As of September 1, 2022, the Railroad Commission (RRC) requires a Fire Safety Analysis (FSA) for new and existing installations with an aggregate water capacity of 10,000 gallons or above.
This is something RRC LPG inspectors are currently looking for.
NFPA 58 Section 6.29.3.5 outlines that the fire safety analysis is an evaluation of the total product control system, such as the emergency shutoff and internal valves equipped for remote closure and automatic shutoff using thermal (fire) actuation, pull-away protection where installed, as well as other the optional requirements that can be found in Section 6.30 of NFPA 58.
Propane companies can create their own fire safety analysis that meets the above NFPA 58 requirements, or the RRC has developed and released an optional FSA template that propane retailers can complete to comply with the new requirement. The template was created at the request of the Texas Propane Gas Association.
Page 6 of the FSA requests an Emergency Response Plan. TPGA has created a sample one, in case you do not have one that you can insert into the FSA.
The fire safety analysis shall be submitted by the owner, operator, or their designee to the authority having jurisdiction, upon request, and to local emergency responders.