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Interpretation Response #99-0155 ([Perkins Propane Gas, Inc] [Mr. John R. Perkins])

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

Interpretation Response Details

Response Publish Date:

Company Name: Perkins Propane Gas, Inc

Individual Name: Mr. John R. Perkins

Location State: MA Country: US

View the Interpretation Document

Response text:

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 (j) 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.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
177.834 General requirements