Standards Division

LP Gas Concerns > Bulk Storage Facilities

Submittal Requirements for LP-Gas Bulk Storage Facilities

We have received an unprecedented number of proposals to install bulk propane storage containers over the last few years. For many years we were not too particular about the drawings submitted for the location of propane containers as long as the drawings were accurate and made sense. Most of the proposals have been excellent, but a few have been very poor.

In August 1994, this division established some minimum submittal requirements for these proposals. You will find the updated result of those requirements listed below. Submittals not meeting the requirements will be returned to you along with a letter stating that we will not consider the proposal until proper plans are received. We have been accepting marginal submittals recently in the interest of approving plans quickly. Do not count on this continuing. It is your responsibility to plan far enough ahead to get the approval before work begins. This includes the fire safey analysis requirement. (See item #6, below.) NFPA 58 (2004 Edition) Section 4.3.1 states the requirement for submitting plans before installation begins. It is also your responsibility to obtain any required local permits, including those required by planning commissions and building inspection departments.

We are very concerned about the number of containers that are installed prior to plans being approved by this office. First, it's a violation of NFPA 58 (See the above reference.) and a bad way to get started on an installation that must meet that code. Also, a few tanks have been set in violation of separation requirements listed in NFPA 58. Contrary to popular belief, there is no way for us to grant an exception to the code. Somebody will have to pay to correct the problem.

Which brings up the next point. All work done to the site, including site acquisition, site preparation, and installation of any structures or equipment before the site is approved by this office is at the financial risk of the company requesting the work. A fire safety analysis can take a significant amount of time. The delay in completing and/or accepting this analysis could create a financial burden on the requestor. You must also allow time for Department of Insurance review for State sites. Please note that inspectors do not give final approval for a site.

Care must be observed when determining the size of container support footings. The process is not one-size-fits-all since soil characteristics vary from place to place. With the high cost of land, we notice that propane containers are being installed on soils that would not have been considered just a few years ago. Larger footings may be required for the less desirable soils.

Lastly, we want to remind you of a little noticed provision in NFPA 58. Section 6.4.2 limits the number of containers at a location unless special fire protection measures are provided. With the additional storage that is going in, some locations are near the limit.

If you have any questions, please feel free to contact the Standards Division.

Requirements for Submitting Plans to Install LP-Gas Storage Containers

1. Required for single containers in excess of 2,000 gallons water capacity or multi-container installations with aggregate water capacity exceeding 4,000 gallons.

2. Plans must show, as a minimum, the following information:
   
   1. size and location of container(s).
   2. exact distances from container(s) to property lines, buildings, highways, driveways, other fuel storage containers, railroad lines and sidings, etc. Approximations will not be acceptable.
   3. location of loading and unloading risers and distances to nearest propane container, buildings, and property lines.
   4. directions or map showing location of the proposed installation (vicinity map is desirable for remote locations).
   5. if fencing is required, the location of exit gates.
   6. location and type of vaporizer and distances to container, container shutoff valves, buildings, and property lines.
   7. an indication about the surroundings of the site (town, industrial park, field, etc.).

3. Installation must comply with the latest edition of NFPA Standard 58, North Carolina General Statutes, and North Carolina Department of Agriculture and Consumer Services Regulations.

4. Name and address of installer if a party other than installer is submitting installation plan.

5. If not readily apparent, name and address of party responsible for maintaining installation.

6. A written Fire Safety Analysis (FSA) is required for each new or enlarged site before it goes into operation. A regulation change in 2002 allows an alternative to the FSA. In each case, the conclusions must state that the site is acceptable. All existing sites must also complete this FSA by July 1, 2005, or the alternative by July 1, 2005. Please contact the Standards Division if you need information on the requirements of a fire safety analysis, a list of engineers willing to be contacted to perform the analysis, or guidelines for the alternative to the FSA.
   Another method to do the FSA was made available in 2004. The Fire Safety Analysis Manual was jointly published by the NFPA and NPGA as a way for those familiar with LP-Gas equipment and operation of bulk plants to follow the instructions in the FSA Manual to write an FSA.You can download a free copy of the manual and the forms at either NFPA or NPGA websites. Be sure to get the appendix, too, as it contains the forms and tables you need.
   Do NOT send the FSA or the operating and maintenance procedures (O&M) with the site drawings. The drawing submittal is simply to get the site approved. You need to coordinate with the local fire officials and get information from them to complete the FSA. Alternate FSAs, FSAs using the FSA Manual, and O&M are not to be sent to this office. They remain onsite for inspector review and for staff training. The only FSAs to be sent to this office are those signed by a registered professional engineer.

7. Written operation procedures and maintenance procedures are required before a bulk plant goes into operation. See chapter 14 of NFPA 58. You also need to make plans to have your personnel trained on the procedures before the plant begins operation. Contractors must also be trained in appropriate parts of the procedures before they operate or perform maintenance on the facility.
   
   
8. Plans must be submitted in triplicate. Four sets are required if the installation is for State property. One copy will be returned to submitter. Please submit only one copy of the fire safety analysis (FSA). This copy will be kept in our files. Do not submit the FSA if you use the alternative method or the FSA Manual. These will be reviewed at the site by the inspector.
   
   
9. Please submit only those drawings or sketches that show the site location, placement of the tank on the site, and distances from the tank , bulkheads, vaporizers, etc., to buildings, property lines, and other features. While piping layout, building features, and other information is interesting, it is not pertenant to approving the site for the tank installation. By sending only pertinent drawings, we will save on storage space, the submitter and the state will both save on shippings costs, and we will take a small step toward improving our environment.
   
   
10. Plans must be neat and legible and mailed or delivered to the North Carolina Department of Agriculture and Consumer Services at:
    
    Standards Division, Room 310
    1050 Mail Service Center
    Raleigh, North Carolina 27699-1050
    
    or
    
    Standards Division, Room 310
    2 W. Edenton Street
    Raleigh, North Carolina 27601
    
    
11. Facsimile transmittals are not acceptable.

12. Container installation is not permitted until plans are approved by this office.

Last updated January 17, 2006