Fire Safety Analysis

All new and existing LP-Gas bulk plants must meet certain documentation requirements to operate in North Carolina. One such requirement is to have a fire safety analysis (FSA) prepared in accordance with NFPA 58, the Liquefied Petroleum Gas Code, section 3.10.2.2 (2001 Edition) or section 6.23.3.2 (2004 Edition). According to the North Carolina Board of Examiners for Engineers and Surveyors, the fire safety analysis must be performed by a professional engineer (PE) licensed in North Carolina.

In 2004, the NFPA and NPGA jointly released the Fire Safety Analysis Manual (FSA Manual). It has been updated each time a new edition of the LP-Gas Code was released. This manual is a simplified method for meeting the requirements of providing an FSA. It is designed for a person familiar with LP-Gas equipment and with plant operations to write the FSA. An engineering background is not required. You may download the FSA Manual free of charge from the Propane Education and Research Council website. Or you may go to the NPGA website and enter "FSA Manual" in the search function. (NPGA members only.) You should use the manual that matches the edition of the LP-Gas Code in effect where you are or for the edition of the LP-Gas Code in effect when the facility was installed or modified.

Alternative Fire Safety Analysis 

The LP-Gas Regulations (02 NCAC 38 .0701 (1) (f) through (h)) allow for an alternative to the fire safety analysis. The alternative to the fire safety analysis is a much less technical document and includes a meeting between the facility owner and local fire officials. It does not require input by a PE. We have a sample format for this documentation. 

This method requires a meeting between the facility owners or the designated agent and local fire officials. The meeting is intended as a method for exchanging information between the owner and the emergency responders on the fire hazards and methods to mitigate them. The items discussed during the meeting will be documented. The meeting documentation and the complete alternative fire safety analysis shall be kept onsite and immediately available for inspection by NCDA&CS personnel.

Following is a brief summary of the regulations, making a guideline that will meet the requirements of the alternative method. We suggest that you download and use the sample format as a detailed guide for writing your document.

The considerations fall into three general categories: Exposure of Adjacent Properties; Emergency Access Routes; and Review Equipment and Emergency Shutdown Procedures. These categories and items to consider are listed below.

• Exposure of Adjacent Properties
  • Review of hazardous exposures to or from real property, population or congestion adjacent to the facility. The primary method of evaluating the concerns will be according to separation requirements of NFPA 58.
  • Review of exposures within the site. The primary method of evaluating the concerns will be according to separation and installation requirements of NFPA 58.
• Emergency Access Routes
  • Review of emergency access routes to the facility.
  • Arrange for access to the facility by emergency responders.
• Review Equipment and Emergency Shutdown Procedures
  • Identify and locate emergency shut down controls.
  • Identify and locate manual shutdown controls and valves.
  •  Familiarize emergency responders with shut down procedures.
  • Determine the best location for listing of the emergency contact name(s) and telephone number(s) for the facility owner.
  •  Identify the emergency responders, whether they are an onsite fire brigade or an offsite fire department.
  • Identify the source of water intended for use to mitigate an incident at the site.

Documentation

The above facility review for the alternative FSA shall be documented in writing, including the results of each determination of the items above, names, positions, addresses and phone numbers of the participants of this meeting, the date and time of the meeting, and the location of such meeting. Signatures of the participants are required.

If arrangements cannot be made to meet with the local fire officials within 60 days of the commencement of plant operations, documentation of efforts to arrange the meeting and the reasons given for not being able to meet must be listed. If this meeting cannot be completed within the 60 day period, the Authority Having Jurisdiction (NCDA&CS) may terminate operation of the plant facility until such meeting has taken place or a fire safety analysis is completed.

What if the Alternative FSA meeting has unresolved concerns?

If the local fire officials determine that they are not capable of responding to an incident at the facility or that they do not have the expertise to determine the above listed considerations, the facility owner may offer design changes to meet the concerns of the fire official. If the owner and the fire officials fail to arrive at a consensus about the acceptability of the conditions listed above, a fire safety analysis as referenced in NFPA 58 must be performed.

Existing Facilities

All facilities are required to have a fire safety analysis and available for review. If the fire safety analysis or the alternate method documentation is not available for inspection, the facility may have to terminate operation until such documentation is available. Keep in mind that the results of the alternative meeting may determine that another form of the fire safety analysis (one written by an outside source, usually a registered professional engineer, or using the Fire Safety Analysis Manual) is required, which will require additional time to complete.