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Mounds View – Ferrellgas Plan Review <br />Page 8 of 10 <br />October 1, 2007 <br /> <br />conditions”, while still not recommending that any additional fire protection be provided <br />over and above code minimum. <br />11. Water Flow Rate Section (page 4) – this table indicates that a total of 854 gpm is <br />necessary to cool the containers and for firefighter protection when approaching <br />containers. This value is NOT conservative in that it ignores additional water for <br />protection of transport trucks, the cylinder loading dock, outside storage, and the office <br />building. Likewise, the flow rates calculated for tank cooling are dangerously low, given <br />the technically unsupported assumption that only one-half of any tank will require <br />cooling water. No authoritative document or study could be found to justify an <br />assumption that the fire department will only need to apply cooling water to one-half of <br />an LP tank, while leaving the remainder dry. <br />12. There are references in the analysis to a pneumatic system that only opens the internal <br />tank valves during product transfer. Design details for this should be confirmed by <br />Ferrellgas and field verified that they meet NFPA 58 requirements. <br />13. The impact of a security breach is required to be considered by the analysis according to <br />NFPA 58 Section 6.23.2.1, but was not. <br />14. A critical item ignored by the analysis is the limited fire department access that is <br />available, which is basically one road into the area via Mustang Drive. Long Lake <br />Regional Park on the west and large industrial buildings on the north and south greatly <br />constrain the fire department incident commander’s options when dealing with an <br />incident at this site. NFPA 58 Section A.6.23.3 recommends site congestion be <br />considered as part of an analysis. <br /> <br />SUMMARY <br /> <br />Based on the Ferrellgas Safety and Technical Support Policies provided with the submission, it <br />is clear that Ferrellgas takes a proactive approach to safety and intends to meet or exceed the <br />minimum adopted codes when their policies are followed. The difficulty with this review, <br />however, is the lack of drawings, reports, or specifications indicating exactly how this <br />installation will come together. Several requests were made to obtain the design information <br />typical for such an installation, and due to its absence, will require field verification of much of <br />the installation. If the assumptions made in this plan review are not correct (i.e. container <br />support, tank appurtenances, internal valves, inspection, testing, and maintenance, and so on) <br />then the design does not appear to be complete or in substantial compliance with the adopted <br />codes. Ferrellgas must realize that any code required changes found in the field will need to be <br />made at their expense. <br /> <br />A thorough examination of the Incident Prevention Review has been conducted and based on the <br />information available; I am unable to support Ferrellgas’ conclusion in the Review that <br />additional fire protection is not necessary for this installation. The Review is not internally <br />consistent in that it doesn’t follow its own recommendations or address identified hazards. It is <br />for this reason that I strongly recommend additional fire protection over and above the code <br />minimum requirements be provided and as supported by the following: <br />