My code wish list, Part 1

By Samuel S. Dannaway, PE,
President, S.S. Dannaway Associates, Inc., Honolulu

During design of a particular system, and in the process of trying to ensure the system complies with the various provisions of the code(s) or standard(s) in play, have you ever thought to yourself, “Is it really necessary to do this?” Well, I seem to be saying it all the time. The young engineers in the company think, “There goes the old geezer mumbling to himself again.”

Please understand: I am not complaining about the members of committees overseeing these documents. It is up to all of us to fix stuff in our codes and standards that we think can be done better. It is not the particular committee’s sole responsibility to do so. Anyone can, and should, make proposals in areas where one feels the document can be improved.

I am going to start with three provisions contained in UFC 3-600-01, Fire Protection Engineering for Facilities. This document establishes the fire protection requirements that are to be used on projects involving the U.S. Department of Defense. Their requirements do not have to pass the rigorous consensus standard requirements used in the NFPA and, as some would argue, in the ICC. A particular requirement usually results from a consensus of the DOD fire protection engineers, of which there are probably about 50 or so. In my opinion the result often is increased cost to the system without concurrent increase in system value. For those DOD AHJ’s out there, please know that I do this only in the best interests of my country.

Paragraph 4.2.3.8 UFC 3-600-01 requires two combined sprinkler/standpipe risers in buildings of four of more stories. It requires the risers to be connected to one another on each floor, and each connection is provided with a floor control valve. The purported reason for the requirement is as a force protection (anti-terrorism) measure, to increase sprinkler system survivability. Please help me understand this. If one of the sprinkler risers is “taken out” during a terrorist attack, all you will have is a big leak and no water for sprinklers. It will take manual intervention to isolate the system and restore protection to the building, assuming there is a building left to protect.

In the meantime, the cost of the sprinkler system is dramatically increased with the requirement for the additional riser and all the additional floor control valve assemblies. I sure hope someone tells the sprinkler contractor fixing a leaking sprinkler on one of these systems that two floor control valves must be closed before the sprinkler is removed (You mean you didn’t read the sign: I hate it when that happens.)

Table 4-1 of UFC 3-600-01 requires minimum 3,000 square feet remote design areas for the various occupancy hazard classes for sprinkler systems, rather than the 1,500 square feet minimums we see in NFPA 13. Also, hose stream allowance requirements for light, ordinary, and extra hazard are 250 gpm, 500 gpm and 750 gpm, respectively, instead of the NFPA 13 requirement of 100 gpm, 250 gpm and 500 gpm. The 3,000-square-foot design area essentially doubles the cost of a sprinkler system for DOD facilities. This cost-with-no-benefit requirement ranks right up there with $5,000 toilets and $600 hammers.

The provisions of NFPA 13 have stood the test of time and should be more than adequate. Also, the additional flow and pressure required to meet this requirement often forces the addition of a booster fire pump to the system. Not only is there significant additional cost, the addition of a fire pump system and the attendant lack of maintenance we so often see is likely to reduce the overall reliability of the sprinkler system.

Here’s another head-scratcher. UFC 3-600-10N is a draft version of UFC 3-600-01, which contains requirements specific to the Navy. Though a draft, its use is required for Navy projects. Paragraph 2-2.1.1 does not permit one to use bolted steel tanks for ground level fire protection water storage. This forces the engineer to specify a more expensive welded-steel or concrete tank. The private sector has had great success with bolted steel tanks.

OK, let’s beat up on the private sector a bit. Did you know that the storage (warehouse) fire sprinkler design criteria contained in NFPA 13 is only valid for those buildings that have ceiling slopes of 2 in 12 or less? NFPA 13, 2010 edition, paragraph 12.1.2, quietly reveals a major disclaimer stating: “12.1.2 Ceiling Slope. The sprinkler system criteria specified in Chapter 12 and Chapters 14 through 20 are intended to apply to buildings with ceiling slopes not exceeding 2 in 12 (16.7 percent) unless modified by a specific section in Chapter 12 and Chapters 14 through 20.” So what do you do if the building in question, often an existing one, exceeds 2/12. The answer is that you are stuck, unless you want to stick your neck out and make something up, like a 30% increase in the design area.

One option is to tell the architect that her building with the severely sloped roof must be changed (Hope the snow load does not mind.) or she will need to provide a drop ceiling throughout the entire warehouse area. So why are we in this dilemma? Well, as I understand it, the major testing agencies that are providing listings and approvals for design criteria for storage protection only have flat ceiling test facilities. Research is needed to provide the engineer with some answers. Sprinkler system design should not dictate how a building is built.

Next, I wish that, in sprinklered buildings, we could eliminate the requirement for interconnecting standpipe system piping that is not located in a protected enclosure (such as a stairwell) to be enclosed in fire resistance construction. NFPA 14, 2010 edition paragraph 6.1.2.2 states, “6.1.2.2 Standpipes and lateral piping supplied by standpipes shall be located in enclosed exit stairways or shall be protected by a degree of fire resistance equal to that required for enclosed exit stairways in the building in which they are located.” If the building is 100% sprinkler protected, I see no need to protect the standpipe interconnecting piping. The interconnection can be located on a lower floor, and will most certainly be quite remote from a fire, a fire that has probably been well controlled by the sprinklers, and, in the case where the standpipe is needed, at a height most certainly well above the lowest levels of the building.
I believe this requirement is why we see so much steel pipe buried underground to interconnect risers to avoid the protection requirement. (You see, this is often left to the mechanical engineer, not the civil engineer, so you get steel pipe “protected from corrosion” instead of something like DI or PVC). I also see a lot of this underground pipe being replaced, because it has rusted out over the years.

Providing sprinkler protection in elevator shafts and elevator machine rooms? Need I say more? Actually, I might. This is a good topic for a future article.

Here is a wish that came true. At the recent NFPA Technical Sessions in Boston, the membership wisely defeated a proposed new provision to require more smoke dampers in NFPA 90A. This was accomplished in spite of the presence of a huge voting contingent from the damper industry. I know this is not a great concern to the plumbing engineering community, but I guess a lot of you are doing HVAC. Now, I think there are important applications for smoke dampers, but the provisions of NFPA 90A have worked for me for over 30 years (That old geezer is mumbling again).

Mechanical smoke control in most fully sprinklered buildings? In my experience smoke management design cannot be adequately accomplished in buildings unless the building is fully sprinklered. This is so the fire can be kept small enough to limit smoke production to a level that can be practically handled. The irony is that, in my opinion, in most instances, the presence of fire sprinklers makes smoke management unnecessary.

These are just of few of my many concerns. I would be interested in your Code Wish List. And, if you think of it, make a code change proposal. And please remember, always follow the code.

Samuel S. Dannaway, PE, is a registered fire protection engineer and mechanical engineer with bachelor’s and master’s degrees from the University of Maryland Department of Fire Protection Engineering. He is past president and a Fellow of the Society of Fire Protection Engineers. He is president of S. S. Dannaway Associates Inc., a 15-person fire protection engineering firm with offices in Honolulu and Guam. He can be reached via email at SDannaway@ssdafire.com.