Perkins Propane Gas, Inc — Hazardous Materials Safety Interpretation

Page 1US.Deportment of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administration Special Programs JUL 12 1999 Mr. John R. Perkins Ref. No: 99-0155 Perkins Propane Gas, Inc. Route 11 North Shapleigh, Maine 04060 Dear Mr. Perkins: This is in response to your letter of June 21, 1999, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to cargo tanks used to transport propane. Specifically you ask whether the main internal valve located in the liquid outage port of a cargo tank and the delivery hose end valve must both be in the closed position during transportation. In addition, you would like confirmation that the closure of any additional valves, such as isolation valves, is not required. As provided by § 177.834() all valves and other closures in liquid discharge systems must be closed and free of leaks. This means each discharge valve in a liquid discharge system must be closed during transportation. This requirement does not pertain to any intermediate isolation valves that may be present in a liquid discharge system. Therefore, in your scenario the main internal valve and the delivery hose end valve must be closed. However you are not required to close any other valves in the system. I hope this information is helpful. Sincerely, Oh Millip Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 177.834 990155#

Page 2PERKINS PROPANE GAS, INC. Lavalle ROUTE 11 NORTH SHAPLEIGH, MAINE 04060 COMPLETE LP-GAS SERVICE (207) 793-2269 8177.834 Jure 21,1999 Mr. Edward Mazzullo, Director, 99-0155 Office of Hazardous Material Standards Dear Mr. Mazzullo, I am writing to request an interpretation As it relates to propane delivery trucks, conmonly referred of section 177.834 j as It appears in the 49CFk regulations• to as Bobtalls. delivery hose end valve both in the closed position would located in the liquid outage port of the cargo tank and the conform to the regulation. The closure of any additional valves located in the liquid discharge system to allow for equipment isolation, such as the meter and delivery hose, is not required. Thank you for taking the time to clarify this regulation. I look forward to your response. Sincoredy, John R. Perkins#