Corrections from last inspection made satisfactorily.

paul following up as to where we are in the progration of instaltion.

Received cover letter from Paul Marcolina with an attached letter from Air Products and Chemicals verifying they market the cabinet for the intended use and providing supporting information for their position that the cabinet meets the intent of IFC requirements, including an automatic fire suppression system.

Meeting and D. Hanneman, S. Rogers to discuss Micron's proposal. Dave requested they provide manufacturer's statement that the proposed cabinet with vermiculite in the base and UV/IR/heat detection constitutues an "automatic fire extinguishing/suppression system in accordance with Chapter 9" as required by IFC table 1805.2.1; or verification by an outside design professional that the proposed cabinet design constitutes an acceptable alternative to the required fire protection. Micron agreed to obtain and resubmit. At the end of the meeting, Bobbie refered to a position paper from the manufacturer dated June 15, 2007, which was not not previously submitted; a copy was left with us.

Meeting at city hall with J. Velikoff, P. Marcolina and Tom Roberts of Micron, J. Gilliland, S. Rogers to discuss Micron's proposal. No new information provided. Requested they provide manufacturer's statement that the proposed cabinet with vermiculite in the base and UV/IR/heat detection constitutues an "automatic fire extinguishing/suppression system in accordance with Chapter 9" as required by IFC tatle 1805.2.1; or approval/certification by an approved testing lab verifying the proposed cabinet design constitutes an acceptable alternative to the required fire protection. Micron to reschedule another meeting when info is ready and present it to Dave Hanneman for review.

Onsite meeting with facility engineers. I explained my concerns with the resubmitted information; they provided additional clarification but no further documentation. I requested they provide additional information, including a specific plan of Micron's proposed design, the length and slope of the tubes connecting the cabinet to workstations, a clear manufacturer's statement indicating the proposed cabinet is intended to be used without a further fire protection system; the full laboratory test report (rather than just the power point slides), any third-party technical opinions of the test results and the testing lab's protocol; and if available, the results of any tests done on the proposed cabinet with full containers of TMA spilled within the cabinet. I explained this information would be subject to further consideration by the Fire Official and Building Official, and it would probably require technical assistance and an outside technical opinion, in accordance with IFC104.7.2 and 104.9.
I explained that my principle concern is the lack of an "approval", or "listing" by a testing laboratory or even a statement by the manufacturer indicating that the cabinet arrangement has been verified to be an equivalent alternative to the Code required "fire protection system". Another concern is the lack of a plan of Micron's proposed installation to compare to the test set-up. Concerns with the test information provided include: lack of information on the name and credentials of the testing laboratory; the limited information provided by the Power Point slides instead of a complete test report; the test protocol uses isododecane instead of TMA in the bulk canister ("to provide a safe testing apparatus"); the test protocol uses only 148 grams of TMA (equivalent volume of one, ¼" line of 56.9 ft length) rather than to spill of one of the two 2-liter canisters which are intended to be stored in the cabinet; there is conflicting information on the weight and volume of vermiculite used; the obvious differences in comparing the use of vermiculite to "over-packing" TMA canisters during shipment and the proposed cabinet arrangement in which the vermiculite material is approximately 5' below the TMA canisters.
The 2006 Fire Code requires the cabinet to be "internally protected with an approved, automatic fire-extinguishing or suppression ("fire protection" per 2006) system complying with Chapter 9". In the proposed arrangement, vermiculite material, which is supposed to act as the fire protection agent, is located at the bottom of the cabinet. The Power Point slide indicates "the bulk of the TMA will burn before it hits vermiculite" (page 4) and "the bags were melted by the burning TMA" (P 12). This indicates to me that the fire protection affect of the vermiculite was minimal based on the amount of TMA that burned before hitting the vermiculite. Perhaps the vermiculite would have more of an effect in a larger spill, but that scenario was not tested according to the information provided.

Received 2nd letter and additiaonl information from Micron. Copy attached

Reviewed initial letter. Letter provides insufficient information to understand the concept or the alternative design proposal. Will discuss at next site visit.