UPS Hydrostatic Shop — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration FEB 1 5 2007 Mr. Robert A. Stewart UPS Component Shop Supervisor Ref. No.: 07-0002 UPS Aircraft Maintenance Hangar UPS Hydrostatic Shop 750 Grade Lane Louisville, KY 40213 Dear Mr. Stewart: This is in reference to your January 4, 2007 letter to Mr. Frazer C. Hilder, Pipe ine and Hazardous Materials Safety Administration's Office of the Chief Counsel, regarding the cylinder requalification requirements contained in § 180.205(g) of the Hazardous Materials and +1% accuracy tolerances of the expansion indicating device (EID), as specified in Regulations (49 CFR Parts 171-180; HMR). Specifically, you ask whether the 1% resolution § 180.205(g)(2) and (g)(3)(ii), apply to the permanent expansion reading specified in § 180.205(g) (4)? permanent expansion reading is used to evaluate the acceptance or rejection of a given tested Tne answer is no. The EID is used to verify the accuracy of the test equipment system. The cylinder. (g)(2), an EID must permit incremental reading of the cylinder expansion to 1% of the total Paragraph (g)(2) prescribes a resolution standard for an EID. In accordance with paragraph expansion of each cylinder tested. Paragraph (g)(3)(ii) prescribes an accuracy standard for an EID. In accordance with paragraph (g)(3)(ii), an EID must provide a stable reacing of a tested that day. cylinder's expansion and must be accurate to +1.0% of the total expansion of any cylinder Each day before retesting, the requalifier must use a calibrated cylinder, or other method authorized in writing by the Associate Administrator for Hazardous Materials Safety, tr verify the accuracy of the test systern. The test equipment must be verified to be accurate to ithin + 1.0% of the calibrated cylinder's certificate values (see § 180.209(g)(4)). This ca e accomplished using the EID by bringing the total expansion to the selected value shou pressure indicating device by bringing the pressure to the selected value shown on the on the calibrated cylinder certificate. Alternatively, this can be accomplished using the calibrated cylinder certificate. Regardless of the procedure used, the calibrated cylinder must 180.205(9) 070002#

Page 2show no permanent expansion. When the pressure is released, the EID must show zero (0) cc. If the pressure fails to return to zero (0) cc, the test system has not been proven to be accurate. The retester is not authorized to test cylinders to determine their suitability for service until the test system is proven to be accurate. I hope this information is helpful. Please contact us if you have additional questions. Sincerely yours, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Mitchell 3180:2059) Cylinders 07-0002 January 4, 2007 Frazer C. Hilder, Attorney Office of the Chief Counsel (PHC-10) Pipeline and Hazardous Materials Safety Administration Room 8417 U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590-0001 RE: Informal Response Case No.: 06-0257-CRS-CE Dear Mr. Hilder: Please be advised that this letter is United Parcel Service Co.'s (UPS) request for written interpretation resulting from the informal conference call held on December 19, 2006. Please provide interpretation to the following: 1. Does the 1% resolution and +1% accuracy tolerances of the expansion indicaring device, specified in 49 CFR180.205 paragraphs (g)(2) and (g)(3)(il), apply to the pennanent expansion reading of paragraph (g)(4)? 2. If not, what is the requirement for the expansion indicating device, and where do we find this new tolerance definition in the CFR? requirements of the device do not pertain to certain readings (i.e. the permanent expansion It seems to be an arbitrary decision of PHMSA to state that the written definition of the tolerance and when they do not apply. And, for any reading to which the stated tolerance requ rements do reading of the calibrated cylinder). Please clarify specifically when the stated tolerar. ces apply, no: apply, please provide the tolerance requirement for that reading. with Mr. Garton, and he stated that the issue was not resolved. He indicated that there was no Ycu indicated that this issue was settled in a verbal conversation with Darrell Garton. I spoke some agreement that the "0.Occ" interpretation was not correct, however PHMSA did not want to final resolution, but that PHMSA personnel were going to work on it. He said that there was allow the full +/-1% of Total Expansion. He said that Mr. Richard Tarr stated, "Well, we might give you 0.Icc or 0.2cc, but that's all I'm willing to go."#

Page 4Frazer C. Hilder Page 2 January 4. 2007 Mr. Garton sent me an email immediately after the meeting you referenced. In it he stated: From: Darrell Garton [mailto: darrell@montrose.net| Sent: Thursday, July 20, 2006 11:26 AM To: 'rastewart@ups.com Subject: RE: DOT Meeting? Hi Robbie, good deal of positive agreement to work toward a solution. Unfortunately, no. There were no definite answers given. However, there was a As you can see, there obviously remains some disagreement regarding this issue. If you have given any direction, verbal or written, please provide it and publish it so that this ind astry has clear direction for the tolerance requirements of the expansion indicating device of the testing referenced to the Compressed Gas Association (CGA) C-l. C-1 was not incorporated into the Per our conversation with you and Ms. Mitchell about the Expansion Measurement System, you the discussion. CFR, and therefore we do not see the relevance to this case. However, since you brought it into According to CGA C-l. Paragraph 4.4 h) Once stabilization is accomplished, release the pressure from the system. With the pressure release valve open, the expansion measurement device should indicate zero accurate and ready for testing cylinders). (If the expansion measurement device does indicate zero, the system is proven measurement is zero, there is still room for interpretation on what is "Zero". With a Burette While I agree with CGA C-1 Paragraph 4.4, h) that we should ensure that the expansion "Zero". The Galiso hydrostatic test system owned by UPS utilizes a device of high precision that system, for expansions above 100cc, anything below 5cc (.1cc, .2cc, .3cc, .4cc) is read as . Icc, whereas the Burette system would read "Zero". is capable of reading to 0.1cc through its full range. When the UPS system reads. Ice it records The Burette system would be considered calibrated with (.1cc, 2cc, 3cc, 4cc) expar.sion at "Zero". The UPS system would not be considered in calibrated due to the electronic display of the expansion. This appears to be a "Double Standard" (Burette vs. Electronic) on what is "Zero".#

Page 5Page 3 January 4. 2007 Frazer C. Hilder For all readings. the adjusisdie panel shall be moved so that the meniscus of the water column reference point indicator of she lesi panel. in the graduated burette is a she same level as the • Burcite reading (at borom of meniscus) is read 1o the nearest of: 1) Marked increment The BOTTOM of the water meniscus is used for ог. all readings as shown betow: 2) Midpoint berween marked increments 2.0 and 3.0 Bottom of meniscus half way between Record as 2.Scc Poene Richereact Indic Mor - - !!I 190cc 70:c Boutor of meniscus is above 2.0 and Record as 2.0cc below 25, bul closer Do 2.0 Cylnder Ready For Takaing Exparison Tols) Reading Permanent Takin Exportsion Readies • Select and use burette lo ensure total expansion 4.2.1.2.1 Burette systems reading can be read to an accuracy of 1% For burette systems, all measurements must be taken at the same reference level and from the bottom of the meniscus (see figure 5). point of water in the water jacket and its connecting piping. If the total expansion of the calibrated cylinder was 50 cc, the required accuracy of the device detailed in 180.205(g)(3)(ii). Our Galiso hydrostatic test system was within +1% accuracy of the would be +/- 0.5 cc (1% of the total expansion) as per the specified accuracy of the device, total expansion of the cylinder tested on the following dates; January 26, 2006 Test record, date vumber of cylinder 3 cylinders retested Perm expansion 0.4cc +1.0% of system accuracy 0.8% January 30, 2006 (2 cylinders retested) 0.2cc 0.4% March 3, 2006 (4 cylinders retested) 0.2cc 0.4%#

Page 6Page 4 Frazer C. Hilder January 4. 2007 Please provide a written interpretation resulting from the informal conference on the questions ask within the first paragraph. Best Regards. UNITED PARCEL SERVICE CO. CoNTAST Robert A. Stewart UPS Hydrostatic Shop (RIN number G305) UPS Component Shop Supervisor UPS Aircraft Maintenance Hangar Louisville. KY 40213 Telephone: (502)-359-8274#