Linde Gas and Equipment — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration February 24, 2026 Mark Hammond Linde Gas and Equipment 3625 S. Main Street South Bend, IN 46614 Reference No. 25-0136 Dear Mr. Hammond: This letter is in response to your October 8, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to leakage testing on cargo tanks. You perform annual visual and leakage inspections on cargo tanks containing liquefied petroleum gas (LPG) in which you apply a leak-detecting fluid to find bubbles at fittings, valves, and welds. You ask about a test and inspection form that your company uses to record requalification activity. The form includes a section to record performance of a leakage test and two boxes to indicate a “hydrostatic” or “pneumatic” test. The report contains an additional section to indicate performance of a leakage test which includes fields to indicate the fluid used and pressure during a leakage test. Specifically, you ask whether you should leave both the hydrostatic or pneumatic boxes blank and instead fill out the second leakage test portion of the form with LPG listed as the test medium (i.e., the fluid used). The HMR neither requires use of a particular form nor specifies a format. Therefore, this Office cannot provide specific instructions regarding how to fill out the proprietary form you provided and described in your letter. You need only record and maintain a report of tests or inspections in accordance with § 180.417(b). However, it is the opinion of this Office that not selecting either “hydrostatic” or “pneumatic” when recording a leakage test is appropriate. Pneumatic and hydrostatic tests are “pressure tests” as specified in 49 CFR 180.407(g). The inspection method you described conforms to the “leakage test” outlined in 49 CFR § 180.407(h), therefore you should only record the completion of a leakage test. Furthermore, this Office suggests that the second portion of the form should also remain blank unless you are providing information related to 1200 New Jersey Avenue, SE Washington, DC 20590#

Page 2Environmental Protection Agency (EPA) Method 27 Vapor Tightness Test (K- EPA27). I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Casey, C. 25-0136 From: INFOCNTR (PHMSA) To: Baker, Yul (PHMSA) Cc: Hazmat Interps Subject: FW: Letter Of Interpretation Request Date: Wednesday, October 8, 2025 16:43:07 Attachments: JJ Keller Inspection Report.pdf Good afternoon, Please see the following request for a letter of interpretation. Please let us know if you need anything. Best, Aminah From: Mark A Hammond <Mark.A.Hammond@linde.com> Sent: Wednesday, October 8, 2025 5:58 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Letter Of Interpretation Request You don't often get email from mark.a.hammond@linde.com. Learn why this is important CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good morning. I have a concern regarding the use of the JJ Keller Tanker Test and Inspection Report (Please see attachment and highlighted areas). I conduct annual Visual and Leak tests only. In the area of the form “Type of Tests – Leakage Test (K)” the form gives a choice of Hydrostatic (water) and Pneumatic (air). While conducting an inspection on a Propane bobtail neither one of these seems appropriate for a flammable gas. Would the best approach be to leave the 2 choices, hydrostatic or pneumatic, blank and mark fluid used (which I always do) in the “Leakage Test” box (also highlighted under the K-EPA27 and Upper Coupler Assembly boxes)? I have attached email communication with Jessica Stiles DOT Hazardous Materials Program Manager on this same question from 9-9-25. Thank you. Mark Hammond Linde Gas and Equipment 574-210-5992 3625 S Main Street South Bend, Indiana 46614#

Page 4From: Stiles, Jessica (FMCSA) <jessica.stiles@dot.gov> Sent: Wednesday, September 17, 2025 9:35 AM To: Mark A Hammond <Mark.A.Hammond@linde.com> Cc: Rios, David (FMCSA) <david.rios@dot.gov> Subject: RE: JJ Keller Tank Inspection Form CYBERSECURITY ALERT: This is an email from an external organization. Use caution, especially with links and attachments. More Hi again Mark. After consultation with PHMSA, we all agree that for a leakage test/inspection report there is no need to list whether it was pneumatic or hydrostatic, since those two terms are not used in 49 CFR 180.407(h). However, those two terms are used in the pressure testing section of the regulation (49 CFR 180.407(g)) so you’ll need to be sure to include hydrostatic or pneumatic when a pressure test report is completed. Section 49 CFR 180.417(b)(2)(iii) also requires that the leakage test report include: identification of the fluid used for the test, test pressure, and holding time of test. So while you don’t need to list pneumatic or hydrostatic, you do still have to include these three items along with all the other information required by 180.417(b). You are correct that for the “fluid used” you can list LPG as the medium if that’s what was used for the test. Thank you, Jessica Stiles Hazardous Materials Program Manager Midwestern Service Center 360-846-3869 From: Mark A Hammond <Mark.A.Hammond@linde.com> Sent: Tuesday, September 16, 2025 4:30 AM To: Stiles, Jessica (FMCSA) <jessica.stiles@dot.gov> Cc: Rios, David (FMCSA) <david.rios@dot.gov> Subject: RE: JJ Keller Tank Inspection Form You don't often get email from mark.a.hammond@linde.com. Learn why this is important CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Thank you, Jessica.#

Page 5From: Stiles, Jessica (FMCSA) <jessica.stiles@dot.gov> Sent: Monday, September 15, 2025 11:12 AM To: Mark A Hammond <Mark.A.Hammond@linde.com> Cc: Rios, David (FMCSA) <david.rios@dot.gov> Subject: RE: JJ Keller Tank Inspection Form CYBERSECURITY ALERT: This is an email from an external organization. Use caution, especially with links and attachments. More Good morning Mark. My apologies – I’m not ignoring this email, but your question made me reevaluate how I’ve read this regulation for years. I’ve reached out to PHMSA to get their take on it and will let you know once I hear back. Thank you, Jessica Stiles Hazardous Materials Program Manager Midwestern Service Center 360-846-3869 From: Mark A Hammond <Mark.A.Hammond@linde.com> Sent: Tuesday, September 9, 2025 6:15 AM To: Stiles, Jessica (FMCSA) <jessica.stiles@dot.gov>; Rios, David (FMCSA) <david.rios@dot.gov> Subject: JJ Keller Tank Inspection Form Some people who received this message don't often get email from mark.a.hammond@linde.com. Learn why this is important CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good morning. I have a question regarding the Leakage Test (Under heading “Type of Tests”) on the form. There is Hydrostatic (water test?) and Pneumatic (air or inert gas?). When conducting an inspection on a propane bobtail neither description seems to be correct. Should I leave the 2 choices (Hydrostatic or Pneumatic) blank and fill out the other Leakage Test area circled about half way down the form on the right side with Liquid Propane noted as the test medium? Thank you. The information contained in this email and any attachments may be confidential and is provided solely for the use of the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution, or use of this e-mail,#

Page 6its attachments or any information contained therein is unauthorized and prohibited. If you have received this in error, please contact the sender immediately and delete this e- mail and any attachments. No responsibility is accepted for any virus or defect that might arise from opening this e-mail or attachments, whether or not it has been checked by anti-virus software. The information contained in this email and any attachments may be confidential and is provided solely for the use of the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution, or use of this e-mail, its attachments or any information contained therein is unauthorized and prohibited. If you have received this in error, please contact the sender immediately and delete this e- mail and any attachments. No responsibility is accepted for any virus or defect that might arise from opening this e-mail or attachments, whether or not it has been checked by anti-virus software. The information contained in this email and any attachments may be confidential and is provided solely for the use of the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution, or use of this e-mail, its attachments or any information contained therein is unauthorized and prohibited. If you have received this in error, please contact the sender immediately and delete this e- mail and any attachments. No responsibility is accepted for any virus or defect that might arise from opening this e-mail or attachments, whether or not it has been checked by anti-virus software.#

Page 7_ AVERAGE PRESSURE TEST REPORT NUMBER REPAIR DATE 8898 (Rev. 1/17) TELEPHONE END ASME CODE SYMBOL DATE MAXIMUM ALLOWABLE WORKING PRESSURE MEASUrE MANUFACTURER'S TANK SERIAL NO. K-EPA27 Gasoline Delivery Tank Pressure Test - EPA Reference Method 27 START VESSEL MATERIAL SPEC. NO. UPPER COUPLER ASSEMBLY WATER CAPACITY IN LBS. • REMOVED FOR EXAMINATION LEAKAGE TEST ASME OR NATIONAL BOARD NO. OF REPAIR FACILITY END • EXAMINED IN PLACE MARKINGS APPLIED: • YES • NO • delivery hose/piping • appurtenances • NO PSIG START | STRESS RELIEVED AFTER FABRICATION FLUID CAPACITY (GALS.) TANK • INSULATED FLUID USED PRESSURE HOLDING TIME PRES RES VENT DESIGN CERTIFYING ENGINEER REGISTRATION NO. • YES • DEFECTS OR DAMAGE DISCOVERED TANK IDENTIFICATION NO. INSPECTION TEST DATE • MATERIAL CORROSIVE TO TANK • DEDICATED SERVICE SIGNATURE OF OWNER PRINCIPAL PLACE OF BUSINESS ADDRESS SPECIAL SERVICE • OTHER MIN. TESTED LINED TYPE (• Full • Local) • NO CARRIER (if other than owner) CITY, STATE, ZIP CODE CARRIER'S EQUIPMENT NO. STRESS RELIEVED AFTER REPAIR TANK MANUFACTURER DOT SPECIFICATION NO. ORIGINAL TEST DATE DESIGN TEMPERATURE • YES REPAIRED BY ADDRESS CITY, STATE, ZIP MFG, ITEMS INSPECTED OR TESTED DATE ORIGINAL Pressure - set to discharge SHELL BOTTOM IS REPAIR CERTIFICATION REQUIRED? • YES • NO TELEPHONE • PRESSURE RETEST (P) Pressure - when open Pressure - when reseated THICKNESS (INCHES) CARGO TANK: • MEETS • FAILS TO MEET THE REQUIREMENTS OF THE DOT SPECIFICATIONS IDENTIFIED ON THIS REPORT • WITHDRAWN FROM SERVICE • RETURNED TO SERVICE MFG. DATE DESIGN TEMPERATURE • HYDROSTATIC • PNEUMATIC PRESSURE Device Number Tested Removed Inspected Replaced Reinstalled HEAD SHELL TOP SHELL SIDE RELIEF DEVICES Repaired TEST DATE DOT REGISTRATION NUMBER CARGO TANK MOTOR VEHICLE CERT. DATE MAX. DESIGN DENSITY OF LADING • NO DEFECT OR DAMAGE DISCOVERED (LBS. PER GAL.) • PNEUMATIC ITEM • suspension system connecting structures Pressure Bearing Portions attachments Lining Material of Heating System Flues for Heating System Corroded or Abraded Areas (• CERTIFIED AS 0.2% WATER BY WEIGHT) MATERIAL HEAD Frangible (Rupture) Disk Major Appurtenances upper coupler assembly TYPE OF TEST(S) • ANHYDROUS AMMONIA • LIQUEFIED PETROLEUM GAS TANKER TEST AND INSPECTION REPORT LINING MATERIALS • DELIVERY HOSE/PIPING Distortions DESIGN PRESSURE Dents Welds • LEAKAGE TEST (K) • HYDROSTATIC For compliance with 49 CFR 180.407(h)(4), 180.417(b) & (c), and 40 CFR 60.505(b) (PSIG) • K-EPA27 YES NO DATE OF ORIG. HOSE DELIVERY HOSE/PIPING ASSEMBLY TEST. LOCATION OF DEFECTS OR DAMAGE: • weld • heat-affected zone DOT REGISTRATION NUMBER OF THE TESTING FACILITY/PERSON Neenah, WI • JJKeller.com • (800) 327-6868 • Printed in the USA PRINCIPAL PLACE OF BUSINESS ADDRESS CARGO TANK MOTOR VEHICLE MFG. EXPOSED SURFACE AREA IN SQ. FT. ITEM Head-to-Shell Seam Tank Shell Tank Heads Manhole Covers Manhole Gaskets Devices for Tightening Gaskets on Full Opening Self-closing Stop-valves Excess Flow Valves Remote Closure Devices CITY, STATE, ZIP CODE OWNER'S TANK SERIAL NO. MAX. WEIGHT OF LADING ] EXTERNAL VISUAL (V) • INTERNAL VISUAL (1)| O LINING INSPECTION (L) Reclosing Pressure CONDITION OF HOSE ASSEMBLY DISPOSITION OF CARGO TANK: SIGNATURE OF INSPECTOR / TESTER Copyright 2017 J. J. Keller & Associates, Inc. • THICKNESS TEST (T) Valves Gaskets Manhole Rear Head Relief Valves Nuts and Bolts & PIPING SYSTEM NATURE AND SEVERITY: METHOD OF REPAIRS: TESTED BY (Person's Name) OWNER HEATING SYSTEM THIS UNIT HAS HAULED SHELL HOSE I.D. NO. _ ADDRESS CITY, STATE, ZIP#