ML030660328

Attachment 4, Letter for NFPA Discussion

ML030660328
Person / Time
Site:	Saint Lucie
Issue date:	08/20/2002
From:	Conroy M National Fire Protection Association (NFPA)
To:	Markhenry Salley Office of Nuclear Reactor Regulation
References
Download: ML030660328 (1)

Text

-I N- uIi VA NFPX A n'ýýri Prk. Quic. N.IA 02269-9101 USA nrpa ore P(TENAT10NAL Phone -1 (617) "770-3000Far -1 (617) 770-0700 *wv August 20, 2002 Mark Salley, P.E.

Fire Protection Engineer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Mark:

you could use Following up on our phone discussion yesterday, I wanted to give you an email reply that you submitted in your discussion with others at NRC. The two requests for formal interpretations that are not being processed as the NFPA Regulations Governing Committee Projects section 6-1.4 says that requests shall not be processed if they involve text that clearly and decisively provides is just a the requested information. Your question on the 1980 edition of NFPA 12A paragraph 2-1.1.1 rewording of the text in the standard.

In other words, the NFPA 12A text talks about a fixed enclosure that will enable the concentration to be built up and maintained to ensure extinguishment in materials. Your question asks if it's installed according to 12A should it be capable of extinguishing a fire in material in an enclosure. The question asks for the same information provided by the paragraph.

Your second request for an FI also involves text that clearly provides the requested information. You are asking if section A-2-4 informs the reader of the need to provide a higher concentration and longer that hold time for deep-seated fires. After reading the 7 paragraphs in A-2-4, that is the only conclusion a reader could come to. It would not be possible to move forward with balloting the Committee on this question as the information requested by the FI request is already contained in the text.

Unfortunately, not all field situation disputes can be resolved by the NFPA Formal Interpretation process. You have explained that you have a situation that involves a cable spreading room that you believe could become a deep-seated fire. The best advice provided for deep-seated fires, higher concentrations, and longer hold times in 1980 is in A-2-4 of the 1980 edition of NFPA 12A. Based on this information you must determine if you have the potential for a deep-seated fire and then the information can be used to determine design parameters.

Please let me know if I can be of further assistance.

Regards, Mark Conroy Senior Fire Protection Engineer 617-984-7950 mconroy@nfpa.org NFPX, mi*%ion i, tit iedu.e the utirldide buider tit tire and other hatard, on the qtuahtw ot lite b%pro, iding and adtocatmng

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