at very low concentra t ions . This can cause aesthet ic p rob lems in rivers a n d streams, and bo th aesthet ic and_operat ional p rob lems in sewers a n d wastewater t r e a t m e n t systems. W h e n too m u c h f i ref ight ing foam is d i scharged at one t ime to a wastewater t r ea tmen t system, ser ious foami ng can occur. T h e bubbles of foam that fo rm in the t r ea tmen t system can trap a n d br ing flocks of the activated s ludge tha t t reat the water in the t r ea tmen t system to the surface. If the foam blows off the surface of the t r ea tmen t system, it leaves a black or brown s ludge res idue where the foam lands a n d breaks down.

If too m u c h of the activated s ludge is physically removed f rom the t r ea tmen t system in foam, the opera t ion of the t r ea tmen t system can be impaired. O the r waste pass ing t h r o u g h the system will t hen be incomplete ly t reated unt i l the activated s ludge concentra t ion again accumulates . For this reason, the rate of f i ref ighting foam solut ion d ischarged to a t r ea tmen t system has to be controlled. Somewhat h ighe r discharge rates may be possible wh en anti- f o a m i n g or de foaming agents are used. Foam concent ra te suppl iers may be contac ted for gu idance on discharge rates and effective ant i - foaming or de foaming agents. E-9.3 Persistence of Surfactants. Surfactants may biodegrade slowly a n d / o r only partially biodegrade. The f luorochemica l surfactants are known to be very resis tant to chemical a n d b iochemica l degradat ion. Th i s m e a n s that , while the n o n - f luorochemical por t ion of these surfactants may break down, the f luor ine con ta in ing por t ion may likely remain . This m e a n s tha t after f i ref ighting f o a m wastes are fully treated, the waste residual could still f o rm some f o a m when shaken. It could also still have some toxicity to aquat ic organisms if no t sufflciendy diluted.

E-9.4 Mobility of Surfactants. Tests and exper ience have shown tha t some surfactants or their res idues can leach t h r o u g h at least some soil types. The resis tance of some surfactants to b iodegrada t ion makes the mobil i ty o f such surfactants a potential concern. While a readily degradable c o m p o u n d is likely to degrade as it leaches t h r o u g h soil, this won' t h a p p e n to all surfactants. Thus , if allowed to soak into the g round , surfactants tha t don ' t b ecome b o u n d to soil c o m p o n e n t s may eventually reach g r o u n d water or flow ou t of the g r o u n d into surface water. If adequa te di lut ion has n o t occurred, they may cause foaming or concerns abou t toxicity. Therefore , it is inappropr ia te to allow t ra ining waste to cont inual ly seep into soil; especially in areas where water resources could be con tamina ted . S U B S T A N T I A T I O N : The c o m m e n t fu r the r clarifies the issue involving the env i ronmenta l proper t ies of hydrocarbon and f luoroca rbon surfactants . COMMITTEE ACTION: Accept . NUMBER OF COMMI2~I'EE MEMBERS ELIGIBLE TO VOTE: 29 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 29

70

il [rt] hague - nfpa...have ul listed 1 percent afff. its fire-fighting capabilities are similar in...

Documents