Allied Universal Corp. — Hazardous Materials Safety Interpretation

Page 1• i US. Deparment 400 Seventh St, S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration JUL 1 0 2003 Ms. Robin J. Eddy Bolte Ref. No. 02-0080 Safety and Regulatory Complaince Manager Allied Universal Corp. 3901 N. W. 115ª Avenue Miami, FL 33178 Dear Ms. Bolte: This is in response to your letter and subsequent telephone conversation with Sandra Webb of my staff requesting clarification of the requirements for marking the tare weight on a cylinder under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you state that your company is trying to determine the proper procedure for handling DOT Specification 3A and 3AA, cylinders that show distinct loss in weight, between five (5) and nine (9) percent of the original stamped tare weight. I regret the delay in responding to your letter and hope it has not caused you any inconvenience. The requirement previously contained in § 173.34(c) was recently moved to § 173.301(b) in a final rule published on August 8, 2002, under RSPA Docket HM-220D; 67 FR 51652. Your specific questions are paraphrased and answered below. QI: If the cylinder passes inspection and requalification, may our hydrostatic testers or third party hydrostatic testing service mark the new tare weight to the right of the original tare weight on the cylinder? Al: The answer is yes. Additional information may be marked on the cylinder provided it does not affect the required markings prescribed in § 178.35(1) and the applicable specification as specified in § 173.301(b). However, we recommend that you stamp one diagonal line through the obselete, orginal tare weights), if present, so that it is still legible for future reference. 02: Is it true that a cylinder with a five to nine percent tare weight lost passing inspection and hydrostatic testing may only be used for one year from the date of that testing, or may it be used until additional inspection and hydrostatic testing is warranted or it fails the ten percent tare weight lost rule? A2: With the exception of DOT Specification 3HT cylinders (see § 173.302a(a)(2) as specified under Docket HM-220D (67 FR 51626; 51646; August 8, 2002)) or cylinders manufactured under exemption, DOT cylinders do not have a specified service life. Therefore, if the cylinder#

Page 2conforms to the applicable requirements specified in Part 173 and Part 180 of the HMR, it may be used in the transportation of hazardous materials. I trust this satisfies your request. Please contact us again if we can be of further assistance. Sincerely, Siven troy Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3Webb {173.34 Cylinders ALLIED UNIVERSAL CORP., 3901 N.W. 118º Avonuo, Miami, Florida 33178 Fax 305-885-4671 305-888-2623 Mr. Edward Mazzullo Director for Hazardous Materials Standards 02-0080 400 Severith Streel, S.W., DHM-10 U.S. Department of Transportation Washington, D.G. 20590-0001 March 1, 2002 Subyect: Interpretation, Cylinder Requalification Dear Mr. Mazzullo: My company is trying to determine the proper procodure for handing DOT Specificalion 3A and 3AA fare weight. cylinders that show a distinct loss in weight, betwoon five end nine percent, from their original stamped $173.34(e), Pamphlet C-l states on page 6, section 3.2.1.1 (copy enclosed) that a cylinder with a tare RSPA refers to Compressed Gas Association (CGA) Pamphlet C-6 In their regulations found al 49 CFR weight lost of five percent or greater is required to be rejected for service, If the cylinder tare weight loss is ten percent or greater, Pamphlet C-b and 49 CFR 173.34(0) both state that the cylinder must be condemned and removed from service. If the loss is five percent of greater, but not more than ten testing. Our questions are regarding cylinders that pass these inspoctions and requalifications. percent, the CGA Pamphlet stales that the cylinder must be Inspectod and requalified by hydrostatic 1. If the cylinder passes inspection and requalification, may our hydrostatic testers of third party hydroststic lasting service mark the now taro weight to the right of the original tare fare weight is due to the following safety concems: weight on the cylinder? Our reason for requesting this ability to mark the cylinder with the new a) One, we do not want to overfill the cylinders; hence the reason for the new lase weight for our b) Two, though the cylinder passed requalification, if the cylinder continues to lose weight, we need cylinder fillers, and, 1o know the onginal fare weight 1o make sure it is rotested or condemned as indicaled in the 2. We were told that a cylinder with a tare weight loss of five percent, but not greater than nine percent, previous paragraph. that passes requalification has a use life of one year from the dato of requalification testing. One year from the date of the requalification testing the cylinder must be condemned, and removed from service. Is it true that a, cylinder with a five to nine percent tare weight lost passing testing, or may it be used until additional inspection and hydrostatic testing is warranted or it inspection and hydrostatic testing may only be used for one year from the date of that fails the ten percent taro weight lost rule? If you should have any questions, please call me al 800-437-8715, extension 183. Thank you. Ki Shur Allied Universal Corp. Sately and Regulatory Compliance Mansoer z0• 6662-908-676#

Page 4I CGA C-6-1993 Раде в COMPRESSEO GAS AXSOCIATION AYE occurs in the ares of the intersection of the footring 2.2.6.3 Crevice Corrosion. Crevice corrosion 2.2.7 Weld Defects. Cracks or faws in weld of crevice corrosion. or headring with the cylinder. Fig. 4 is an example areas reduce the structural strength of metal which may eause separation when pressurized. that which covers considerable surface areas of the 2.2.6.4 General Corrosion. General corrosion is 3. LOW PRESSURE CYLINDERS EXEMPT FROM THE HYDROSTATIC TEST often difficult to measure or estimate the depth of cylinder. It reduces the structural strength. It is This section covers cylinders exempt from the original wall cannot always be made. General general corrosion because direct comparison with hydrostatic retest requirements of the DOT by virtue of their exclusive use in certain non- corrosion is often accompanied by pitsing. This corrosive gas service. They are nos subject to form of corrosion is shown in Figs. 5 and 6. internal corrosion and do not require internal shell inspection. il. due to unusual circumstances. cylinders of these types suffer internal corrosion. they should be inspected in accordance with the procedure in Section 4. 3.L Preparation for Inspection. Al the time of requalification. all russ, scale. caked paint, caked the exterior surface so that the surface is coatings, erc., shall be complescly removed from adequately prepared for inspection. checked as outlined below for corrosion, general 3.2 Exterior Inspection. Cylinders shall be a weakness which would render them unfit for distortion. or any other defcet that might indicate service. 3.2.) Corrosion 3.2.1.1 Corrosion Limits. To fix corrosion limits for all types, designs and sizes of cylin. pracsicable: Failure to meel any of the following ders. and include them in this standard ts not four general rules is cause for condemning a cylinder. Fig. S. General Corrosion with Pitting. tare weight is less than 90% of the original (1) A cylinder shall be condemned when the stampedisre weight & cylinder shall be rejecred original stamped tare weight. A rejeczed cylin. when the rare weight is less than 95% of the der may be requalificd in accordance with 49 expansion. [1) When decermining rare weight. be CER 173.31(e). by water jacket or by direct sure the cylinder is empty. remaining wall in an area having isolated pitting (2) A cylinder shall be condemned when the mum allowable wall thickness. Refer to Fig. 2. only is less than one-third of the original mini- crevice corrosion on the cylinder is 3 inches (76:2 () A cylinder shall ue condemned when line or less than three fourths of the original ininimum mm) in length or over and the remaining wall is - corrosion isless than 3 inches (76.2 mm) inlength allowable wall thickness or when line or crevice and the remaining wall thickness is less than Fix. 6. Goneral Corrosion with Pirting on Cylinder Wall thickness. Refer to Figs, 3 and 1. one-hail the original minimum allowable wall 6662-908-616#

Page 5.. ALLIED UNIVERSAL CORPORATION PHONE: 800.107.071STEAX:005.883148;1859 115T* AVENUE. FACSIMILE TRANSMITTAL SHEET 10. Edwaro Mazzullo FRoM Robin Botto COMPANY: MISDOT /RSPA DATE. 3-13-02 PAX NUMBER TOTALNO. ON PAGIX INCIUDING COVEA 202-334-3012 PHONE NUMBEY: 202-344-8853 Interpretation Request O URGENT FOR REVIEW O PLEASE COMMENT OPLEASE REPLY NOTES/COMMENTS Mr. Muzzullo, If you can not read this, please contact me. EPA sent usal a letter asking us not to mail anuthing to Dc. To tax it, Feder it, Couriex snice it, but no mail. Robi To d 6662-908-616#