EXHIBIT 5.1

                    LEGAL OPINION OF PEDERSEN & HOUPT, P.C.

                      (Pedersen & Houpt, P.C. Letterhead)

                                 June 17, 1999

Blue Rhino Corporation
104 Cambridge Plaza Drive
Winston-Salem, North Carolina 27104

Gentlemen:

     We have acted as counsel to Blue Rhino Corporation, a Delaware corporation
(the "Company"), in connection with the preparation of a Registration Statement
on Form S-8 (the "Registration Statement"), which has been filed by the Company
with the Securities and Exchange Commission for the purpose of registering under
the Securities Act of 1933, as amended (the "Securities Act") and the rules and
regulations thereunder the sale of up to 100,000 (the "Shares") of the Company's
Common Stock, $.001 par value per share ("Common Stock") upon the exercise of
options granted under the Company's Amended and Restated Stock Option Plan for
Non-employee Directors (the "Plan").

     Before rendering the opinions hereinafter set forth, we examined, among
other things:

     1.  Registration Statement;

     2.  The Plan;

     3.  The Company's Second Amended and Restated Certificate of Incorporation;

     4.  The Company's Amended and Restated Bylaws;

     5.  Resolutions of the Company's Board of Directors; and

originals or photostatic or certified copies of all those corporate records of
the Company and of all those agreements, communications and other instruments,
certificates of public officials, certificates of corporate officials and such
other documents as we have deemed relevant and necessary as a


June 17, 1999
Page 2

basis for the opinions hereinafter set forth. As to factual matters known to the
Company, we have relied without investigation, to the extent we deem such
reliance proper, upon certificates or representations made by the Company's duly
authorized representatives.

     We are members of the Bar of the State of Illinois, and we express no
opinion with respect to laws other than the laws of the State of Illinois, the
General Corporation Law of the State of Delaware and federal laws of the United
States of America.

     Based upon the foregoing, and subject to the qualifications and limitations
stated herein, we are of the opinion that when (i) the Registration Statement
becomes effective under the Securities Act and (ii) the options have been duly
exercised pursuant to the terms of the Plan, that the Shares will be validly
issued, fully paid and non-assessable.

     We hereby consent to the filing of this opinion letter as an exhibit to the
Registration Statement. In giving this consent, we do not hereby admit that we
are within the category of persons whose consent is required under Section 7 of
the Securities Act and the rules and regulations of the Securities and Exchange
Commission promulgated thereunder.


                                                /s/ Pedersen & Houpt, P.C.