First, let me say this article was written for those who do NOT live in the world of process safety, but yet they do have hazardous materials on-site in some type of bulk system, albeit below the PSM/RMP thresholds. In this posting, I am going to use Propane/LPG as my HAZMAT as there are many facilities that have this chemical on-site, even above the PSM/RMP TQs, but are exempt as it is used SOLELY as a fuel. But just because OSHA/EPA provided this regulatory exemption from PSM/RMP, it does NOT mean we do not have some very basic safety requirements for storing/handling this “extremely flammable” CAT 1 gas. Recently a friend had an incident at his/her facility involving LPG/Propane and things got way out of control and people were placed in harm’s way in their attempt to fix a bad situation. SO let’s review what basic safety and emergency fundamentals should be in place when a business has LPG/Propane on site:
NOTE: I can not think of a state that does not have some type of regulatory structure around the storage and handling of Propane/LPG, and yet the vast majority of businesses, large and small, fail in a big way in how they store and handle this CATEGORY 1 Flammable Gas.
The simplest of requirements is… what do I do if I have a leak?
Let’s get the regulatory application out of the way…
If you have more than 300 pounds of LPG/Propane stored in a container, you have exceeded the MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A PHYSICAL HAZARD IN AN OUTDOOR CONTROL AREA. (IFC TABLE 5003.1.1(3))
When we exceed this TQ, the fire/hazmat codes will require additional safeguards, of which I will list. I have highlighted the key parts!
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5003.1.4 Quantities exceeding the maximum allowable quantity per control area. The storage and use of hazardous materials in quantities exceeding the maximum allowable quantity per control area indicated in Tables 5003.1.1(1) through 5003.1.1(4) shall be in accordance with this chapter. 5003.2 Systems, equipment, and processes. Systems, equipment, and processes utilized for storage, dispensing, use, or handling of hazardous materials shall be in accordance with Sections 5003.2.1 through 5003.2.9. 5003.2.1 Design and construction of containers, cylinders and tanks. Containers, cylinders, and tanks shall be designed and constructed in accordance with approved standards. Containers, cylinders, tanks, and other means used for containment of hazardous materials shall be of an approved type. Pressure vessels not meeting DOTn requirements for transportation shall comply with the ASME Boiler and Pressure Vessel Code. 5003.2.2 Piping, tubing, valves, and fittings. Piping, tubing, valves, and fittings conveying hazardous materials shall be designed and installed in accordance with ASME B31.1 or other approved standards, and shall be in accordance with Sections 5003.2.2.1 and 5003.2.2.2. 5003.2.2.1 Design and construction. Piping, tubing, valves, fittings, and related components used for hazardous materials shall be in accordance with the following: 1. Piping, tubing, valves, fittings, and related components shall be designed and fabricated from materials that are compatible with the material to be contained and shall be of adequate strength and durability to withstand the pressure, structural and seismic stress, and exposure to which they are subject. 2. Piping and tubing shall be identified in accordance with ASME A13.1 to indicate the material conveyed. 3. Manual valves or automatic remotely activated fail-safe emergency shutoff valves shall be installed on supply piping and tubing and provided with ready access at the following locations: 3.1. The point of use. 3.2. The tank, cylinder, or bulk source. 4. Manual emergency shutoff valves and controls for remotely activated emergency shutoff valves shall be clearly visible, provided with ready access, and identified in an approved manner. 5. Backflow prevention or check valves shall be provided where the backflow of hazardous materials could create a hazardous condition or cause the unauthorized discharge of hazardous materials. Exceptions: 1. Piping for inlet connections designed to prevent backflow. 2. Piping for pressure relief devices. |
So these basic fire code requirements require a business to have:
1) Emergency isolation valves at BOTH the “point of use” AND “tank/cylinder/bulk source”
2) These emergency isolation valves are required to be CLEARLY VISIBLE, READILY ACCESSIBLE, and IDENTIFIED as such
These are in place so that when the forklift hits the gas line and is spewing this flammable gas into the building, as everyone is evacuating, someone knows where to go and what valves to close to minimize the leaking gas into the building. If the business waits 10-15 minutes for the local FD to arrive, it will be AT LEAST another 15 minutes before the FD can locate and close these valves. We have just created a bomb with plenty of ignition sources!!!
And for anyone who thinks that using the “General Requirements” for all HAZMATS is the wrong section of the code to use, don’t worry – here are the requirements specifically for FLAMMABLE GASES AND FLAMMABLE CRYOGENIC FLUIDS. Here we can see because LPG/Propane is a flammable gas, we have the SAME requirements, but they apply to ALL systems – even those that do NOT exceed the MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A PHYSICAL HAZARD IN AN OUTDOOR CONTROL AREA. (IFC TABLE 5003.1.1(3))
As well, this section not only addresses a means to SAFELY STOP the leak from a distance location (depending on where the leak is located), it also addresses “ignition sources”…
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5803.1 Quantities not exceeding the maximum allowable quantity per control area. The storage and use of flammable gases in amounts not exceeding the maximum allowable quantity per control area indicated in Section 5003.1 shall be in accordance with Sections 5001, 5003, 5801, and 5803. 5803.1.1 Special limitations for indoor storage and use. Flammable gases shall not be stored or used in Group A, E, I or R occupancies or in offices in Group B occupancies. Exceptions: 1. Cylinders of nonliquefied compressed gases not exceeding a capacity of 250 cubic feet (7.08 m3) or liquefied gases not exceeding a capacity of 40 pounds 2. Food service operations in accordance with Section 6103.2.1.7. 3. Hydrogen gas systems located in a hydrogen fuel gas room constructed in accordance with Section 421 of the International Building Code. 5803.1.1.1 Medical gases. Medical gas system supply cylinders shall be located in medical gas storage rooms or gas cabinets as set forth in Section 5306. 5803.1.1.2 Aggregate quantity. The aggregate quantities of flammable gases used for maintenance purposes and operation of equipment shall not exceed the maximum allowable quantity per control area indicated in Table 5003.1.1(1). 5803.1.2 Storage containers. Cylinders and pressure vessels for flammable gases shall be designed, constructed, installed, tested and maintained in accordance with Chapter 53. 5803.1.3 Emergency shutoff. Compressed gas systems conveying flammable gases shall be provided with approved MANUAL OR AUTOMATIC EMERGENCY SHUTOFF VALVES THAT CAN BE ACTIVATED AT EACH POINT OF USE AND AT EACH SOURCE. 5803.1.3.1 Shutoff at source. A MANUAL OR AUTOMATIC FAIL-SAFE EMERGENCY SHUTOFF VALVE SHALL BE INSTALLED ON SUPPLY PIPING AT THE CYLINDER OR BULK SOURCE. Manual or automatic cylinder valves are allowed to be used as the required emergency shutoff valve where the source of supply is limited to unmanifolded cylinder sources. 5803.1.3.2 Shutoff at point of use. A MANUAL OR AUTOMATIC EMERGENCY SHUTOFF VALVE SHALL BE INSTALLED ON THE SUPPLY PIPING AT THE POINT OF USE OR AT A POINT WHERE THE EQUIPMENT USING THE GAS IS CONNECTED TO THE SUPPLY SYSTEM. 5803.1.4 Ignition source control. Ignition sources in areas containing flammable gases in storage or in use shall be controlled in accordance with Section 5003.7. Exception: Fuel gas systems connected to building service utilities in accordance with the International Fuel Gas Code. 5803.1.4.1 Static-producing equipment. Static-producing equipment located in flammable gas storage areas shall be grounded. 5803.1.4.2 Signs. “No Smoking” signs shall be posted at entrances to rooms and in areas containing flammable gases in accordance with Section 5003.7.1. |
And lastly, as evidence that BOTH sections apply to LPG/Propane, the IFC 2021 edition was kind enough to make it crystal clear:
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5803.2 Quantities exceeding the maximum allowable quantity per control area. The storage and use of flammable gases in amounts exceeding the maximum allowable quantity per control area indicated in Section 5003.1 shall be in accordance with Chapter 50 and this chapter. |