{"operation":"document","citation":"99-0155","title":"Perkins Propane Gas, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-07-12","effective_on":null,"summary":"99-0155 response to Perkins Propane Gas, Inc concerning 177.834.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0155.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0155.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0155","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990155.pdf","body":"<<<PAGE 1>>>\n\nUS.Deportment\nof Transportation\nWashington, D.C.\n400 Seventh Street, S.W.\n20590\nResearch and\nAdministration\nSpecial Programs\nJUL 12 1999\nMr. John R. Perkins\nRef. No: 99-0155\nPerkins Propane Gas, Inc.\nRoute 11\nNorth Shapleigh, Maine 04060\nDear Mr. Perkins:\nThis is in response to your letter of June 21, 1999, requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to cargo tanks used to\ntransport propane. Specifically you ask whether the main internal valve located in the liquid\noutage port of a cargo tank and the delivery hose end valve must both be in the closed position\nduring transportation. In addition, you would like confirmation that the closure of any additional\nvalves, such as isolation valves, is not required.\nAs provided by § 177.834() all valves and other closures in liquid discharge systems must be\nclosed and free of leaks. This means each discharge valve in a liquid discharge system must be\nclosed during transportation. This requirement does not pertain to any intermediate isolation\nvalves that may be present in a liquid discharge system. Therefore, in your scenario the main\ninternal valve and the delivery hose end valve must be closed. However you are not required to\nclose any other valves in the system.\nI hope this information is helpful.\nSincerely,\nOh Millip\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n177.834\n990155\n\n<<<PAGE 2>>>\n\nPERKINS PROPANE GAS, INC. Lavalle\nROUTE 11 NORTH SHAPLEIGH, MAINE 04060\nCOMPLETE LP-GAS SERVICE\n(207) 793-2269\n8177.834\nJure 21,1999\nMr. Edward Mazzullo, Director,\n99-0155\nOffice of Hazardous Material Standards\nDear Mr.\nMazzullo,\nI\nam writing to request an interpretation\nAs it relates to propane delivery trucks, conmonly referred\nof section 177.834 j as It appears in the 49CFk regulations•\nto as Bobtalls.\ndelivery hose end valve both in the closed position would\nlocated in the liquid outage port of the cargo tank and the\nconform to the regulation. The closure of any additional\nvalves located in the liquid discharge system to allow for\nequipment isolation, such as the meter and delivery hose,\nis not required.\nThank you for taking the time to clarify\nthis regulation. I look forward to your response.\nSincoredy,\nJohn R. Perkins","truncated":false,"body_characters":2313}