In this Monday Morning Messenger, TPGA continues our U.S. DOT PHMSA onsite inspection series with part 3. Find out who else at your office PHMSA investigators interview and what additional questions they will ask propane retailers regarding ASME Tanks.

In our second story of the morning, the association puts a spotlight on a common NFPA requirement, an RRC exception, and also why a common element can't be used. You may well know you can't use it, but do you know why?

Lastly, the association commonly gets questions about competitors filling company-owned tanks. This time, it's not the law that we are highlighting but an item that we carry that may help you stake the claim to your tank.

Don't forget to explore our Quick Links section, which provides convenient access to essential resources. Uncover ways to provide seasonal updates to your customers, swiftly access the TPGA compliance store, tap into an exclusive continuing education opportunity, and inform your customers about the option to upgrade their propane appliances with rebates from the Propane Council of Texas.

In this issue

• In Brief
• PHMSA Inspection Series Continued
• Propane Pointers
• Claim Your Tank
• Quick Links

September 2023

National Preparedness Month

September 17-20, 2023

GPA Midstream Convention

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September 21-22, 2023

Fall NPGA Benchmarking Council Meeting

September 21-22, 2023

Fall NPGA Benchmarking Council Meeting

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September 27, 2023

Fall/Winter Propane Living Deadline

Affinity Partners

Lone Star Energy Group Workers Comp Insurance

&

Basys Credit Card Processing

&

NoCell Technologies

Recently, the Texas Propane Gas Association hosted inspectors from the Pipeline Hazardous Materials & Safety Administration (PHMSA) of the U.S. Department of Transportation (US DOT) for training for the propane industry, and they shared some excellent information that we are passing on to the entire membership through a series each week on DOT inspections. This is week 2.

PHMSA investigators will walk your yard looking at ASME tanks, and PHMSA will interview your service techs.

PHMSA will ask questions like:

- Does your company move tanks with more than 5%?

- Explain how the tanks are moved.

- Do you have a record of movement?

- Is the record complete?

- Show me your equipment

What should you know about moving ASME tanks with more than 5%?

- Tanks must be 500 gallons or less

- Keep a record of visual inspection for two years

- One tank per vehicle

- Lift by slings only – ASME B30.9

- Cradle - secured – no overhang

- Trailers – rear end protection 49 CFR § 393.86

- Consumer premises to the nearest facility

- Employees must be trained and qualified

What should be on the ASME tank Record of Inspection?

- Record of inspection by a qualified person

- Checking for leaks/corrosion/abrasions/dents/

distortions/weld defects/or anything unsafe

- Signed and dated by a qualified person

- Date of inspection

- Inspectors contact info

- Containers serial # / Container size 250/500

- % of propane from gauge

- Origin / Destination

Missed week 1 in this series? Access week 1's PHMSA inspection series by clicking here.

Next week, we will complete the end of our PHMSA inspection series. Stay tuned next Monday for our final article on the topic.

NFPA 58, §6.8.3.1 governs the standard for installations of horizontal ASME containers. Horizontal ASME containers designed for permanent installation in stationary aboveground service shall be placed on masonry or other noncombustible structural supports located on concrete or masonry foundations with the container supports. These vessels must be placed on a solid masonry foundation, and the use of hollow blocks concrete masonry units (CMUs, commonly referred to as "cinder blocks") is PROHIBITED. The key word being here is "hollow".

Many of you may know you can't use hollow cinder blocks, but do you know the reason why? The reason you cannot use hollow cinder blocks is hollow cinder blocks break easily, which can tip the tank and break the propane line. You need to put a concrete slab, or "solid" blocks work as well. You can even pour concrete in the hollow portions to make it solid to comply.

Also, the Railroad Commission of Texas adds in its exceptions to NFPA 58: Containers shall not be in contact with the soil. A properly installed container should not come into direct contact with the ground to allow for air circulation underneath it. It is common for animals to dig under the tank or for the ground to shift, causing the tank to settle onto the soil. If this happens, the container must be raised and reinstalled to ensure it does not touch the ground.

Air circulation beneath the container aids in the evaporation of moisture on the tank's surface and reduces the risk of corrosion damage. Containers in direct contact with the soil are susceptible to pitting and rusting due to moisture and soil chemicals. Furthermore, when incorrectly installed, the container's bottom remains exposed and should be inspected for corrosion damage before servicing. A tank extensively damaged by corrosion poses a severe safety hazard and must be removed from LP gas service.

Installing your tanks on pads and solid foundations also protects your investment!

Updated from its original version of Railroad Commission's Propane Pointers.

Yes, here in Texas, we have the law that other companies cannot fill company-owned propane tanks unless an emergency exists.

But how else can you protect your customer lease tanks?

You can stake the claim to your tank by stating it is your property or owned by your company.

TPGA's compliance store, Propane Service Corporation (PSC), sells "Property of" as well as "Owned & Serviced by" custom decals. Make sure all your lease tank installs have these decals. It's also a reminder to the customer that your company owns the tank, and they know who to call, especially when there is a change in ownership of the house or at rental properties, they know to call you.

"Property of" Decals

"Serviced by" Decals

Send seasonal propane information to your customers through the Fall/Winter Propane Living newsletter.

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