NFPA 58 vs. NFPA 59 for my process RAGAGEP

This week, I am doing my intermediate 3-day process safety training course for a new client whose process HHC/EHS is Liquefied Petroleum Gas (LPG); however, this process is VERY different than the other clients I have whose HHC/EHS is LPG.  My clients are END-USERS of LPG; this facility is NOT the user of the LPG; they merely process it and store it for distribution to the END-USER.  They have always used NFPA 58 as their baseline RAGAGEP; however, NFPA 58 is intended more for an END-USER type of process, whereas NFPA 59 is designed for a “Utility Gas Plant,” which is defined as:

(emphasis by me)

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