Safe Delivery System, L.L.C. (SDS — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Special Programs Research and Washington, D.C. 20590 Administration ._... 6 1998 Mr. Daniel R. Meyer 404 North Main Safe Delivery System, I.L.C. (SDS) Rei. No.: 98-0281 Quimoy, Iowa 51049 Dear Mr. Meyer: This responds to your letter of September 8, 1998, concerning cargo tank requirements under the Hazardous (HMR; 49 CFR Parts 171-180). You ask whether a system that Materials Regulations detects shear or separation within the vehicle pumping system and automatically shuts the satisfies the requirement in S internal self-closing stop valve 178.337-11 (a) (1) (i). The answer to your question is "yes." The specification requirements for emergency discharge control can be achieved by means of either an internal self-closing stop valve or an excess System" will automatically close the internal self-closing stop (see § 178.337-8 (a) (2)). Thus, if the "DRM Safety valve in the event of shear or separation of piping or hose, then 11 (a) (1) (i) • the system does conform to the performance standard in § 178.337- You should be aware that the provisions of the HMR applicable to emergency discharge control systems are currently under discussion by a negotiated rulemaking advisory committee that was chartered to develop recommendations standards for preventing and mitigating unintentional releases of for alternative safety hazardous materials during the unloading of cargo tank motor vehicles in liquefied compressed gas service. Enclosed for your information is a copy of the Federal Register notice that established the advisory committee and outlined the issues it is 178.337-11#

Page 2* .. to consider. Also enclosed is a Federal Register notice announcing the advisory committee's meeting schedule. I hope this information is helpful. questions, please do not hesitate to If you have further contact this office. Sincerely, A. Allan Thomas G. Allan senior Transportation Regulations Specialist Offict of Hazardous vaitriais Siandaras Enclosure#

Page 3Gorsky 5178.337-11 Safe Delivery System, L.L.C. (SDS) 404 North Main 98-0281 Quimby, Iowa 51049-0266 September 8, 1998 Mr. Ed Mazzullo 400 Seventh Street Southwest Office of Hazardous Materials Standards and Regulations Washington, D.C. 20590 Dear Mr. Mazzullo: used with MC 330, MC331 and 173.315(k) cargo tanks for compliance with the current Title 49 CFR 178.337-11 Safe Delivery Systems, (SDS, L.L.C) is an Iowa based company that is currently developing a system to be (a)(1)(i). and the hose or hoses for shear or separation and if detected, will close the internal self closing stop valves and shut The system, called the "DRM Safety System", is designed to continuously monitor both the piping system down the engine of the cargo tank operating vehicle. With this letter I am asking for interpretation to Title 49 CFR 178.337-11 (a)(1)(i). According to Title 49 CFR 178.337-11 (a)(1)(i), which reads as follows: "178.337-11 (a)(1)(i) (1) Each internal self-closing stop valve and excess flow valve must automatically close if any of its attachments are sheared off or if any attached hoses or piping are separated." Our question to you is: be found on the cargo tank motor vehicle in conjunction with an internal self closing valve. The regulations state "and excess flow valve must automatically close", although this type of valve will not stop valve is shut off by activating its actuator have we complied with If shear or separation is detected within the vehicle pumping system, and the internal valve or the self closing Title 49 CFR 178.337-11 (a)(1)(i)? this is an important issue for us. I can be reached at 1-515-964-4940 if you should need to contact me. Please reply as soon as possible as Thanking you in advance for your reply, I remain Sincerely Danil R Meyer Daniel R. Meyer 529 S.W. Goodwin Ankeny, Iowa 50021#