{"operation":"document","citation":"14-0133","title":"Virginia State Trooper — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-11-03","effective_on":null,"summary":"14-0133 response to Virginia State Trooper concerning 173.150.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0133.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0133.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0133","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140133.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nNOV 0 4 2014\nMr. Kevin J. Teter\nMaster Trooper, Virginia State Police\n15139 State Police Rd.\nCulpeper, VA 22701\nRef. No.: 14-0133\nDear Mr. Teter:\nThis is in response to your letter dated June 14, 2014, and attached magazine article,\nrequesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n180) regarding multi-compartment fuel tanks and their ability to utilize exceptions provided in\n§ 173.150(f)(2). You present a scenario in which a trailer has been equipped with a\npermanently mounted diesel fuel tank that contains various individual compartments each\nhaving a 105 gallon capacity. The total amount of fuel contained within the tank varies\nbetween 315 gallons and 945 gallons depending on the number of compartments. You note\nthat each of the individual compartments within the tank are not connected to each other in\nany way. You ask if the tank represents a non-bulk package that would be eligible for\nexceptions mentioned in § 173.150(f)(2).\nThe compartments mentioned in your letter would be considered non-bulk packages, and be\neligible for the exceptions provided for such packages in § 173.150(f)(2) because they are not\nconnected to each other. Each individual compartment is considered a package.\nI trust this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nShoe chly\nShane C. Kelley\nActing International Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nWebb\n173.150 (F)\nDOT/RSPA/ OHMS\nCombustäble Liquids\nINIT\nMr. Magdy El-Sibaie, PhD\n14-0133\n14 JUN 27 PM 3: 30\nAssociate Administrator for Hazardous Material Safety\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\nEast Building Second Floor (PH)\n1200 New Jersey Avenue, S.E...\nWashington, D.C. 20590-0001\nDear Mr. El-Sibaie:\nI read an article In the March 2014 issue of Southern Loggin Times\" about a diesel fuel transport trailer that has a permanently\nmounted tank. There are nine total compartments in this one tank. Each compartment has a capacity of 105 gal. each and can\ntotal anywhere from 315 gals total to 945 gallons depending on the number of compartments. The compartments are not\nconnected to each other. (See attached Article and Photo) The manufacture states that the tank is in compliance with 49-CFR\n173.150(f) in that the tanks are not connected therefore it is a non-bulk package. (see attached)\nDoes this tank represent a non-bulk package that would being granted certain exemptions under 49 CFR 173.150(f)(2)?\nLooking forward to your response.\nSincerely\nKevin f. Jeter\nKevin J. Teter, Master Trooper\nVirginia State Police\n15139 State Police Road\nCulpeper VA 22701\n\n<<<PAGE 3>>>\n\nSOUTHERN STUMPIN'\nBy David Abbott • Associate Editor • Ph. 334-834-1170 • Fax: 334-834-4525 • E-mail: david@hattonbrown.com\nLogger Innovation\n'm a big movie guy. I enjoy watching movies, I\nnot legal to transport more than 119 gallons of\nseparate, unconnected containers. Obviously, this\nfuel without a hazmat permit, unless the fuel is in\nlegal and will keep the DPS off our backs,\"\nDOT-approved trailers with lights, he said it's\ncould i'd love to make movies (you know, if I\nkeep up with movie industry news, and if I\nhad any discernable talent). Every year Hollywood\nagricultural fields. Tired of getting pulled over\nis a strain on those working in the forestry and\nardous material permit so long as it's not over\nSheppard says. \"We won't have to have a haz-\ning in hundreds of millions of dollars, and some-\nturns out blockbusters that make a big splash, rak-\ncost so much to make that many of them barely\ntimes in the billions, worldwide. Still, those movies\ninspired. As a solution, he has developed his own\nand threatened with fines, Sheppard became\n1,000 gallons. That's a federal law, not jut Geor-\npending number and informed the DPS that he\ngia.\" In October last year Sheppard got the patent\nmovies with smaller budgets, even though they\nbreak even. They say that sometimes, the smaller\nsystem just for his own use but soon realized it\nfuel transport system. He started building the\nwanted to know\"\ncould start selling. \"They said that's what they\ngross a lot less, actually profit a lot more. It can\ncould be useful to others.\nsometimes be the same way with loggers.\nYear (and a feature article subject in Southern\nSheppard, a former Georgia Logger of the\ninstrumental in getting this off the ground. The\nSheppard says the DPS was very helpful and\nMargins (page 28) and As We See It (page 32),\nIn this month's installments of both At The\nand received patent pending (evidently it takes a\nLoggin' Times in March 2011), has applied for\nDPS spent hours one Friday measuring it and\ner, said it was legal and to build them. His con-\nwhen finished, one of the sergeants, Mike Hatch-\nthere are mentions of the oft-cited need for log-\ngers to maximize efficiency. In a lot of ways, the\nfew years to get final approval for the full patent\ncompanies featured in this issue have found cre-\nnumber). He has partnered with Albany-based\ntacts at the DPS put him in touch with Lewis M\npotential and strengthening their businesses by\native ways to do just that, improving profit\nufacture and market the innovation. They've\nLMC-AG (Lewis M. Carter Agriculture) to man-\nthe manufacture it.\nCarter, who was interested and soon agreed to\ndoing little things a little differently. These are\nsented the diesel hauling trailer at farm shows in\nalready sold two units, both to farmers, and pre-\npeople who think outside the box.\nbegins on page 14, has developed a special flip-\nSouth Carolina's Dennis Wall, whose story\navailable to the logging community. The first\nthe South in February. They're also making it\n173.150 (F), which allows users to haul fuel over\nThe tanks are in compliance with 49-CFR\npayload within the legal weight range. The Red-\nbolster on lightweight trailers to let him haul more\nging of Jeffersonville, Ga.\nlogger to buy one was Charles Hill of Hill Log-\nand hazmat endorsement. So class C drivers\n119 gallons combined total without having CDL\nrequired to legally haul this tank. Sheppard and\nlicense and medical card are the only things\nfern family of Tennessce (page 20) keeps debt and\noverhead down. Georgia's Diamond G Forest\nself before taking his plans to the Georgia Dept.\nSheppard built three prototype versions him-\ntanks: a 315 (three tanks), 630 (six tanks) and\nthe manufacturer, LMC-AG, offer three sizes of\nturpentine industry and saw opportunity.\nProducts (page 26) looked at a dormant domestic\nof Public Safety and Dept. of Transportation.\n945-gallon (nine tanks). The design allows for up\nAssn., Ken Sheppard of Vidalia, Ga. is another\nDirector of the Southeastern Wood Producers\nAccording to Tommy Carroll, Executive\nseal of approval.\nThey inspected the prototypes and gave it their\nto nine separate tanks with capacity of up to 105\ngallons each to connect to a single pump. A\nsupport for the project, calling repeatedly to see\nMembers of the DPS were enthusiastic in their\none is emptied. They offer it as a tank ready to\nquick coupler connects to each one as the last\nger who looked at a problem and found a way\nexample of just such an out-of-the-box type log-\nwhen it would be ready. \"As long as it is on\nmount on trailer or as a whole unit with a trailer.\naround it. As I'm sure many of you know, it is\nfill a need in the logging and agricultural mar-\nFor its part, LMC-AG says it is \"trying to ful-\nket.\" They offer the tanks either as individual\nunits or on running gears to allow towing. They\noffer 20-25 gallon per minute pumps along with\nthe units.\nchannel (8 in. on the 630 and 945 gallon units, and\nThe running gears are made from mild steel\nIMO\n6 in. on the 315). They use heavy-duty Torflex\naxles with eight lug hubs. Each trailer comes with\none axle with brakes and emergency brake box.\ncan order your trailer with any one of a variety of\nTrailer lights come with a seven-way plug. You\nball hitch. The trailers come with highway rated,\nhitches, such as drop pin, pintle eye, and a 2-% in.\nrange E, and include tread plate fender wells over\nDOT-approved tires, size ST235/80R16 load\ntrailer for whatever you need (spare chain, etc.).\nthe tires. A basket is included on the front of each\nDEF (diesel exhaust fluid) tanks are available;\nDEF tanks, according to LMC-AG, will likely be\nstricter emissions standards.\nrequired for all diesel tanks in the next year due to\n912-245-9180 or email kshepp@att.net or call\nTo find out more, contact Ken Sheppard at\nLogger Ken Sheppard, inset, relies on LMC-AG to make and market his fuel system.\nthe LMC-AG office at 229-639-1775.\nSLT\n6 • MARCH 2014 • Southern Loggin' Times\n\n<<<PAGE 4>>>\n\nLMC Ag\nLMG\nPrevious • Next\nDiesel Fuel Trailer\nBack to Album • LMC Ag's Photos • LMC Ag's Page\nLMC\nTrailer, 9 Chambers @ 105 Gallon Each (950 Gallons Total) :\nDiesel Fuel Trailer, 9 Chambers @ 105 Gallon Each (950 Gallons Total) -- at Diesel Fuel","truncated":false,"body_characters":9094}