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Mounds View – Ferrellgas Plan Review <br />Page 6 of 10 <br />October 1, 2007 <br /> <br />Realize further that the Fire Safety Analysis submitted for review only addresses the three above <br />ground tanks and is not intended to address the cylinder loading dock or outside storage. As <br />such, issues like required water supply, necessary fire department response levels, storage of new <br />style composite cylinders, risk to and from exterior exposures (i.e. buildings and the mobile <br />home park), access, and storage limitations are not addressed. <br /> <br />EVALUATION OF THE INCIDENT PREVENTION REVIEW <br /> <br />Two different versions of a Product Release Prevention and Incident Preparedness Review (i.e. <br />Incident Prevention Review or Fire Safety Analysis) were submitted and although similar, the <br />two are not identical. The older version contains 90 pages and is based on the 2001 edition of <br />NFPA 58, while the version consisting of only 39 pages of worksheets appears to be based on <br />the 2004 edition of NFPA 58. Neither document is dated, so it was not possible to determine <br />absolutely which analysis governs, so for purposes of this review the 39 pages using the 2004 <br />edition of NFPA 58 will be used as the basis for compliance with NFPA 58 Section 6.23.3 which <br />states: <br /> <br />6.23.3.1 Fire protection shall be provided for installations with an aggregate water <br />capacity of more than 4000 gal and of ASME containers on roofs. <br />6.23.3.2 The modes of fire protection shall be specified in a written product release <br />prevention and incident preparedness review. <br /> <br />The following represent the comments and observations I have relating to the Incident <br />Prevention Review: <br /> <br />1. Miscellaneous Storage and Vehicles Section (page 8) – This section indicates there are <br />nearly 1,900 containers that will be on site, both full and empty, with a combined <br />capacity potentially exceeding 200,000 lbs (47,000 gallons) of propane. As already <br />discussed, the Incident Prevention Review doesn’t include release scenarios or hazard <br />introduced by the outside storage. Likewise, water application to the outside storage <br />during a fire is not factored into the analysis. The number of cylinders identified on page <br />1 of the Summary worksheet conflicts with this section. <br />2. Emergency Controls Section (page 2) – There is a conflict between the top of the table <br />which indicates that the “product control system meets alternate redundant, fail-safe <br />requirements” and line #11 below which is marked no, yet is required for the redundant, <br />fail-safety system. This also conflicts with the information on page 1 of the Summary. <br />Ferrellgas needs to clarify if complete redundant, fail-safe protection according to NFPA <br />58 is provided. <br />3. Physical Protection and Other Measures Section (page 1) – Line #2 is marked N/A, yet is <br />required to be addressed according to NFPA 58 Sections 6.16.5 and 6.23.2.1. A security <br />plan and training should be developed and approved prior to occupancy. <br />4. Points of Transfer Section (page 5) – The minimum separation distances in lines #1 and <br />#10 are not provided according to the site diagram. This was discussed earlier in the <br />section of this review relating to separation distances to transfer operations.