Interpretation Response #06-0185 ([Ehrhart Propane Gas] [Mr. Thomas G. Overbaugh])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/12/2006

Company Name: Ehrhart Propane Gas

Individual Name: Mr. Thomas G. Overbaugh

Location State: NY Country: US

View the Interpretation Document

Response text:

Oct 12, 2006

Mr. Thomas G. Overbaugh                 Reference No. 06-0185
President, Ehrhart Propane Gas
P.O. Box 388
Trumansburg, NY 14886

Dear Mr. Overbaugh:

This is in response to your July 31, 2006 letter and August 16, 2006 telephone conversation with a member of my staff asking if a RegO Products “Flomatic” fully automatic internal valve installed on your company’s bobtail cargo tanks is considered closed in transportation under § 177.834(j) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You state the cargo tanks are in propane delivery service and when the pump is operating it applies pressure to a piston that opens the internal valve, that this valve closes when the pump is turned off, and the visual indicator that shows when the valve is open or closed is located on its top flange. You also state this internal valve eliminates the need to close a separate actuator switch at another location on the cargo tank truck and to operate the internal valve this separate switch must be open.

Based on the information you provided, the answer is yes the valve is considered closed in accordance with § 177.834(j) of the HMR when the cargo tank pump is not in operation and the slot in the visual indicator is in a horizontal position.

I hope this information is helpful.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

177.834(j)

Regulation Sections