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 safety analysis requirement. (See item #6, below.) NFPA 58 Section 4.3.1 (2017 Edition) 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 6.5.1 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 4,000 gallons
water capacity or multi-container installations with aggregate
water capacity exceeding 4,000 gallons.
It makes no difference whether the containers are piped separately or manifolded together. Proximity of containers is the concern. A separation of at least 25 feet between groups of containers will cause them to be considered separately.
- 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 are not acceptable. See #3, below, for more information about the required drawing.
- location of loading and unloading connections and distances to nearest propane container, buildings, and property lines.
- 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 and internal valves.
- 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.).
- an explanation of unusual situations (e.g., property line too close but same property owner, building too close but reason why it is not important, 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 it is very large. 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 (G.S. §119-54 through -62) , and North
Carolina Department of Agriculture and Consumer Services
Regulations (02 NCAC 38 .0701 through .0704) (Current as of July 2018).
- 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 (*)
- Fire Safety Analysis
- A written Fire Safety Analysis (FSA) is required for each new or enlarged site within 60 days of starting 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 or guidelines for the alternative to the FSA.
- Another method to do the FSA was first 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
- Written operation procedures and maintenance procedures
are required before a bulk plant goes into operation. See
chapter 15 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.
- Plan Submittal
- For hardcopy submittal of drawings, submit drawings in triplicate. One copy will be returned to submitter. Please submit only one copy of the fire safety analysis (FSA) and send it after the site is installed and emergency plans have been coordinated with emergency responders. 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 pertinent 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 shipping
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 Services at NCDA & CS, Standards Division, Room 310, 2 W. Edenton Street, 1050 Mail Service Center, Raleigh, North Carolina 27699-1050.
- Plans may be sent by email to email@example.com. Attachments must be in Word document (.doc or .docx) or Adobe Acrobat (.pdf) files. Attachments must be legible when printed on 8-1/2 by 11 inches or 8-1/2 by 14 inches paper. If necessary, they may be as large as 11 by 17 inches. We have no way to print larger than that. If the drawings attached are not readily legible on an 11 by 17 inch page, as determined by us, then the submittal will be refused and the drawings must be submitted by mail or delivery service.
- Facsimile transmittals are not acceptable.
- Your submittal will be recognized by a return letter, informing you of the inspector assigned to visit the site. They will contact you to arrange for a site visit, after which they will submit a report. We will send a letter either approving the site or explaining why the site or drawing(s) is not acceptable. This should be completed by three weeks after your initial submittal is received. You may revise the drawing to make the installation acceptable and resubmit it. Please plan your construction schedule to accommodate our schedule. We cannot assure that site visits or approval can happen on a shorter schedule, especially when scheduled times away from our normal duties are involved.
- Container installation is not permitted until plans are approved by this office.
Last updated July 31, 2018