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NFPA Liquefied Petroleum Gas Code 58 Fire Safety Analysis Plan and O&M Instructions for Propane Storage Systems

Tim Laughlin, P.E.

To safeguard propane installations, the NFPA and the US EPA have developed the FSA and O&M instructions that all-applicable propane facilities must comply within a certain time frame. In some states a licensed professional engineer must fully understand and prepare the FSA plan. The 2001 edition of the National Fire Protection Associations (NFPA) Pamphlet 58, Liquefied Petroleum Gas Code requires a written Fire Safety Analysis (FSA) and written Operations & Maintenance Instructions. These requirements originated at the US Environmental Protection Agency (EPA) under the Risk Management Program (RMP). The NFPA 58 requirements are much less restrictive than what the EPA originally proposed. The requirement for a written (FSA) for all tank installations over 4,000 gallons aggregate capacity becomes effective when your State adopts the 2001 edition NFPA 58, section 3.10, Fire Protection. New propane bulk plants and tank installations and for ASME tank installations on roofs, must complete an FSA before completion of the new facility. Also, a written FSA is required for all-existing bulk plants, tanks and roof installations by three years after the effective date of the code. In North Carolina, a professional engineer registered in North Carolina must prepare the FSA. Other guidelines for an alternative FSA come under the NC Department of Agriculture. The other RMP-like requirements are found in the new Chapter 11 of NFPA 58, Operations and Maintenance. This requires written procedures for safely conducting LP-Gas activities at bulk and industrial plants. Also, these procedures must be kept up to date. Similarly, maintenance procedures must be prepared and implemented. These must be made available to contractors coming on site to do maintenance. Be sure to look at NFPA 58, Appendix A, sections A.11.2.1 and A.11.2.2 for some guidance for what is expected in these procedures and what you may use to help you prepare them. This course includes a multiple choice quiz at the end.

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