403-16 Log #CP16 & 403-27 Log #CP25 -Dan Pierce C.M.F. 1. NFPA 403, 3.3.2 - Actual Response Time. “The total period of time measured from the time of an alarm until the first ARFF vehicle arrives at the scene of an aircraft accident and is in position to apply agent.” Is “actual response time” the same as “demonstrated response time” in 9.1.3? NFPA 1710 – Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments. 18.104.22.168 The fire department shall establish the following objectives: (1) Alarm handling time to be completed in accordance with 22.214.171.124 (2) 80 seconds for turnout time for fire and special operations response and 60 seconds turnout time for EMS response. (3)* 240 seconds or less travel time for the arrival of the first arriving engine company at a fire suppression incident and 480 seconds or less travel time for the deployment of an initial full alarm assignment at a fire suppression incident. (4) 240 seconds or less travel time for the arrival of a unit with first responder with automatic external defibrillator (AED) or higher level capability at an emergency medical incident. (5) 480 seconds or less travel time for the arrival of an advanced life support (ALS) unit at an emergency medical incident, where this service is provided by the fire department provided a first responder with AED of basic life support (BLS) unit arrived in 240 seconds or less travel time. 126.96.36.199.3 The fire department shall establish a performance objective of having an alarm processing time of not more than 60 seconds for at least 90 percent of the alarms and not more than 90 seconds for at least 99 percent of the alarms, as specified by NFPA 1221. 188.8.131.52 The fire department shall establish a performance objective of not less than 90 percent for the achievement of each turnout time and travel time objective specified in 184.108.40.206. -------------------------------------------------------------------------------------------------------------------220.127.116.11 Initial Arriving Company 18.104.22.168.1 The fire department’s fire suppression resources shall be deployed to provide for the arrival of an engine company within a 240-second travel time to 90 percent of the incidents as established in Chapter 4. Total Response Time = 60 sec. (Alarm Processing) + 80 sec. (Turnout Time) + 240 sec. (Travel Time) = 380 SECONDS (6.3 Min.) 22.214.171.124 The airport fire department shall deploy the required number of ARFF vehicles required for the airport’s assigned category as established by NFPA 403. (Note- A four minute response in the RRA is consistent with the NFPA 1710 travel time requirement.) 3. NFPA 1710, 126.96.36.199 - Total Response Time a. 188.8.131.52 - Alarm processing time (60 sec.) + b. 184.108.40.206 - Turnout time (80 sec.) + c. 220.127.116.11 - Travel time (240 sec.) Total Response Time = 60 sec. (Alarm Processing) + 80 sec. (Turnout Time)+ 240 sec. (Travel Time) = 380 SECONDS (6.3 Min.) 4. NFPA 1710, 18.104.22.168 “The airport fire department shall deploy the required number of ARFF vehicles required for the airport’s assigned category as established by NFPA 403.” 5. NFPA 1710, 5.5 Airport Rescue and Fire Fighting Services “5.5.2 ARFF operations shall be organized to ensure the fire department‘s capability includes personnel, equipment and resources to deploy the initial arriving company, the initial full alarm assignment, and additional alarm assignments as required in 5.2.4.” 6. NFPA 403 9.13 Using a NFPA 2-minute “demonstrated response” anywhere in the RRA is not consistent with ICAO Annex 14, 9.2.21 standard or FAA Part 139, 139.319 regulations. 7. NFPA 403 9.13 Using a NFPA “demonstrated response time” requirement of 2-minutes anywhere in the RRA does not use the same fundamental reasoning as identified in NFPA 1710, 22.214.171.124 “Total Response Time”, for initial response of other fire department equipment responding to an on/off airport incident. NFPA 1710 Annex A Fig. 126.96.36.199 8. NFPA 403, 9.13 Using a “demonstrated response time” of 2-minutes anywhere in RRA is not practical for U.S. Congressional funding as identified in ACRP 7 & 12 reports. (Reference prior presentation on ACRP Reports Arguments). DOT/FAA AR-11/27 a. Fig. 27 shows typical burn through of aircraft skin adjacent to fuel in less than 2 minutes using an “average” (pg.37) heat flux of 120-150 kW/m² with 2” of insulation. Wouldn’t this “average” heat flux scenario exceed current NFPA 403 3-minute control requirements for Q1agent application? b. Table 7@ 5(< 16.4 ft.), Table 9 @ 4?(<16.4 ft.), Table [email protected] (16 ft.) indicates no advantage to 2-minute response to reduce “Time Region” life safety effects in scenario for groups 1, 2 or 3 respectively. AR 11-27 Group Comparisons Group 1 Group 2 Group 3 Group 4 Group 5 Group 6 Group 7 Group 8 Fire Width 240 159 89 240 73 240 240 240 Max Flame Height 266 202 137 266 240 208 208 266 Max Flame Emissive Power 20 20.4 24.6 20 20 20 20 20 Heat Release Rate 170 113 63 170 170 170 170 170 Offset Distance view factor 7.1 5.1 3.4 7.1 29 29 7.1 Distance Flux = 9.59 kW/m² 19.1 50 44 63 104 104 9.2 63 R1 Dist. for 2-min. Response 39 33 33 16.4 74 39 4.9 n/a R1 Dist. for 3-min. Response 52 49 39 33 90 59 8.2 n/a Group 1 Group 2 Group 3 Group 4 Group 5 involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero. involves a 48-m (159-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero. involves a 27-m (89-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero. involves a 73-m (240-ft)-long aircraft with a 2.5-mm (0.1-in.) aluminum skin. The wind speed is assumed to be zero. involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and the aircraft is downwind of the source fire. Group 6 involves a 73-m (240-ft)-long aircraft with a 2.5-mm (0.1-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and the aircrafty is downwind of the source fire. Group 7 involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and the aircraft is upwind of the source fire. Group 8 involves a 73-m (240-ft)-long aircraft with a robustly constructed composite skin. The wind speed is assumed to be zero. 10. DOT/FAA AR-11/29 3.31 a. “The ICAO RFFP I  noted that the existing 3-minute vehicle response time specified in Annex 14 was considered an acceptable upper limit, though it was recognized that, under many instances, airport authorities could improve (lower) this limit. ICAO RFFP II considered that a 2-minute response time to any part of the airport movement area should be an objective. Their official recommendation was that response time to any part of the airport movement area under optimum conditions of visibility and surface conditions should be not more than 3 minutes, but preferably, not more than 2 minutes.” Note – Use of the ICAO reference (above), is a subjective argument itself based on speculative accident conditions. “They indicated that a desirable response time would be 90 seconds (0second response time would be the goal, but it is obviously not practical), with a 2-minute response as optimum.” –pg. 13 Really? b. “The current 2-minute response time in NFPA 403 is based on what is practical . It was shown that the Lindemann assumption  of 2 minutes before the onset of hazardous conditions is optimistic in some scenarios.” –pg. 104 c. Appendix Table D-3 - “The ARFFRWG panel members suggested that an additional time criteria be established for ARFF response to preannounced incidents. A qualitative review of the incidents in appendix D, where ARFF had a potential impact, does not show a substantial percentage of incident prenotification. This does not necessarily include response to minor incidents, which could develop into major incidents. From the data and analysis in this report, there is an insufficient technical basis to modify the current NFPA 403 response time criteria.” -Pg. 105 Note – The last sentence (above) is a false premise based on the data provided in Table D-3. On many incidents, ARFF response times over 2-minutes (majority) were NOT identified where ARFF assisted in rescue/fire suppression operations. The Cherry report (DOT/FAA/AR-09/18) provides additional response time data. From the data and analysis in this report, there is insufficient technical basis to support the current NFPA 403 response time criteria. TV (actual vehicle response time) + TB (90% extinguishment time) = TE (occupants exposure time). Note - A TV actual vehicle response time of 2-minutes from an ARFF station to any point in the RRA for an Alert-3 without prior notification for the incident is not practical. This response performance requirement only satisfies a very low probability of incidents. A “hot-spot” like that used by the USMC may satisfy this standard. Some airports may require multiple “hot spots” to comply with a NFPA 2minute response requirement in the RRA. c. Immersion exception? - “Interior aircraft ignition may not be prevented if the aircraft is totally immersed in fire, even with a rapid (less than 2 minutes) ARFF response. The current assumption that there may be 2 minutes before occupants are threatened is optimistic for the analyzed scenarios of interest in this report.” -pg. 112 e. Insufficient data? - “There were only 27 major accidents identified over the period from 1992 to the time of this analysis (20 years) involving large (?) occupant load in which Aircraft Rescue and Firefighting (ARFF) provided potential assistance, indicating the low probability of such an accident. Even under the most favorable response scenarios, ARFF response may have limited effectiveness because of potential rapid breach of the fuselage (by fire or by impact) and resulting rapidly deteriorating cabin conditions.” -pg. 111 11. ARFFRWG Final Draft to ARAC a 3-minute time objective to begin agent application at any point on any runway at all indexed airports is identified. -pg.17 “Category 4 & 5 Airports 5 3 Minutes Begin discharge of required agent from first required vehicle 6 4 Minutes Begin discharge of required agent from all other required vehicles 7 Establish incident command system and request additional resources 8 Initiate access to aircraft cabin” etc… 12. Other NFPA Life Safety Codes (i.e. NFPA 101, 1710 etc.) do not use worst case scenarios to establish minimum life safety standards. Example: A fire in a high occupancy structure that restricts egress through any corridor or door to a safe area (i.e., WTC 1 & 2 on 9/11/2001) -NFPA 101 Example: A bus carrying multiple occupants is involved in a traffic collision with a tractor trailer vehicle transporting thousands of gallons of gasoline. -NFPA 1710 13.NFPA 403 9.13 Because of practicality, cost and risk analysis (severity/probability matrix), the 2minute ARFF “demonstrated response time” probably will not change an AHJ’s airport ARFF response requirement that currently complies with existing ICAO/FAA standards/regulations. 14. NFPA 403 9.13 Why has the 2-minute NFPA 403 “demonstrated response time” been modified for practical use by the U.S. military? Thank-you!