Grayson Hill Farm — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 pecial Program Administratior JUN 26 2001 Ref. No. 01-0025 Mr. Chris Schimp 1705 Grayson Rd. Grayson Hill Farm El Dorado, IL 62930 Dear Mr. Schimp: This is in response to your letter and subsequent telephone are required to apply for an exemption to transport methane conversations with a member of my staff asking whether you gas as a Division 2.1 under the Hazardous Materials: pressure vessel is filled with activated carbon which Regulations (HMR; 49 CFR Parts 171-180). You state that a absorbs the methane. carbon has been determined not to meet the definition for You also state that the activated "Natural gas, compressed" UN1971. Division 4.2 and that the material will be described as Under the Hazardous 185), an exemption is not required to transport methane gas Materials Regulations (HMR; Parts 100- material when prepared and packaged in conformance with the containing activated carbon as a Division 2.1 hazardous Section 173.22 states that it is the shipper's responsibility to properly classify a hazardous material. It is not the function of this Office to confirm findings. However, based on the information provided in your letter, it is the opinion of this Office that methane gas absorbed in activated carbon under described as Division 2.1. pressure is appropriately A hazardous material described as "Natural gas, compressed," must be packaged in DOT specification cylinders in full conformance accordance with § 173.302. Cargo tank motor 010025 113-#

Page 2under the terms of an exemption. You may submit an vehicles and other packagings are not authorized except application for an exemption in accordance with the procedures prescribed in § 107.105. you need further assistance. I hope this information is helpful. Please contact us 1f Sincerely, Natte z. matthell. Hattie I. Mitchell, Chief) Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3HYDROPONIC PRODUCE AQUACULTURE Me Intyre Grayson HillFAM METHANE UXTAZATION MONDAY, JANUARY 22, 2001 $ 173:33 Exempteon TO: Director of O.H.M.S. U.S. D.O.I. (Edward Mazzullo) Applieability FROM: Chris Schimp (owner of Grayson Hill Farms) 01-0025 RE: Respectfully request a letter verifing that a Federal exemption is not needed to transport methane gas under 2.1 Division with activated carbon that has been determined not be classified in Division 42. Grayson Hill Farms produces electrical power from coal mine methane gas which is sold on the power grid to local utilities and captures the waste heat from the generators to grow Hydroponic produce along with fish in speciality designed greenhouses. Chris Schimp a Mining Engineer has a lot of experience with methane gas and through this experience has a Patent on a system that can transport methane gas very economically by truck. The State of Illinois has awarded Grayson Hill Farms with a Grant to put this system in operation. Grayson Hill Farms contracted the scientist from University of Illinois for the carbon selection for the transportation system. The carbon selected is from Waterlink/Barnebey Sutcliffe Corporation and has been determined not to be liable to spontaneous combustion according to IATA Dangerous Goods Regulations and according to the 49 CFR Ch.I, + DOT Research and Special Programs Administration. Please find the enclosed test results. The transportation system will involve a propane tanker filled with the carbon which will absorb the methane thus increasing the volume of methane that can he transported in the tanker. The pressure will not exceed the rated pressure of the vessel which is 250 psi and meet the necessary safety regulation. The carbon will stay in the tank and will last as long as the system is in operation. The methane will desabsorb from the carbon when the pressure is released from the tanker during unloading. A letter verifing that a Federal exemption is not needed is part of the Grant project in putting the transportation system together. 2/6/01 Thank You Chirschip Thinks JOAN#