How are liquefied petroleum gas tanks classified for application procedures and rule enforcement in Illinois?
LP-Gas tanks are addressed separately from either fuel dispensing or bulk storage flammable and combustible liquid storage tanks. LPG = liquefied petroleum gas, meaning that the product is stored as a liquid under pressure in the tank, but at normal pressures and temperatures, the product is a gas. Therefore, different rules apply (Title 41 Ill. Adm. Code Part 200). Also, there is a separate application for the installation of an LP-Gas tank.
If a LP-Gas tank is installed underground, or mounded in earth, what rules/applications apply?
A LP-Gas tank, whether installed above or below ground, is considered a LP-Gas tank by the Office of the State Fire Marshal. The OSFM retains jurisdiction for the inspection of these tanks and a regular LP-Gas tank installation application should be submitted. (NFPA Standard #58 does contain special rules when a LP-Gas tank is installed underground or under a mound of earth). An underground LP-Gas tank is NOT considered an underground petroleum storage tank by the OSFM and the rules for underground storage of regulated substances found in 41 Ill. Adm. Code 170 do NOT apply.
When do I have to submit an application to the OSFM for LP-Gas tanks?
Applications are required to be submitted to the OSFM for the following LP-Gas tank installations:
- Installation of tanks (including relocation of existing tanks) larger than 2,000 gallons in individual capacity.
- Installation of multiple tanks at the same site with an aggregate capacity of greater than 4,000 gallons.
- Installation of any capacity tank that will be used to dispense LP-Gas (such as refilling cylinders or fueling vehicles).
Applications are NOT required to be filed for work being done to previously inspected tanks for:
- Replacement or repair work related to existing piping or valves.
- Replacement or repair work related to existing collision protection equipment or the installation of additional means of collision protection.
- Replacement or installation of tamper protection or fencing.
- Replacement or repair work related to existing dispensers that do not provide additional dispensers or relocate dispensers.
What are the Applicable Rules of the OSFM for a LP-Gas Tank Installation?
The rules are found at 41 Illinois Administrative Code 200. The “Part 200” rules primarily reference National Fire Protection Association Standard #58 “The LP-Gas Code” for the installation and operation of liquefied petroleum gas tanks. Effective August 1, 2012 the section of the Illinois Administrative Code (41 Ill. Adm. Code 200), wherein the Office of the Illinois State Fire Marshal adopts the National Fire Protection Association’s (NFPA) Standard #58, the LP-Gas Code®, has been modified to adopt the 2011 edition of NFPA 58 to replace the previously applicable 2008 edition of that standard. The rules have also been updated to reference the 2009 edition of NFPA 54 The National Fuel Gas Code® to replace an older edition of NFPA 54 that was previously referenced. All new installations or modifications conducted in Illinois as of August 1, 2012 must comply with these updated editions of the adopted standards.
For what period of time is my OSFM LPG application review letter valid?
Application and plan review letters are valid for a period of 6 months. This is stated within the review letter.
Are there different forms for applying for LPG tank work?
Yes, the OSFM has three separate applications that apply to LP-Gas installations. Depending upon the installation circumstances, one or all of the applications may apply:
- The revised OSFM “Application for LPG Tank Installation”. This is now a three page application that has been expanded to request more extensive information in order to result in more accurate information for the OSFM and a shorter review letter pertaining to the work. This form is required to be completed, signed and submitted in triplicate, with site plans also in triplicate, for the installation or relocation of any LPG storage tank that is greater than 2,000 gallons capacity, or when the aggregate water capacity of multiple tanks exceeds 4,000 gallons or for any LPG tank, regardless of capacity, if gas will be dispensed from the tank into smaller cylinders or vehicles.
- A new application entitled “Supplemental LPG Tank Installation Application for Vertically Mounted Tanks”. This application must accompany the above-described “Application for LPG Tank Installation” if any of the proposed tanks will be installed in a vertical position.
- A new application entitled “Supplemental LPG Tank Application for Indoor LPG Dispensing”. This application must accompany the above-described “Application for LPG Tank Installation” if any dispensing of LPG will be conducted indoors (e.g., in a separate structure, an attached structure, or a room within a structure).
Are there an exceptions or modifications to the adoption of NFPA 58?
Yes. The OSFM has maintained a requirement within the Part 200 rules that does not appear in the 2011 edition of NFPA 58. The pressure relief valve discharge on each aboveground container of more than 2000 gal. water capacity shall be piped vertically upward to a point at least 7 ft. above the top of the container, and the discharge opening shall be unobstructed to the open air.
Is collision protection required to be provided for my LP-Gas tank?
The answer to this question depends upon the location of the LP-Gas tank in relation to roadways and the anticipated vehicular traffic in proximity to the tank. NFPA 58 Section 126.96.36.199 requires that: “LP-Gas containers or systems of which they are a part shall be protected from damage from vehicles”. However, the NFPA LP-Gas Handbook offers explanation that this is intended as a “performance provision” rather than a specific guideline for when protection is needed or the specific nature of the protection. The determination of threat to containers and the means of mitigation of the threat are the responsibility of the code user and the authority having jurisdiction. It is possible to not have vehicular collision protection be required depending upon the location of the tank and the anticipated vehicle traffic, or lack thereof, in proximity to the tank. The application/plan review required by the OSFM will assist owners/installers in determining whether collision protection is required.
I have an existing LP-Gas tank and want to relocate it on my property. Must I still complete and submit the OSFM LP-Gas application?
Yes. The application submittal process and subsequent on-site inspection apply to newly installed LP-Gas tanks as well as those that are relocated at a facility.
Must I apply to the OSFM to simply report an existing LP-Gas tank if I am not relocating the tank?
No. The OSFM application and plan submittal and review process, as well as the subsequently conducted field-inspection process, is designed for tanks that are being newly installed or relocated (including tanks that are being relocated at the same facility). However, existing LP-Gas tanks that are not being relocated do not have to undergo the OSFM application process on any recurring schedule.
Does NFPA 58 apply to LP-Gas at Utility Gas Plants?
No. Standards for the Storage and Handling of Liquefied Petroleum Gases at Utility Gas Plants as published in the 2008 Edition of NFPA 59 (Utility LP Gas Plant Code) are mandatory. NFPA 59 has been adopted into 41 Illinois Administrative Code 200 to address such facilities.
Does NFPA 58 address LP-Gas piping within an occupancy?
No. Standards for the Installation of Gas Appliances and Gas Piping as published in the 2009 Edition of NFPA 54 (National Fuel Gas Code) are mandatory. NFPA 54 has been adopted into 41 Illinois Administrative Code 200 to address appliance installation and piping issues.
Does NFPA 58 address LP-gas installations at natural gas processing plants, refineries and petrochemical plants?
No. Storage and handling of liquefied petroleum gas at natural gas processing plants, refineries, and petrochemical plants is required to comply with the 8th edition (2001) of Standard API 2510 of the American Petroleum Institute (Design and Construction of LPG Installation). This requirement is found within Section 200.40 of 41 Illinois Administrative Code 200.
Do I need to wait for an OSFM inspection to operate an LP-Gas tank?
Yes. Section 200.80 of 41 Illinois Administrate Code 200 requires that any liquefied petroleum gases installation requiring approval by the OSFM shall not be placed in operation until final inspection and approval is given by the OSFM.
May I supply LP-Gas to a facility or container that I know is not in compliance with the law?
No. Specifically, Section 200.90 of 41 Illinois Administrative Code 200 states that “No supplier of liquefied petroleum gases shall service any installation not in compliance with the Liquefied Petroleum Gases Law, Rules and Regulations”.
Is the self-service dispensing of LP-Gas allowed?
No. Section 200.110 of 41 Illinois Administrative Code 200 specifically prohibits the self-service of LP-Gases. The section states: “No person other than the bulk storage, container charging plant, or service station owner or a fully trained authorized employee shall use or dispense any liquefied petroleum gases at these locations”.
Who can perform LP-Gas container installation, modification or operation?
Although the OSFM does not “license” or “certify” personnel in connection with LP-Gas operations, the applicable rules do restrict those who can perform installation, service, operation and maintenance of LP-Gas tanks and equipment.
These requirements are found in two separate citations:
Section 200.100 of 41 Illinois Administrative Code 200 requires that "personnel performing installation, service, operation and maintenance work must be properly trained in such work in accordance with the applicable NFPA Standard cited in this Part. Documentation of training must be made available to the OSFM upon request".
Also, NFPA 58 which has been adopted by reference by the OSFM makes the following requirement:
4.4 Qualification of Personnel
Persons who transfer liquid LP-Gas, who are employed to transport LP-Gas, or whose primary duties fall within the scope of this code shall be trained in proper handling procedures. Refresher training shall be provided at least every 3 years. The training shall be documented.
Why do I need to do a fire safety analysis (FSA) for my existing plant?
Illinois Administrative Rules adopt NFPA 58 "The LP-Gas Code" be reference (with the 2011 edition of NFPA 58 taking effect in Illinois on August 1, 2012). A Fire Safety 5 Analysis (FSA) is required by NFPA. A FSA is required by the Code for facilities with aggregate storage of more than 4,000 gallons water capacity. This requirement is not new to the 2011 edition of NFPA 58 and has been required by previously adopted editions of the LP-Gas Code.
What is the purpose of a FSA?
The purpose of the FSA is to provide local emergency response agencies with information on the various safety features built into a propane installation that are used to control the product and the operations that may take place at the facility. Also, the FSA evaluates the hazard to the neighborhood surrounding the facility and the capabilities of local emergency response agencies.
How do I determine whether a facility or installation requires a Fire Safety Analysis?
A facility must have a written FSA prepared if it has storage containers that are greater than 4,000 gallons water capacity; or, if the aggregate amount of storage containers at the facility exceeds 4,000 gallons water capacity and those containers are either connected to one another through a manifolded filling or service connection.
Who in my organization can perform the FSA?
There are no special credentials required to fill out the FSA forms. However, the person doing so should be familiar with operations taking place at the facility and the product control hardware and how it functions.
What if no one in my organization can perform the FSA?
In addition to providing direction for company employees performing FSAs, the manual can also be used by a consultant, professional engineer or anyone else a company wishes to designate to prepare this document.
What elements must be included in the analysis?
The Fire Safety Analysis Manual has been developed to correspond to the general requirements of NFPA 58 (product control measures, local conditions of hazard within the container site, exposure to/from other properties, population density and congestion, probable effectiveness of plant fire brigades or local fire departments, consideration for adequate application of water for effective control of leakage, fire or other exposures, and (if necessary) a designated time period for review with local emergency response agencies). All of the information contained in the FSA forms must be reviewed and filled out if it is applicable to the facility. Additional information (drawings or details on the operation of equipment) can be submitted at the discretion of the submitter or if required by the authority having jurisdiction (AHJ).
Are there installations that are not covered by the FSA manual?
The manual does not address the following:
- Marine terminals, refrigerated LP-gas storage, and the transportation of LP-gas either by rail tank cars or by cargo tank trucks.
- Storage of LP-gas in salt domes and caverns.
- Installations of ASME LP-gas containers on roofs of buildings. This type of installation is excluded from the scope of this manual (even though a FSA is required for such operations according to section 188.8.131.52 of the 2001 edition of the Code) primarily because of the rarity of such installations in the United States.
- Cylinder filling operations at a dispensing facility, unless the storage threshold for LP-gas has been exceeded, requiring an FSA to be prepared.
- The use of facility employees performing as a “fire brigade.”
How do I present the analysis to the AHJ?
The owner or representative of the facility can schedule an appointment with the local emergency response agency or AHJ and present the FSA at that time. Be familiar with the elements of the FSA and be prepared to answer any questions that may arise.
What assurance do I have that the AHJ will accept the results of this FSA document? Can the AHJ require a professional engineer to perform the analysis?
Although the AHJ is not required to accept the results of the FSA, the goal of developing this tool was to provide a credible document to fire and code officials. Hence, NFPA played a prominent role in its development; in addition, the effort was enhanced by the participation of fire protection engineers currently serving on the Technical Committee on Liquefied Petroleum Gases. Should any question arise as to the credibility of the FSA, both NPGA and NFPA are available to clarify the development and rationale of the manual.
Does submitting a fire safety analysis mean that a sprinkler or other type of water protection will have to be added to an existing facility?
The FSA does not require additional equipment or systems to be added to existing facilities. Rather, the FSA reflects NFPA 58 in that the first consideration shall be an evaluation of total product control system, including emergency shutoff and internal valves equipped for remote closure and automatic shutoff using thermal (fire) actuation pull-away protection. Although fire suppression is an optional means of protection, the most effective means is to prevent the uncontrolled release of fuel, and the requirements in NFPA 58 for product control equipment and employee training effectively accomplish this goal.
What are my options if the AHJ will not accept a proposed installation without water protection for the facility?
The background and training of some AHJs will make applying water or other suppression agents a priority to a propane facility. As the facility operator, you should be knowledgeable on the important aspects of product control and training, as reflected in the requirements of NFPA 58. Make an effort to contact the AHJ and utilize the information in the FSA manual to educate the AHJ on the overall importance of product control and the realistic product release scenarios that are portrayed in the manual. Contact NPGA if additional assistance is needed.
What is the difference between a Fire Safety Analysis and an Incident Prevention Review?
The previously adopted 2004 edition of NFPA 58 referred to the safety analysis procedure an “Incident Prevention Review”. In the 2008 edition of NFPA 58 the LP-Gas Code returned to the terminology that appeared in the 2001 edition of NFPA 58 which is “Fire Safety Analysis” (FSA); the essential elements of the process, however, have not changed. The 2011 edition of NFPA 58 that is effective in Illinois on August 1, 2012 continues to use the term “Fire Safety Analysis”.