Keehn Service Corporation — Hazardous Materials Safety Interpretation

Page 1Transportatio S. Departmen 400 Seventh Street, S.W. Washington, D.C. 20590 MAY 1 0 2000 Mr. Richard C. Willard Ref. No. 00-0123 President Keehn Service Corporation 99 North 11'h Avenue Coatesville, Pennsylvania 19320 Dear Mr. Willard: This responds to your letter, dated April 18, 2000, concerning certain record keeping requirements applicable to cargo tanks used to transport liquefied compressed gases under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the information that will be required to document hose testing conducted by a Registered Inspector in accordance with § 180.407(h)(4) of the HMR. As currently written, the language related to record keeping in § 180.407(h)(4) is unclear, particularly the reference to the date of the "original hose assembly test." The inclusion of the term "original" in this paragraph was inadvertent. To comply with the record keeping requirements in this paragraph, a Registered Inspector must note the hose identification number of the hose being tested, the date of the test, and the condition of the hose assembly and piping system tested. We will delete the inadvertent reference to an "original" hose assembly test in a future rulemaking. Section 180.416(b) of the HMR requires operators to assure that each cargo tank delivery hose assembly is permanently marked with a unique identification number and maximum working pressure. This marking must be applied by July 1, 2000. In addition, after July 1, 1999, new and repaired hose assemblies must be marked with the month and year that they were pressure tested in accordance with §§ 178.337-9(b)(7) and 180.416(f). Hose assemblies manufactured or repaired prior to July 1, 1999, will not have this test marking. You are correct that, after July 1, 2000, operators must maintain written records documenting pressure tests for new and repaired hose assemblies. The record must include the date of the test, the signature of the inspector, the name of the hose owner, the hose identification number, the date of the original 180.407 000123#

Page 2delivery hose assembly and test, notes of any defects observed and repairs made, and an indication that the delivery hose assembly passed or failed the tests or inspections. For hose assemblies manufactured or repaired prior to July 1, 1999, there will be no date for an original hose assembly test because none was required before this date. For hose assemblies manufactured after July 1, 1999, the date the hose assembly was manufactured and pressure tested will be marked on the hose and must be entered on the written record documenting any subsequent pressure test. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Thorn I. Allan Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3KEENN Gorsku SERVICE CORPORATION $ 18-0023 99 NORTH 11th AVENUE • COATESVILLE, PA 1932( PHONE: (610) 384-6851 FAX: (610) 380-0316 April 18, 2000 Mr. Edward T. Mazzullo, Director United States Department of Transportation Office of Hazardous Materials Standards Research and Special Programs Administration gram Amition Washington, DC 400 Seventh Street, Southwest 20590 RE: Request for Clarification-Hose Testing and Inspection Dear Mr. Mazzullo, MC-330 and 331 compressed gas equipment. We hold valid "U" and "R" certification stamps and Keehn Service Corporation is currently involved with the fabrication, testing, and repair of are registered with the Department under CT number 0140. In preparation for the new hose inspection deadline of July 1, 2000, we are making modifications to our external visual ("V*) and leakage test ("K") forms. Under the leakage test requirements as shown in 180.407 (h) (4), we foresee the potential problem of receiving serial number marked on the delivery hose or hoses. This will be especially true for the propane customers equipment brought into our shop for this inspection without the original test date and bobtail trucks with hoses mounted on hose reels on the back deck of the truck. Under the current regulations as shown in 180.407 (h)(4), if these markings are missing, the hose does not comply $180.407(h)(4) After July 1, 2000, Registered Inspectors of specification MC- • 330 and MC331 cargo tanks, and nonspecification cargo tanks authorized under §173.315 (k) of this subchapter must visually inspect the delivery hose assembly rejection criteria listed in §180.416 (g). Delivery hose assemblies not and piping system while the assembly is under leakage test pressure utilizing the permanently attached to the cargo tank motor vehicle may be inspected separately from the cargo tank motor vehicle. In addition to a written record of the conducting the hose test must note the hose identification number, the inspection prepared in accordance with §180.417 (b), the Registered Inspector assembly and piping system tested. date of the original hose aşsembly test, and the condition of the hose There does not appear to be any relief from the regulation requiring certain original hose as shown in 180.416 (f), which allows for the retesting of a repaired hose, the date of the original manufacturer markings. Even under the new and repaired section for delivery hose assemblies hose assembly and test is required.#

Page 4§180.416(f)(3) After July 1, 2000, the operator must complete a recora inspector, the hose owner, the hose identification number, the date of documenting the test and inspection, including the date, the signature of the repairs made, and an indication that the delivery hose assembly passed or failed original delivery hose assembly and test, notes of any defects observed and the tests and inspections. markings, and the operator or owner cannot provide this information to us from his or her files, What we are proposing is that in the event we find a hose that does not have the required that we be capable of recertifying the existing hose assembly (if we so choose) by performing the following operations: 1. Perform a visual inspection of the full length of the outside of the hose assembly and 2. With visual inspection approval, pressure test the hose to 120 percent of hose reject any assemblies per the rejection criteria as contained in §180.416(g). Permanently mark the tested assembly with the date of this test, the test pressure maximum working pressure (generally extruded into the covering of the hose itself) and a new unique identification number for this assembly. A report of this retestin is installed with a copy to be retained on file by us as the hose testing company. sample attached) would be provided to the owner or lessor of the vehicle on which i issemblies. These assemblies are expensive (a new 1" diameter by 150 foot long propan: This proceedure would allow for the continued use of otherwise good and safe hose elivery hose sells for $455.00) and if inspected and tested properly could provide additiona years of safe delivery for our customers. reached by telephone at the number shown above or by email at rcwillard@aol.comfor Please advise at your earliest convenience if you find our suggestion plausible. 1 can be comments or questions. Thank you for your help in this matter. Sincerely, Dill Richard C. Willard President Attachment Msword DOT-letter-request for ruling-4-00.doc •#

Page 5Keehn Service Corporation Hose Test Report Customer: Customer Location (District ) : Truck unit number: Make of hose : Original Hose Information Diameter of hose : Length of hose: Previous test I.D. or Keehn S.O. number : Original hose test date: Original hose test pressure : New Keehn Identification Number : New Test Information New Test Date : Month: Day: Year: Test Pressure : (120% of maximum work pressure- 350 Rated hose=420 Lbs.test) Inspection Criteria PASS FAIL 1- Condition Of Hose Assembly: 2- Damage to hose cover that exposes the reinforcement. 3- Wire braid reinforcement has been kinked or flattened so as to permanently deform the wire braid 4- Soft spots when not under pressure, bulging under pressure or loose outer covering. 5- Loose or missing bolts or fasteners on bolted hose coupling assemblies. Inspector Print: Inspector Signature :#