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 (2011 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. 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
- Required for single containers in excess of 2,000 gallons
water capacity or multi-container installations with aggregate
water capacity exceeding 4,000 gallons.
- Plans must show, as a minimum, the following information:
- a drawing or neat sketch showing the layout of the
property with pertinent features indicated.
- size and location of container(s).
- 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. See #3, below, for more information about the required drawing.
- location of loading and unloading risers and distances
to nearest propane container, buildings, and property
- directions or map showing location of the proposed
installation (vicinity map is desirable for remote locations).
- if fencing is required, the location of exit gates.
- the location of remote shutdown station(s) for ESVs.
- location and type of vaporizer and distances to container,
container shutoff valves, buildings, and property lines.
- an indication about the surroundings of the site (town,
industrial park, field, etc.).
- In creating a drawing, you need to pay attention to accepted drafting standards. Dimension lines must clearly indicate the distance between specified objects and must not be subject to interpretation. Distances to a line (property line, power line, right of way, etc.) must be perpendicular to the line. The scale of the drawing must allow us to clearly see the arrangement, dimensions, and detail of the proposed installation. You need not show the entire site. If you do, please show a detail of the tank area. The drawing can be a freehand sketch, a drawing where straight edge is used, a CAD drawing, or other drawing as long as it is legible and on a standard piece of paper at least 8-1/2" by 11". Drawings are not limited as to how large they are, but drawings larger than 11" by 17" can be difficult for us to store.
- Installation must comply with the latest edition of NFPA
Standard 58, North Carolina General Statutes, and North
Carolina Department of Agriculture and Consumer Services
- Provide name and address of installer if a party other
than installer is submitting installation plan.
- If not readily apparent, provide name and address of party
responsible for maintaining installation.
- Provide full information for contacting the owner/operator
of the site. Please provide name*, mailing address*, telephone
numbers (voice* and fax), and e-mail address. We know
that not all sites will have all of these methods of contact.
Please provide what you can. Items with an asterisk (*)
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. Please contact the Standards Division if you need
information on the requirements of a fire safety analysis
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
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
- 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.
- Plans must be submitted in triplicate. 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.
- 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 step toward improving our
- Plans must be neat and legible and mailed or delivered
to the North Carolina Department of Agriculture and Consumer
Standards Division, Room 310
1050 Mail Service Center
Raleigh, North Carolina 27699-1050 (for USPS shipments)
Standards Division, Room 310
2 W. Edenton Street
Raleigh, North Carolina 27601 (for UPS, FedEx, etc. shipments)
- Facsimile transmittals are not acceptable.
- Container installation is not permitted until
plans are approved by this office.
Last updated July 26, 2011