Ehrhart Propane Gas — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Hazardous Materials Safety Pipeline and Administration Mr. Thomas G. Overbaugh OCT 12 2006 Reference No. 06-0185 P.O. Box 388 President, Ehrhart Propane Gas Trumansburg, NY 14886 Dear Mr. Overbaugh: This is in response to your July 31, 2006 letter and August 16, 2006 telephone conversation with a member of my staff asking if a RegO Products "Flomatic" fully automatic internal valve installed on your company's bobtail cargo tanks is considered closed in transportation under § 177.834(j) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state the cargo tanks are in propane delivery service and when the pump is operating separate actuator switch at another location on the cargo tank truck and to operate the internal valve this separate switch must be open. in accordance with § 177.834() of the HMR when the cargo tank pump is not in Based on the information you provided, the answer is yes the valve is considered closed operation and the slot in the visual indicator is in a horizontal position. I hope this information is helpful. Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 177.834(j) 060185#

Page 2_amonsor { 171.8346 loading Unloading hining EHRHART PROPANE GAS 7387-8881 PO Box 388 • Trumansburg NY 14886 July 31, 1984 US Dept. of Transportation 400 Seventh Street S.W. Pipeline Hazardous Materials Safety Administration Washington, D.C. Attention: Standards Development Office Of Hazardous Materials Standards RE: CFR177.834(J.2) Propane cargo tank Dear Sirs; I would like to have a formal interpretation on the use a REGO FloMatic internal valve. interpretation from you will put this issue to bed permanently. impossible to have this valve open while driving down the road I am inclosing a letter I received from the manufacturer of this valve explaining that it is Yours truly President#