As previously reported, the Railroad Commission (RRC) adopted the Fire Safety Analysis (FSA) requirements found in NFPA 58 with a compliance date of September 1, 2022. While NFPA requires fire safety analysis for installations of 4,000 gallons and over, the RRC will only require a fire safety analysis for new and existing installations with an aggregate water capacity of 10,000 gallons or more.
The Railroad Commission is still in the process of creating a Fire Safety Analysis to help propane retailers to comply. The RRC template is expected some next week. Until then, in case of inspection, TPGA is providing its members with an interim solution approved by the RRC.
If a propane marketer at least has the RRC Bulk Storage checklist completed and hands it to an inspector, it could serve as their interim FSA. It only hits some requirements but shows you made an effort until RRC releases its version.