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Mounds View – Ferrellgas Plan Review Page 5 of 10 October 1, 2007 11. Inspection, Operations and Maintenance – No detailed plans or procedures specific to this facility were provided to evaluate NFPA 58 compliance. Portions of a plan were included in the Ferrellgas policies provided and if followed, would appear to provide substantial compliance in those areas addressed. Cylinder Loading Dock and Outside Cylinder Storage No detailed design information is provided on the construction, piping, mechanical systems, or fire protection features associated with the cylinder loading dock. Given that many LP-gas bulk plants are constructed in out state areas without Building Code enforcement, there is sometimes a failure to realize the construction provisions that may apply. If the cylinder loading dock meets the definition of a building, then it will most likely be a High Hazard, Group H-2, occupancy and fall under the requirements of SBC Sections 307, 414 and 415.6.3. Buildings housing H-2 occupancies would be expected to address code provisions for suppression systems, type of construction, separation from other buildings/occupancies, and finally explosion control (see SBC Section 414.5.1, for example). According to Chapter 27’s Scope in the MSFC, the hazardous materials requirements in the IFC apply to LP-gas even when regulated elsewhere in the Code. The following are a few of the provisions you’ll want to consider in reviewing the dock and outside cylinder storage: 1. Permit requirements – especially limitations placed on the storage quantities, locations, heights, etc. 2. Hazardous Materials Management Plan (MSFC Section 2701.5.1) 3. Hazardous Materials Inventory Statement (MSFC Section 2701.5.2). 4. Quantity Limits for Outside Storage (MSFC Table 2703.1.1(3). For outdoor cylinder storage exceeding the Maximum Allowable Quantities in MSFC Table 2703.1.1(3), MSFC Chapter 2704 applies and specifically Section 2704.11 on clearances to combustibles. 5. Required leak detection and emergency shut off or excess flow for the cylinder loading dock (MSFC Section 2703.2, including 2703.2.2.1(6)). 6. MSFC Section 2705 for Use, Dispensing and Handling when exceeding the Maximum Allowable Quantities in the cylinder loading dock. 7. Chapter 30 in the MSFC on compressed gases also applies to LP-gas. There are only a few fire safety requirements in the adopted codes specific to the outdoor storage of LP-gas cylinders at a bulk plant. Chapter 8 of the 2004 edition of NFPA 58 contains provisions on the storage of cylinders awaiting use, resale or exchange, but there is an exception to indicate this chapter doesn’t apply to storage of cylinders at bulk plants. This leaves few adopted provisions related to quantities that can be stored, pile size and height, storage configuration, distances to combustibles, separation from buildings, and distances to property lines. It is recommended more details on the exterior cylinder storage be provided to allow a review of these items. Long term limitations to the outside cylinder storage could be addressed in the permit, Hazardous Materials Management Plan, or zoning.