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Mounds View – Ferrellgas Plan Review <br />Page 7 of 10 <br />October 1, 2007 <br /> <br />5. Special Protection Section (page 6 and 7) – The boxes indicating “no passive special <br />protection is used” and “no active special protection is used” are checked, thus <br />identifying that no additional fire protection above code minimum is planned for this <br />installation. There is no discussion or analysis to indicate how this was determined or to <br />support such a conclusion. Exactly the opposite, this conflicts with the Exposures to <br />Facility From External Hazards worksheet (page 3) – which indicates there is a hazard to <br />the LP-Gas facility from the adjacent metal cutting, welding, and metal fabrication <br />building. The conclusion of the analysis that no additional fire protection is necessary is <br />in conflict with results of other worksheets, including water supply and fire department <br />response. <br />6. Types of Exposure Section (page 1) - A large mobile home park is located within 500 <br />feet of the proposed installation, yet was not included in the analysis. <br />7. Exposures to Facility from External Hazards (page 3) – A hazard was determined to exist <br />from the adjacent metal cutting, welding and metal fabrication building, yet there is no <br />indication as to the steps that are proposed to be taken to address the hazard. The analysis <br />also fails to include the hazard from the adjacent high piled combustible storage (i.e. <br />nothing in the worksheet analysis or hazard calculation deals with an exposure from a <br />three dimensional warehouse fire). <br />8. Potential Release Scenarios Section (page 4) - The product release scenarios in the <br />Incident Prevention Review are generic (the default ones from the analysis workbook) <br />and do not cover the actual site conditions or piping arrangements, nor do they include <br />releases from three tanks interconnected via a manifold, the container filling operation, or <br />outdoor storage of 1,900 cylinders. <br />9. Fire Department Capabilities Section (page 2) – Line items #6 and #7 are blank. <br />10. Fire Department Response Time Section (page 3) – As provided by the City, it is <br />expected that 11 to 15 minutes are necessary from alarm receipt to arrival on the scene <br />and doesn’t include additional time necessary for establishing a water supply, pulling <br />hoses, operating pumps and applying water. Suffice to say it is even longer than 11 to 15 <br />minutes for water to be applied to a tank if the initial incident involves ignition of any <br />release (i.e. a fire happens at the start of an incident). Such a result should have sounded <br />warning bells for the person conducting the analysis, but it didn’t, and neither did the <br />guidance in the NFPA/NPGA Manual for conducting such an analysis under the 2004 <br />edition of NFPA 58. Here is what page 8-7 of the NFPA/NPGA Fire Safety Analysis <br />Manual for LP-Gas Storage Facilities indicates when evaluating fire department response <br />time [note: the same language is in the Ferrellgas Policy version of the analysis manual]: <br /> <br />…If the capability to apply cooling water within the first 10 minutes of initial fire <br />exposure to the container is not present, extremely dangerous conditions could <br />begin to develop. Note that it will take several minutes after the apparatus arrives <br />at the facility gate before cooling water is actually applied to the containers and <br />that hand held hose lines will be used with water supplied from the water tank on <br />the apparatus…. <br /> <br />This analysis has therefore ignored the fact that the fire department response time for <br />water application will exceed the time for development of “extremely hazardous