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Arguments to Support an Increase in Response Time

Arguments to Support an Increase in Response Time. 403-16 Log #CP16 & 403-27 Log #CP25 -Dan Pierce C.M.F.

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Arguments to Support an Increase in Response Time

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  1. Arguments to Support an Increase in Response Time 403-16 Log #CP16 & 403-27 Log #CP25 -Dan Pierce C.M.F.

  2. 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?

  3. 3. NFPA 1710, 3.3.53.6 - Total Response Time a. 3.3.53.3 - Alarm processing time (60 sec.) + b. 3.3.53.8 - Turnout time (80 sec.) + c. 3.3.53.7 - 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. 4.NFPA 1710, 5.5.4.1 “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. 5. NFPA 1710, 5.5 Airport Rescue and Fire Fighting Services “5.5.2ARFF 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. 6. NFPA 4039.13 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. 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, 3.3.53.6 “Total Response Time”, for initial response of other fire department equipment responding to an on/off airport incident.

  8. NFPA 1710 Annex A Fig. 3.3.53.6

  9. 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).

  10. 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 11@5 (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.

  11. 10.DOT/FAA AR-11/29 3.31 a.“The ICAO RFFP I [10] 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 (0-second response time would be the goal, but it is obviously not practical), with a 2-minute response as optimum.”–pg. 13 Really?

  12. b.“The current 2-minute response time in NFPA 403 is based on what is practical [1]. It was shown that the Lindemann assumption [17] of 2 minutes before the onset of hazardous conditions is optimistic in some scenarios.” –pg. 104

  13. c. Appendix Table D-3 - “The ARFFRWG panel members suggested that an additional time criteria be established for ARFF response to pre-announced 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.

  14. TV (actual vehicle response time) + TB (90% extinguishment time) = TE (occupants exposure time). Note - A TV actual vehicle responsetime 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 2-minute response requirement in the RRA.

  15. 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

  16. e.Insufficient data? - “There were only 27major 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

  17. 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 53 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…

  18. 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

  19. NFPA 4039.13 Because of practicality, cost and risk analysis (severity/probability matrix), the 2-minute ARFF “demonstrated response time” probably will not change an AHJ’s airport ARFF response requirement that currently complies with existing ICAO/FAA standards/regulations.

  20. 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?

  21. ARFF Solutionswww.arffsolutions.comDM Pierce A.F.O. Thank-you!

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