Submittal Requirements for LP-Gas Bulk Storage Facilities

In August 1994, this division established some minimum submittal requirements for these proposed locations with the intent of having uniform submittals, allowing fo quicker reviews. 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. This includes the fire safety analysis requirement. (See item #6, below.) NFPA 58 Section 4.3.1 (2024 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

1. 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.

      

2. Plans must show, as a minimum, the following information:

   • 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.).

    

3. 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.

    

4. 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).

    

5. Provide name and address of installer if a party other than installer is submitting installation plan.

    

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

    

7. 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 (*) are required.

    

8. 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 engineer.

    

9.  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.

    

10. 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 environment.
    • Plans must be neat and legible and delivered to the North Carolina Department of Agriculture and Consumer Services at NCDA&CS, Standards Division, 4400 Reedy Creek Road, Raleigh, NC 27607 or mailed to NCDA&CS Standards Division, 1050 Mail Service Center, Raleigh, North Carolina 27699-1050.
    • Plans may be sent by email to standards@ncagr.gov. 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.

     

11. 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.

     

12. Container installation is not permitted until plans are approved by this office. An inspection at a bulk plant that does not have approved plans on record is subject to a civil penalty.