Form L Depot Construction Requirements
in Pakistan

A Form L licence is granted only when your depot or tank farm is built exactly to the drawings approved by NEPSA (formerly the Department of Explosives). This guide explains the Form L depot construction requirements in Pakistan: site layout, tanks, bund walls, fire fighting and electrical safety, with the official rule behind each one.

Depot Basics

Why Construction Decides Your Form L Licence

A Form L licence covers bulk storage of petroleum products and petroleum-based chemicals in fixed tanks, above ground or underground. Under the Petroleum Rules 1937, such premises are an “installation”: a place specially prepared for storing petroleum in bulk. The licensing authority is the National Explosives and Petroleum Safety Agency (NEPSA), the new name of the Department of Explosives under the Ministry of Energy (Petroleum Division).

NEPSA approves your drawings first. You build to them, every tank is tested and an officer inspects the finished site. If anything differs from the approved plan, the licence waits until it is corrected. For oil marketing companies and commercial depots, OGRA also applies its Technical Standards for Depots for the Storage of Petroleum Products (S.R.O. 624(I)/2009), which follow the American NFPA 30 code. The figures in this guide come from these sources.

The rules get stricter as the product gets more flammable. Petroleum is grouped by flash point: Class A (below 23°C, such as petrol), Class B (23°C to 65°C, such as diesel and kerosene) and Class C (65°C to 93°C, such as furnace oil). A petrol depot therefore needs more distance and more fire protection than a furnace oil tank. If you store in drums rather than tanks, see our Form M godown construction requirements instead.

Site and Layout Requirements

Before You Build

Industrial or approved site with heavy-vehicle access, away from housing
Concrete or brick boundary wall at least 7 ft high with 3 ft of barbed wire on top
Ring road around the site, at least 10 ft wide, with branch roads
Tanker loading point at least 25 ft from tanks, buildings and the boundary for petrol
15 ft for diesel, kerosene and furnace oil loading points
Staff and visitor parking at least 50 ft from product handling areas
No high-tension power line passing over any tank

Tank Construction Requirements

Built to API and NFPA 30

Steel or approved fibre-reinforced tanks built to API standards and NFPA 30
Firm, non-combustible foundation under every tank
Corrosion protection by coating or cathodic protection
Capacity in litres painted clearly on each tank
Water pressure test before use, with a signed test certificate
Vents with breather valves and flame arrestors
Underground petrol tanks at least 3 ft from the property line

Bund (Dyke) Wall Requirements

Spill Containment

Holds the full contents of the largest tank inside it
Volume of other tanks below bund height deducted from capacity
Average inside height limited to 6 ft (1.8 m) unless safe access is provided
Intermediate walls at least 18 inches high between tank groups
A separate subdivision for each group of tanks up to 15,000 barrels
Floor sloped so rainwater does not collect inside
Drain valve outside the bund, kept closed except when draining

Fire-Fighting Requirements

OGRA Depot Standards

Fire water for at least 2 hours where there is no other water source
Two fire pumps of similar capacity: one main and one standby
Fire main of at least 6 inches, hydrant connections of at least 4 inches
Hydrants every 50 to 100 m, with at least two for each bund
Foam system for fixed-roof tanks at 4.1 litres per minute per m²
Cooling for nearby tanks within one tank diameter or 30 m
Portable extinguishers chosen and placed as per NFPA 10

Form L Approval, Step by Step

Step 1: Choose an industrial site and check the access road and buildings around it
Step 2: For an oil marketing company, start the OGRA licence process
Step 3: Get the District Authority (Deputy Commissioner) NOC with an attested site plan
Step 4: Prepare engineered drawings of the layout, tanks, bunds and fire system

Step 5: Apply online on the NEPSA e-portal with the treasury challan and documents
Step 6: Build exactly to the approved drawings and test every tank
Step 7: Final site inspection by the NEPSA officer
Step 8: Licence issued in Form L, then renewed every year before the 1 December deadline

Electrical, Earthing and Drainage Requirements

Most depot fires start from a spark, so electrical work is checked closely at inspection. These are the Form L depot construction requirements that are easiest to get wrong:

Hazardous zones: areas around tanks, vents and loading points are classed as Zone 0, 1 or 2. Zone 0 needs intrinsically safe equipment and Zone 1 needs intrinsically safe or flameproof equipment.
Flameproof fittings: lights, switches and motors near tanks and pumps must be flameproof. Pumps with ordinary motors or engines go in a separate pump house.
Earthing: every tank needs at least two separate earth connections on opposite sides, tested at least once a year with records kept on site.
Bonding at loading points: tankers are bonded and earthed before loading or unloading to discharge static electricity.
Cables: wiring near tanks holding petrol must be armoured or in metal conduit, and no high-tension line may cross the installation.
Drainage: oily water from bunds and loading areas goes through an oil-water separator so that discharge meets the National Environmental Quality Standards (NEQS). Most depots also need an environmental approval from the provincial EPA.

Form L Licence Fees and Common Mistakes

The Form L licence fee is Rs. 30,000 per product up to 500,000 litres and Rs. 80,000 per product above that, as listed in our Petroleum Rules 1937 guide. The fee is charged for each product, so a depot storing three products, for example diesel, furnace oil and a solvent, pays Rs. 90,000 (3 × Rs. 30,000). A Form M godown, by contrast, pays one fixed Rs. 25,000 for all its products: see the difference between Form L and Form M. Construction, engineering drawings, tank testing and NOCs cost far more than the fee and depend on tank size and site. Use our DPL cost estimator for a first budget, and check the land requirements for a DPL licence before you buy or lease a plot.

The mistakes that delay most Form L files are:

Starting construction before NEPSA approves the drawings
Building the bund for one tank, then adding a second tank later
Placing the loading point too close to the boundary wall
Ordinary (non-flameproof) lights or motors near the tanks
Tank test certificates missing from the file
A District Authority NOC that has expired before the application is filed

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Common Questions

Form L Depot Construction Requirements: FAQs

Short answers to the questions depot owners ask us most often. For the full licence process, see our guide on how to get a DPL licence in Pakistan.

Can I get a Form L licence for an underground tank at my factory?

Yes. Form L covers both underground and above-ground tanks. An underground tank needs corrosion protection, leak-tight fill and vent pipes, and safe distances from the property line and any basement wall. The tank is pressure-tested before use and the test certificate goes with your application.

Do I need OGRA approval as well as the NEPSA licence?

It depends on what the depot is for. An oil marketing company or a commercial storage depot also needs OGRA licences under the Pakistan Oil (Refining, Blending, Transportation, Storage and Marketing) Rules 2016, and OGRA expects the storage to be built before it issues a marketing licence. A factory that stores fuel only for its own use normally needs just the Form L licence from NEPSA.

How big must the bund wall be?

The bund (dyke) must hold the full contents of the largest tank inside it, after deducting the space taken by the other tanks below the bund height. Under OGRA depot standards the average inside height is kept to about 6 ft (1.8 m), so a large tank needs a wider bund rather than a taller one.

Can I start construction before the licence is issued?

No. You may build only after NEPSA approves your drawings in writing. Work started before approval, or built differently from the approved plan, is one of the most common reasons a Form L file is held back.

How long does a Form L licence take?

Usually several months. The District Authority NOC, drawing approval, construction, tank testing and final inspection each take time, and construction is normally the longest stage. Files with complete drawings and documents move fastest.

Where is the NEPSA office that handles Form L?

NEPSA (formerly the Department of Explosives) has its head office at the Local Government Complex, G-5/2, Islamabad, and regional offices in Lahore, Karachi, Multan, Peshawar and Quetta. Applications are filed online on the NEPSA e-portal, and the regional office inspects the site.