Liquefied Petroleum Gas Tanks

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    Questings

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    Statutes

    430 ILCS 5/) Liquefied Petroleum Gas Regulation Act.

    430 ILCS 10/) Liquefied Petroleum Gas Container Act.

    Rules

    LP-Gas Storage and Handling

    41 Ill. Adm. Code 200 Rules for Liquefied Petroleum Gas (LPG) Storage Tanks

     


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

    LPG tanks are addressed separately from dispensing or bulk storage tanks holding flammable and combustible liquid storage tanks. LP-Gas tanks store liquid under pressure in the tank.  At normal pressures and temperatures, the product is a gas.  Title 41 Ill. Adm. Code 200 provides the regulations for the installation of LPG tanks. 

    If a LP-Gas tank is installed underground, or mounded in earth, what rules/applications apply? An LP-Gas tank, whether installed above or below ground, is considered an LP-Gas tank by OSFM. The OSFM retains jurisdiction for the inspection of these tanks and a regular LP-Gas tank installation application should be submitted. NFPA 58 contains 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 tanks found in 41 Ill. Adm. Code 170 do not apply.

    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.

    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 a tank that would bring the aggregate capacity of greater than 4,000 gallons on one site or property.
    • Installation of any capacity tank that will be used to dispense LP-Gas (such as refilling cylinders or fueling vehicles).

    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.

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

    The rules are found at 41 Ill. Adm. Code 200. The "Part 200" rules primarily reference NFPA 58 Liquefied Petroleum Gas Code for the installation and operation of liquefied petroleum gas tanks. Effective August 1, 2012 the section of Title 41 Ill. Adm. Code 200 has been modified to adopt the 2011 edition of NFPA 58. The rules have also been updated to reference the 2009 edition of NFPA 54, National Fuel Gas Code.  All new installations or modifications conducted in Illinois as of August 1, 2012 must comply with these updated editions of the adopted standards.

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

    Application and plan review letters are valid for a period of 12 months. This is stated within the review letter.

    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. 
    • 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).

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

    Yes. The OSFM has maintained a requirement within Part 200 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. Additionally, standards for fuel systems and equipment in recreational vehicles as published in NFPA 1192, Standard on Recreational Vehicles (2011 edition) is also a mandatory reference.

    Is collision protection required to be provided for my LP-Gas tank?

    Yes, if the installation is exposed to vehicular traffic. Vehicular traffic includes farming vehicles such as tractors and combines. 

    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.

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

    No. OSFM does not require LP-Gas tanks to be registered as OSFM does not maintain data base for LP-Gas tanks installed in Illinois. 

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

    No. The storage and handling of LP-Gas is covered in OSFM's adoption of  NFPA 59, Utility LP Gas Plant Code) (2008 edition) and are mandatory. NFPA 59 is referenced by Title 41 Ill. Adm. Code 200.

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

    No. LP-Gas piping installed within a building are covered in OSFM's adoption of NFPA 54, National Fuel Gas Code (2009 edition) 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 Title 41 Ill. Adm. Code 200.

    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 in Section 200.40 of Title 41 Ill. Adm. Code 200.

    Do I need to wait for an OSFM inspection to operate an LP-Gas tank?

    Yes. Section 200.80 of Title 41 Ill. Adm. Code 200 requires that any LP-Gas installation requiring approval by the OSFM shall not be placed in operation until final inspection and approval is given by the OSFM.

    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 Title 41 Ill. Adm. 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."

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

    No. Section 200.110 of Title 41 Ill. Adm. Code 200 specifically prohibits the self-service of LP-Gas. 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."

    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 Title 41 Ill. Adm. 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.

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

    NFPA 58 requires an FSA to be completed with aggregate storage of more than 4,000 gallons water capacity or if the LP-Gas installation is located on a roof. 

    What is the purpose of an 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.

    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.

    Does OSFM assist in the development of, or the review of an FSA? 

    No. OSFM will not assist in the development of an FSA. OSFM will not review an FSA. This document is something developed cooperatively between the LP-Gas owner and the local first responders. OSFM will make a statement in their plan review that an FSA is required and some very general information but does not offer any more information beyond what is found in the plan review letter.

    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.