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)

Let’s break down the THREE (3) key elements of this definition to understand its scope fully:

A plant:

• that stores and vaporizes LP-Gas for distribution
• that supplies either LP-Gas or LP-Gas gas–air mixtures to a natural gas pipeline operator
• that operates a gas distribution system of 10 or more customers

When we look at the application of NFPA 58 we see the following language:

As we can see, NFPA 58 has four (4) criteria for its application to “processes”:  (NOTE: I left out “highway transportation of LPG” as it does not impact our process safety discussion)

1. when delivering LP-Gas for use as a fuel gas
2. when supplying LP-Gas for use in a manufacturing, plant oil extraction, or liquid fuel blending process
3. marine terminals
4. pipeline terminals, beginning downstream of the last pipeline valve or tank manifold inlet, that receive LP-Gas from pipelines under the jurisdiction of the U.S. Department of Transportation (DOT) whose primary purpose is the receipt of LP-Gas for delivery to transporters, distributors, or users

Number four muddies the waters a bit, but NFPA also has some exclusions that may help us in our selection of the proper RAGAGEP to apply to our process:

This code shall not apply to the following:

(1) Frozen ground containers and underground storage in caverns, including associated piping and appurtenances used for the storage of LP-Gas

(2) Natural gas processing plants, refineries, and petrochemical plants

(3) LP-Gas at utility gas plants (including refrigerated storage) (see NFPA 59)

(4)* Chemical plants where specific approval of construction and installation plans is obtained from the authority having jurisdiction

(5)* LP-Gas used with oxygen

(6)* The portions of LP-Gas systems covered by NFPA 54 where NFPA 54 is adopted, used, or enforced

(7) Transportation by air, rail, or water under the jurisdiction of the DOT

(8)* Marine fire protection

(9) Refrigeration cycle equipment and LP-Gas used as a refrigerant in a closed cycle

(10) The manufacturing requirements for recreational vehicle LP-Gas systems that are addressed by NFPA 1192

(11) Propane vehicle fuel dispensers located at multiple fuel refueling stations (see NFPA 30A)

The ultimate decision as to which RAGAGEP is best suited for the process ULTIMATELY ends with the business and its ability to justify its decision.  Both are excellent standards; I found it interesting that there are two (2) different standards for two different processes, meaning they should be applied properly.  How one goes about this decision-making is left to the decision-makers within each business.

Related Content that may be of value to SAFTENG members:

Processing Facilities and PHMSA Jurisdiction (w/OSHA)

Draft Midstream Processing Facilities FAQs (OSHA PSM Implications)