{"operation":"document","citation":"07-0002","title":"UPS Hydrostatic Shop — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-02-15","effective_on":null,"summary":"07-0002 response to UPS Hydrostatic Shop concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070002.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nHazardous Materials Safety\nAdministration\nFEB 1 5 2007\nMr. Robert A. Stewart\nUPS Component Shop Supervisor\nRef. No.: 07-0002\nUPS Aircraft Maintenance Hangar\nUPS Hydrostatic Shop\n750 Grade Lane\nLouisville, KY 40213\nDear Mr. Stewart:\nThis is in reference to your January 4, 2007 letter to Mr. Frazer C. Hilder, Pipe ine and\nHazardous Materials Safety Administration's Office of the Chief Counsel, regarding the\ncylinder requalification requirements contained in § 180.205(g) of the Hazardous Materials\nand +1% accuracy tolerances of the expansion indicating device (EID), as specified in\nRegulations (49 CFR Parts 171-180; HMR). Specifically, you ask whether the 1% resolution\n§ 180.205(g)(2) and (g)(3)(ii), apply to the permanent expansion reading specified in\n§ 180.205(g) (4)?\npermanent expansion reading is used to evaluate the acceptance or rejection of a given tested\nTne answer is no. The EID is used to verify the accuracy of the test equipment system. The\ncylinder.\n(g)(2), an EID must permit incremental reading of the cylinder expansion to 1% of the total\nParagraph (g)(2) prescribes a resolution standard for an EID. In accordance with paragraph\nexpansion of each cylinder tested. Paragraph (g)(3)(ii) prescribes an accuracy standard for an\nEID. In accordance with paragraph (g)(3)(ii), an EID must provide a stable reacing of a\ntested that day.\ncylinder's expansion and must be accurate to +1.0% of the total expansion of any cylinder\nEach day before retesting, the requalifier must use a calibrated cylinder, or other method\nauthorized in writing by the Associate Administrator for Hazardous Materials Safety, tr\nverify the accuracy of the test systern. The test equipment must be verified to be accurate to\nithin + 1.0% of the calibrated cylinder's certificate values (see § 180.209(g)(4)). This ca\ne accomplished using the EID by bringing the total expansion to the selected value shou\npressure indicating device by bringing the pressure to the selected value shown on the\non the calibrated cylinder certificate. Alternatively, this can be accomplished using the\ncalibrated cylinder certificate. Regardless of the procedure used, the calibrated cylinder must\n180.205(9)\n070002\n\n<<<PAGE 2>>>\n\nshow no permanent expansion. When the pressure is released, the EID must show zero (0)\ncc. If the pressure fails to return to zero (0) cc, the test system has not been proven to be\naccurate. The retester is not authorized to test cylinders to determine their suitability for\nservice until the test system is proven to be accurate.\nI hope this information is helpful. Please contact us if you have additional questions.\nSincerely yours,\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nMitchell\n3180:2059)\nCylinders\n07-0002\nJanuary 4, 2007\nFrazer C. Hilder, Attorney\nOffice of the Chief Counsel (PHC-10)\nPipeline and Hazardous Materials Safety Administration\nRoom 8417\nU.S. Department of Transportation\n400 Seventh Street, S.W.\nWashington, DC 20590-0001\nRE:\nInformal Response\nCase No.: 06-0257-CRS-CE\nDear Mr. Hilder:\nPlease be advised that this letter is United Parcel Service Co.'s (UPS) request for written\ninterpretation resulting from the informal conference call held on December 19, 2006. Please\nprovide interpretation to the following:\n1. Does the 1% resolution and +1% accuracy tolerances of the expansion indicaring device,\nspecified in 49 CFR180.205 paragraphs (g)(2) and (g)(3)(il), apply to the pennanent\nexpansion reading of paragraph (g)(4)?\n2. If not, what is the requirement for the expansion indicating device, and where do we find\nthis new tolerance definition in the CFR?\nrequirements of the device do not pertain to certain readings (i.e. the permanent expansion\nIt seems to be an arbitrary decision of PHMSA to state that the written definition of the tolerance\nand when they do not apply. And, for any reading to which the stated tolerance requ rements do\nreading of the calibrated cylinder). Please clarify specifically when the stated tolerar. ces apply,\nno: apply, please provide the tolerance requirement for that reading.\nwith Mr. Garton, and he stated that the issue was not resolved. He indicated that there was no\nYcu indicated that this issue was settled in a verbal conversation with Darrell Garton. I spoke\nsome agreement that the \"0.Occ\" interpretation was not correct, however PHMSA did not want to\nfinal resolution, but that PHMSA personnel were going to work on it. He said that there was\nallow the full +/-1% of Total Expansion. He said that Mr. Richard Tarr stated, \"Well, we might\ngive you 0.Icc or 0.2cc, but that's all I'm willing to go.\"\n\n<<<PAGE 4>>>\n\nFrazer C. Hilder\nPage 2\nJanuary 4. 2007\nMr. Garton sent me an email immediately after the meeting you referenced. In it he stated:\nFrom: Darrell Garton [mailto: darrell@montrose.net|\nSent: Thursday, July 20, 2006 11:26 AM\nTo: 'rastewart@ups.com\nSubject: RE: DOT Meeting?\nHi Robbie,\ngood deal of positive agreement to work toward a solution.\nUnfortunately, no. There were no definite answers given. However, there was a\nAs you can see, there obviously remains some disagreement regarding this issue. If you have\ngiven any direction, verbal or written, please provide it and publish it so that this ind astry has\nclear direction for the tolerance requirements of the expansion indicating device of the testing\nreferenced to the Compressed Gas Association (CGA) C-l. C-1 was not incorporated into the\nPer our conversation with you and Ms. Mitchell about the Expansion Measurement System, you\nthe discussion.\nCFR, and therefore we do not see the relevance to this case. However, since you brought it into\nAccording to CGA C-l. Paragraph 4.4\nh) Once stabilization is accomplished, release the pressure from the system. With the\npressure release valve open, the expansion measurement device should indicate zero\naccurate and ready for testing cylinders).\n(If the expansion measurement device does indicate zero, the system is proven\nmeasurement is zero, there is still room for interpretation on what is \"Zero\". With a Burette\nWhile I agree with CGA C-1 Paragraph 4.4, h) that we should ensure that the expansion\n\"Zero\". The Galiso hydrostatic test system owned by UPS utilizes a device of high precision that\nsystem, for expansions above 100cc, anything below 5cc (.1cc, .2cc, .3cc, .4cc) is read as\n. Icc, whereas the Burette system would read \"Zero\".\nis capable of reading to 0.1cc through its full range. When the UPS system reads. Ice it records\nThe Burette system would be considered calibrated with (.1cc, 2cc, 3cc, 4cc) expar.sion at\n\"Zero\". The UPS system would not be considered in calibrated due to the electronic display of\nthe expansion.\nThis appears to be a \"Double Standard\" (Burette vs. Electronic) on what is \"Zero\".\n\n<<<PAGE 5>>>\n\nPage 3\nJanuary 4. 2007\nFrazer C. Hilder\nFor all readings. the adjusisdie panel shall be\nmoved so that the meniscus of the water column\nreference point indicator of she lesi panel.\nin the graduated burette is a she same level as the\n• Burcite reading (at borom of meniscus) is read 1o\nthe nearest of:\n1) Marked increment\nThe BOTTOM of the water meniscus is used for\nог.\nall readings as shown betow:\n2) Midpoint berween marked increments\n2.0 and 3.0\nBottom of meniscus half way between\nRecord as 2.Scc\nPoene\nRichereact\nIndic Mor\n- -\n!!I\n190cc\n70:c\nBoutor of meniscus is above 2.0 and\nRecord as 2.0cc\nbelow 25, bul closer Do 2.0\nCylnder\nReady\nFor\nTakaing\nExparison\nTols)\nReading\nPermanent\nTakin\nExportsion\nReadies\n• Select and use burette lo ensure total expansion\n4.2.1.2.1\nBurette systems\nreading can be read to an accuracy of 1%\nFor burette systems, all measurements must be taken at the same reference level and from the bottom of the\nmeniscus (see figure 5).\npoint of water in the water jacket and its connecting piping.\nIf the total expansion of the calibrated cylinder was 50 cc, the required accuracy of the device\ndetailed in 180.205(g)(3)(ii). Our Galiso hydrostatic test system was within +1% accuracy of the\nwould be +/- 0.5 cc (1% of the total expansion) as per the specified accuracy of the device,\ntotal expansion of the cylinder tested on the following dates;\nJanuary 26, 2006\nTest record, date\nvumber of cylinder\n3 cylinders retested\nPerm expansion\n0.4cc\n+1.0% of system accuracy\n0.8%\nJanuary 30, 2006\n(2 cylinders retested)\n0.2cc\n0.4%\nMarch 3, 2006\n(4 cylinders retested)\n0.2cc\n0.4%\n\n<<<PAGE 6>>>\n\nPage 4\nFrazer C. Hilder\nJanuary 4. 2007\nPlease provide a written interpretation resulting from the informal conference on the questions\nask within the first paragraph.\nBest Regards.\nUNITED PARCEL SERVICE CO.\nCoNTAST\nRobert A. Stewart\nUPS Hydrostatic Shop (RIN number G305)\nUPS Component Shop Supervisor\nUPS Aircraft Maintenance Hangar\nLouisville. KY 40213\nTelephone: (502)-359-8274","truncated":false,"body_characters":8915}