FREQUENTLY ASKED QUESTIONS

LP-GAS STORAGE TANKS

Note: These questions and answers apply to storage tanks for Liquefied
Petroleum Gas (LP-Gas). They are NOT applicable to storage tanks containing
flammable or combustible liquids.

1. How are liquefied petroleum gas tanks classified for application procedures
and rule enforcement in Illinois?

LP-Gas tanks are addressed separately from either fuel dispensing or bulk storage
flammable and combustible liquid storage tanks. LPG = liquefied petroleum gas, meaning
that the product is stored as a liquid under pressure in the tank, but at normal pressures
and temperatures, the product is a gas. Therefore, different rules apply (Title 41 Ill. Adm.
Code Part 200). Also, there is a separate application for the installation of an LP-Gas tank.

2. If a LP-Gas tank is installed underground, or mounded in earth, what

rules/applications apply?

A LP-Gas tank, whether installed above or below ground, is considered a LP-Gas tank by the
Office of the State Fire Marshal. The OSFM retains jurisdiction for the inspection of these
tanks and a regular LP-Gas tank installation application should be submitted. (NFPA
Standard #58 does contain special rules when a LP-Gas tank is installed underground or
under a mound of earth). An underground LP-Gas tank is NOT considered an underground
petroleum storage tank by the OSFM and the rules for underground storage of regulated
substances found in 41 Ill. Adm. Code 170 do NOT apply.

3. When do I have to submit an application to the OSFM for LP-Gas tanks?

Applications are required to be submitted to the OSFM for the following LP-Gas tank
installations:

 Installation of tanks (including relocation of existing tanks) larger than 2,000 gallons
in individual capacity.
 Installation of multiple tanks at the same site with an aggregate capacity of greater
than 4,000 gallons.
 Installation of any capacity tank that will be used to dispense LP-Gas into smaller
cylinders.

Applications are NOT required to be filed for work being done to previously inspected tanks
for:

 Replacement or repair work related to existing piping or valves

 Replacement or repair work related to existing collision protection equipment or the
installation of additional means of collision protection
 Replacement or installation of tamper protection or fencing
 Replacement or repair work related to existing dispensers that do not provide
additional dispensers or relocate dispensers

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4. What are the Applicable Rules of the OSFM for a LP-Gas Tank Installation?

The rules are found at 41 Illinois Administrative Code 200. The “Part 200” rules primarily
reference National Fire Protection Association Standard #58 “The LP-Gas Code” for the
installation and operation of liquefied petroleum gas tanks. Effective August 1, 2012 the
section of the Illinois Administrative Code (41 Ill. Adm. Code 200), wherein the Office of
the Illinois State Fire Marshal adopts the National Fire Protection Association’s (NFPA)
Standard #58, the LP-Gas Code®, has been modified to adopt the 2011 edition of NFPA 58
to replace the previously applicable 2008 edition of that standard. The rules have also
been updated to reference the 2009 edition of NFPA 54 The National Fuel Gas Code® to
replace an older edition of NFPA 54 that was previously referenced. All new installations or
modifications conducted in Illinois as of August 1, 2012 must comply with these updated
editions of the adopted standards.

5. For what period of time is my OSFM LPG application review letter valid?

Application and plan review letters are valid for a period of 6 months. This is stated within
the review letter.

6. Are there different forms for applying for LPG tank work?

Yes, the OSFM has three separate applications that apply to LP-Gas installations.
Depending upon the installation circumstances, one or all of the applications
may apply:

 The revised OSFM “Application for LPG Tank Installation”. This is now a three page
application that has been expanded to request more extensive information in order to
result in more accurate information for the OSFM and a shorter review letter
pertaining to the work. This form is required to be completed, signed and submitted
in triplicate, with site plans also in triplicate, for the installation or relocation of any
LPG storage tank that is greater than 2,000 gallons capacity, or when the aggregate
water capacity of multiple tanks exceeds 4,000 gallons or for any LPG tank,
regardless of capacity, if gas will be dispensed from the tank into smaller cylinders or
vehicles.

 A new application entitled “Supplemental LPG Tank Installation Application for

Vertically Mounted Tanks”. This application must accompany the above-described
“Application for LPG Tank Installation” if any of the proposed tanks will be installed in
a vertical position.

 A new application entitled “Supplemental LPG Tank Application for Indoor LPG
Dispensing”. This application must accompany the above-described “Application for
LPG Tank Installation” if any dispensing of LPG will be conducted indoors (e.g., in a
separate structure, an attached structure, or a room within a structure).

7. Are there an exceptions or modifications to the adoption of NFPA 58?

Yes. The OSFM has maintained a requirement within the Part 200 rules that does not
appear in the 2011 edition of NFPA 58. The pressure relief valve discharge on each
aboveground container of more than 2000 gal. water capacity shall be piped vertically
upward to a point at least 7 ft. above the top of the container, and the discharge
opening shall be unobstructed to the open air.
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8. Is collision protection required to be provided for my LP-Gas tank?

The answer to this question depends upon the location of the LP-Gas tank in relation to
roadways and the anticipated vehicular traffic in proximity to the tank. NFPA 58 Section
6.6.1.2 requires that: “LP-Gas containers or systems of which they are a part shall be
protected from damage from vehicles”. However, the NFPA LP-Gas Handbook offers
explanation that this is intended as a “performance provision” rather than a specific
guideline for when protection is needed or the specific nature of the protection. The
determination of threat to containers and the means of mitigation of the threat are the
responsibility of the code user and the authority having jurisdiction. It is possible to not
have vehicular collision protection be required depending upon the location of the tank
and the anticipated vehicle traffic, or lack thereof, in proximity to the tank. The
application/plan review required by the OSFM will assist owners/installers in determining
whether collision protection is required.

9. I have an existing LP-Gas tank and want to relocate it on my property. Must

I still complete and submit the OSFM LP-Gas application?

Yes. The application submittal process and subsequent on-site inspection apply to newly
installed LP-Gas tanks as well as those that are relocated at a facility.

10. Must I apply to the OSFM to simply report an existing LP-Gas tank if I am
not relocating the tank?

No. The OSFM application and plan submittal and review process, as well as the
subsequently conducted field-inspection process, is designed for tanks that are being
newly installed or relocated (including tanks that are being relocated at the same
facility). However, existing LP-Gas tanks that are not being relocated do not have to
undergo the OSFM application process on any recurring schedule.

11. Does NFPA 58 apply to LP-Gas at Utility Gas Plants?

No. Standards for the Storage and Handling of Liquefied Petroleum Gases at Utility Gas
Plants as published in the 2008 Edition of NFPA 59 (Utility LP Gas Plant Code) are
mandatory. NFPA 59 has been adopted into 41 Illinois Administrative Code 200 to
address such facilities.

12. Does NFPA 58 address LP-Gas piping within an occupancy?

No. Standards for the Installation of Gas Appliances and Gas Piping as published in the
2009 Edition of NFPA 54 (National Fuel Gas Code) are mandatory. NFPA 54 has been
adopted into 41 Illinois Administrative Code 200 to address appliance installation and
piping issues.

13. Does NFPA 58 address LP-gas installations at natural gas processing plants,
refineries and petrochemical plants?

No. Storage and handling of liquefied petroleum gas at natural gas processing plants,
refineries, and petrochemical plants is required to comply with the 8th edition (2001) of
Standard API 2510 of the American Petroleum Institute (Design and Construction of LPG
Installation). This requirement is found within Section 200.40 of 41 Illinois
Administrative Code 200.
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14. Do I need to wait for an OSFM inspection to operate an LP-Gas tank?

Yes. Section 200.80 of 41 Illinois Administrate Code 200 requires that any liquefied
petroleum gases installation requiring approval by the OSFM shall not be placed in
operation until final inspection and approval is given by the OSFM.

15. May I supply LP-Gas to a facility or container that I know is not in

compliance with the law?

No. Specifically, Section 200.90 of 41 Illinois Administrative Code 200 states that “No
supplier of liquefied petroleum gases shall service any installation not in compliance with
the Liquefied Petroleum Gases Law, Rules and Regulations”.

16. Is the self-service dispensing of LP-Gas allowed?

No. Section 200.110 of 41 Illinois Administrative Code 200 specifically prohibits the self-
service of LP-Gases. The section states: “No person other than the bulk storage, container
charging plant, or service station owner or a fully trained authorized employee shall use or
dispense any liquefied petroleum gases at these locations”.

17. Who can perform LP-Gas container installation, modification or

operation?

Although the OSFM does not “license” or “certify” personnel in connection with LP-Gas
operations, the applicable rules do restrict those who can perform installation, service,
operation and maintenance of LP-Gas tanks and equipment.

These requirements are found in two separate citations:

Section 200.100 of 41 Illinois Administrative Code 200 requires that “personnel performing
installation, service, operation and maintenance work must be properly trained in such work
in accordance with the applicable NFPA Standard cited in this Part. Documentation of
training must be made available to the OSFM upon request”.

Also, NFPA 58 which has been adopted by reference by the OSFM makes the following
requirement:

4.4 Qualification of Personnel.

Persons who transfer liquid LP-Gas, who are employed to transport LP-Gas, or whose
primary duties fall within the scope of this code shall be trained in proper handling
procedures. Refresher training shall be provided at least every 3 years. The training shall be
documented.

The following frequently asked questions were taken from website of the National
Propane Gas Association (NPGA), which in conjunction with the National Fire
Protection Association (NFPA) developed the Fire Safety Analysis Manual under a
project that was funded by the Propane Education and Research Council (PERC).

18. Why do I need to do a fire safety analysis (FSA) for my existing plant?

Illinois Administrative Rules adopt NFPA 58 “The LP-Gas Code” be reference (with the
2011 edition of NFPA 58 taking effect in Illinois on August 1, 2012). A Fire Safety
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Analysis (FSA) is required by NFPA. A FSA is required by the Code for facilities with
aggregate storage of more than 4,000 gallons water capacity. This requirement is not
new to the 2011 edition of NFPA 58 and has been required by previously adopted
editions of the LP-Gas Code.

19. What is the purpose of a FSA?

The purpose of the FSA is to provide local emergency response agencies with
information on the various safety features built into a propane installation that are
used to control the product and the operations that may take place at the facility.
Also, the FSA evaluates the hazard to the neighborhood surrounding the facility and
the capabilities of local emergency response agencies.

20. How do I determine whether a facility or installation requires a Fire

Safety Analysis?

A facility must have a written FSA prepared if it has storage containers that are
greater than 4,000 gallons water capacity; or, if the aggregate amount of storage
containers at the facility exceeds 4,000 gallons water capacity and those containers
are either connected to one another through a manifolded filling or service
connection.

21. Who in my organization can perform the FSA?

There are no special credentials required to fill out the FSA forms. However, the
person doing so should be familiar with operations taking place at the facility and the
product control hardware and how it functions.

22. What if no one in my organization can perform the FSA?

In addition to providing direction for company employees performing FSAs, the

manual can also be used by a consultant, professional engineer or anyone else a
company wishes to designate to prepare this document.

23. What elements must be included in the analysis?

The Fire Safety Analysis Manual has been developed to correspond to the general
requirements of NFPA 58 (product control measures, local conditions of hazard within
the container site, exposure to/from other properties, population density and
congestion, probable effectiveness of plant fire brigades or local fire departments,
consideration for adequate application of water for effective control of leakage, fire or
other exposures, and (if necessary) a designated time period for review with local
emergency response agencies). All of the information contained in the FSA forms
must be reviewed and filled out if it is applicable to the facility. Additional information
(drawings or details on the operation of equipment) can be submitted at the
discretion of the submitter or if required by the authority having jurisdiction (AHJ).

24. Are there installations that are not covered by the FSA manual?

The manual does not address the following:

1. Marine terminals, refrigerated LP-gas storage and the transportation of LP-gas
either by rail tank cars or by cargo tank trucks.
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 2. Storage of LP-gas in salt domes and caverns.
3. Installations of ASME LP-gas containers on roofs of buildings. This type of
installation is excluded from the scope of this manual (even though a FSA is
required for such operations according to section 3.10.2.2 of the 2001 edition
of the Code) primarily because of the rarity of such installations in the United
States.
4. Cylinder filling operations at a dispensing facility, unless the storage threshold
for LP-gas has been exceeded, requiring an FSA to be prepared.
5. The use of facility employees performing as a “fire brigade.”

25. How do I present the analysis to the AHJ?

The owner or representative of the facility can schedule an appointment with the
local emergency response agency or AHJ and present the FSA at that time. Be
familiar with the elements of the FSA and be prepared to answer any questions that
may arise.

26. What assurance do I have that the AHJ will accept the results of this FSA
document? Can the AHJ require a professional engineer to perform the
analysis?

Although the AHJ is not required to accept the results of the FSA, the goal of
developing this tool was to provide a credible document to fire and code officials.
Hence, NFPA played a prominent role in its development; in addition, the effort was
enhanced by the participation of fire protection engineers currently serving on the
Technical Committee on Liquefied Petroleum Gases. Should any question arise as to
the credibility of the FSA, both NPGA and NFPA are available to clarify the
development and rationale of the manual.

27. Does submitting a fire safety analysis mean that a sprinkler or other type
of water protection will have to be added to an existing facility?

The FSA does not require additional equipment or systems to be added to existing
facilities. Rather, the FSA reflects NFPA 58 in that the first consideration shall be an
evaluation of total product control system, including emergency shutoff and internal
valves equipped for remote closure and automatic shutoff using thermal (fire)
actuation pull-away protection. Although fire suppression is an optional means of
protection, the most effective means is to prevent the uncontrolled release of fuel,
and the requirements in NFPA 58 for product control equipment and employee
training effectively accomplish this goal.

28. What are my options if the AHJ will not accept a proposed installation
without water protection for the facility?

The background and training of some AHJs will make applying water or other
suppression agents a priority to a propane facility. As the facility operator, you
should be knowledgeable on the important aspects of product control and training, as
reflected in the requirements of NFPA 58. Make an effort to contact the AHJ and
utilize the information in the FSA manual to educate the AHJ on the overall
importance of product control and the realistic product release scenarios that are
portrayed in the manual. Contact NPGA if additional assistance is needed.

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29. What is the difference between a Fire Safety Analysis and an Incident
Prevention Review?

The previously adopted 2004 edition of NFPA 58 referred to the safety analysis
procedure an “Incident Prevention Review”. In the 2008 edition of NFPA 58 the LP-
Gas code returned to the terminology that appeared in the 2001 edition of NFPA 58
which is “Fire Safety Analysis” (FSA); the essential elements of the process, however,
have not changed. The 2011 edition of NFPA 58 that is effective in Illinois on August
1, 2012 continues to use the term “Fire Safety Analysis”.