UPS Hydrostatic Shop — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAR 3 0 2007 Mr. Robert A. Stewart UPS Component Shop Supervisor Ref. No.: 17-0059 UPS Aircraft Maintenance Hangar UPS Hydrostatic Shop 750 Grade Lane Louisville, KY 40213 Dear Mr. Stewart: This is in reference to your March 9, 2007 letter in which you again ask about possible tolerance requirements for the permanent expansion reading for the calibrated cylinder. use a calibrated cylinder or other approved method to verify the accuracy of the test As stated in my February 15, 2007 letter (ref. No.: 07-0002), the cylinder requalifier must verified as accurate within =1.0% of the calibrated cylinder's pressure and the equipment system. When the calibrated cylinder is pressurized, the test equipment must be pressure is released, this calibration process requires that the calibrated cylinder exhibit no corresponding expansion value shown on the cylinder calibration certificate. When the permanent expansion as specifically stated in § 180.205(g)(4). I hope this information is helpful. Please contact us if you have additional questions. Sincerely yours, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 180205 (g)(+) 070059#

Page 2Mitchell March 7, 2007 $ 180-205 g14) VIA UPS NEXT DAY AIR Cylinders Office of Hazardous Materials Standards 07-0059 Regulatory Review and Reinvention 400 7* St., S.W. Hattie Mitchell, Chief Washington, DC 20590 Ref. No.: 07-0002 Dear Ms. Mitchell: Thank you for your response dated February 15, 2007. However, it appears that your interpretation of 49 CFR 180.205 (g)(4) contradicts the definitions of the required! accuracy and resolution of the device, as detailed in 49 CFR180.205 paragraphs (g)(2) and (g)(3)(ii). It would be extremely beneficial to get a written definition of the tolerance requirements of the device in order for our operations to fully comply with the regulations. This is the fourth time that I have questioned this "double standard" on the tolerance requirements of the device that do not pertain to certain readings (i.e. the permanent expansion reading of the calibrated cylinder). Again please reading to which the stated tolerance requirements do not apply, please provide the tolerance clarify specifically when the stated tolerances apply, and when they do not apply. And for any requirement for that reading. I was unable to determine the tolerance requirement for the permanent expansion reading based on the letter you provided. According to your letter the calibrated cylinder must show no permanent expansion. "When the 'pressure' [I believe you mean 'expansion' ] fails to return to zero (0) cc, the test system has not pressure is released, the EID must show (0)cc." Does that mean 0.Occ? You said, "If the proven to be accurate." This appears to contradict the first sentences in this parag: aph. (g)(4) The test equipment must be verified to be accurate within < plus- minus>1.0% of the calibrated cylinder's pressure and corresponding expansion values. This may be accomplished by bringing the pressure to a value shown on the calibration certificate for the calibrated cylinder used and verifying that the resulting total expansion is within splus-minus- 1.0% of the may be demonstrated by bringing the total expansion to a known value on the this paragraph (g) to an authorized inspector on any day that it retests cylinders. A retester must maintain calibrated cylinder certificates in conformance with Sec. 180.215(b)(4). 1#

Page 3Questions: 1. Are you stating that the tolerances in 49 CRF 180.205 (g)(4) should be 0.0% not +1.0%? 2. If the EID is allowed ‡1.0% accuracy, and the Calibrated cylinder is used to prove this accuracy (+1.0% of the total expansion value of the Calibrated Cylinder), then according to 49 CFR 180.205 paragraph (g)(3)(ii) and 49 CFR180.205 paragraphs (g)(4), what are the tolerance requirements of the device that do not pertain to certain readings (i.e. the permanent expansion reading of the calibrated cylinder). 3. According to 180.205(g)(2) and (3), the EID is required to have a readability to within according to your letter, the EID must show zero (Occ) permanent expans on, in other 1% of the Total Expansion, and an accuracy of +1.0% of the Total Expansion. However, words †0.0% tolerance. Please answer the following questions specifically and explain your answers: than the device, itself, is required to have? (i.e. 0.Occ Permanent Expansion How can we be held to an accuracy and readability requirement that is higher reading for a device that is allowed +1.0% deviation.) readings would not even be seen on a system using a burette. On a burette type Why are we being penalized for using higher quality equipment? These machine, the increments would be 0.5cc, and the operator would record 0.0cc quality, digital equipment that these readings can even be detected. These for anything less than 0.5cc. It is only because we have invested in higher the device, and would never be seen on the old burette type equ pment. This readings are smaller than the required resolution and accuracy requirements of lack of understanding of technical specifications for resolution and accuracy by PHMSA is penalizing users who invest in higher quality equipment. If our for 0.001 cc deviations? How far are you going to take this fool shness? machine was capable of reading in 0.001 cc increments, would you penalize us The following information quantifies the calibration of our high precision test system capable of reading to 0.1cc through its full range, and the associated days in question. The information also verifies the system was in tolerance according the to 49 CFR180.205 paragraph (g)(3)(ii) and 49 CFR180.205 paragraphs (g)(4).#

Page 449 CFR 180.205 (g)(2) The pressure indicating device of the testing apparatus must permit reading of pressures to within 1% of the minimum prescribed test pressure. • 1 RECORTEST/OPEN (A)System Components research and development in the field of computer controlled hydrostatic test systems. Each •e advanced design of the Recortest/Open (A) Test System is the culmination of fifteen years of cylinder re-qualificatior process. Collectively, the components of the Recortest/Open (A) Test System componert of the Recortest/Open (A) Test System has been carefully designed to streamlire the work together to provide unparalleled speed, accuracy and simplicity of operation. The primary Recortest/Open A) test system components are discussed in detail in Sections 2.1 through 2.6. Standard Recortest/Open (A) System specifications are as follows: Test Pressure Range: 0 to 10,000 psig Expansion Test Results: 0.1 cc increments Cylinder Throughput: 10 to 20 cylinders (2640 cu. in. ea.) per hour Warranty 1 Year see warranty terms LOAD CELI. ASSEMBLA KEYBOARDENITOR -COAPUTER •TE. ST CONSOLE YI INDE PRINTER- AIR RESERVOIA - BLEED VALVE The total expansion of our calibrated cylinder is 52.5 cc, the required accuracy o the device would be +/- 0.5 cc (1% of the total expansion), (52.0 to 53.0) as per the specified accuracy of the device, detailed in 180.205(g)(3)(ii). According to 49 CFR 180.205 (g)(3)(ii) and your letter, our Calibrated Cylinder was with in the ‡1.0% accuracy limit. On the following dates: 1/26/06, 1/30/06, & 3/3/06 & 3/3/06. (g)(3)(ii) The expansion-indicating device, as part of the retest apparatus, gives a stable reading of expansion and is accurate to 1.0% of the total expansion of any cylinder tested or 0.1 cc, whichever is larger. The expansion-indicating device itself must have an accuracy of <PLUS-MINUS0.5%, or better, of its full scale. 3#

Page 5Reference: Exhibit Number #4 Cylinder Calibration Certificate 7122/03 Cylinder Calibration Certificate Galiso Inc. Sales Order Number: 83767 Company Name: UPS1 Cylinder Information: Cylinder Manufacturer: Taylor Wharton Temperatures: Galiso Serial Number: SCC0306-070BC Mfg. Serial Number: TWE03-606816 Cylinder: Jacket: 72 F Air: -75 F 72 F Calibration Control: Reference Standard: Heise Model PM Digital Pressure Indicator S/N 41570 Next Calibration Due: Last Calibration: 7/8/03 7/8/04 0-200 7420790 1 00 420s: possible to the temperature of the water in the cylinder and the ambient air temperature. To ensure accuracy, the temperature of the water in the test jacket should be as close as All temperatures must be held as stable as possible, and with 5 degrees of each other. Accuracy may be affected by temperature changes as slight as 2 degrees Fahrenheit. Expansion in cubic centimeters vs. Pressure in psi: 3,000 PSI CC's Tolerance 52.5 (+/-) Acceptable Range: 87.8 70.1 0.5 Low to High 4,000 0.7 52.0 6,000 5,000 105.5 0.8 69.4 123.6 1.0 87.0 U.S. DOT/PHIMSA/OHME/CE REPORT NUMBER: 06434025 159.9 141.6 1.2 104.5 1.4 122.4 106.5 EXHIBIT NUMBER: 4 8,000 7,000 1.5 158.4 140.2 143.0 124.8 PAGE 1 OF 1 9,000 161.4 calibrated bi l ile Da10687/2217 the daily calibration required by 49 CFR 173.34(e)(4)(iv). File one copy and post the other copy at the test station for the test operator's use during O§CALSO® COPY 4#

Page 6Exhibit Number #5 Test Record date 1/26/06 Calibrated cylinder pressure test at 3000 psi, pressure returned to "0" after test. Test record, date Number of cylinders Perm expansion +1.0% of system accuracy January 26, 2006 (3 cylinders retested) 0.4cc 0.8% REPORT NUMBER: 06434025 U.S. DOT/PHMSA/OHME/CE EXHIBIT NUMBER: 5 PAGE 1 OF 1 LouisviLLE, KY 40213 750 UZADE LAN 307/CTC kegistration 0977? lest bate: 01:261:00 SUERISOR SIGMATuRES: speres or at a see will at terest see tests sere nade ander ay - ME: 1/24/06 Operater ilner Test fine serial a Pieter Site AFG. Jate: Whit init i Pressare 13:35 5124342 8. 50x39 8-7 REE Dispit Reeart 19120 5124342 V 13427561300 13:39 794013 8.50123 0. 36729 8-2 ü-i BYNE 341-1850 3645850 PSI 3400 PSI 3002 30 V 52.86.4 04/2001 PST 381-1850 2467 PSI PSI 2485 30 128.0 0.0 0.8 52.4 04/2801 1W200.0 PON CAL VER ANJ ( 2050 fin 8.50x29 8-2 COYL 3#T-1839 3084 989730 166,0 0.8 0.0 128.0 164.9 ppp SR:127351 3MT-1850 3064 2467 3104 30V171.0 171.00:0 2480 30 0.0 160.064.9 PAPV 59112301 AT 13:50 503752 V 6.34424 1-2 135.0 0.0 0.8 135.0 9.0 pAP SE1127346 8.304 2" 8-2 Ci/2600 2467 2486 30 131.5 C.0 0.: 171.0 90 spouse27946 r 41i2300 3034 PSI 2096 30 V 163.0 0.0 2.0 131.0 T 222 199 0.0 163.0] 722 100 58:2439 SR1:27433#

Page 7Exhibit Number #6 Test Record date 1/30/06 Calibrated cylinder pressure test at 3000 psi, pressure returned to "0" after test. Test record, date Number of cylinders Perm expansion ‡1.0% of system accuracy January 30, 2006 (2 cylinders retested) 0.2cc 0.4% REPORT NUMBER: 06434025 U.S. DOT/PHMSA/OHME/CE PAGE 1 OF 1 EXHIBIT NUMBER: 6 CRUISVILLE, KY 49213 CRAFT BALMTENANCE/ GRABE 1 PA - Pass Visaal, short 1 Pera, Abort RE ers, Passed RE 38T/CTC Registration e???? lest late: 01/30/2896 surelyisür sisteroles: — ME: 1/50/06 heres car a cord the fit i it repent on its were ande ander i *Tine Serial • Glinter size Strice timer ase ilest haccuat, lase Total Pere bets tas LETED 130.0 C. 6.6 :30.0 R.1 530 2000 PAN CA-V 165.0 6.0 0.1 165.0 172.2 PPP • 5R1:27576 166.0 0.0 132.; 6.0 .: 132.9 i69.: ppp 6#

Page 8Exhibit Number #8 Test Record date 3/3/06 Calibrated cylinder pressure test at 3000 psi, pressure returned to "0" after test. Number of cylinders Perm expansion +1.0% of system accuracy March 3, 2006 (4 cylinders retested) 0.4% U.S. DOT/PHMSA/OHME/CE EXHIBIT NUMBER: 8 REPORT NUMBER: 06434025 PAGE 1 OF 1 LOUISVILLE, KY 40213 75i SPACE - Pass visa, Ass : Fero, Passed REE 2a - Pass Viscal, Ador! : Pers,Abort REE * 3/3/06 asis were dade under i Test Jeerator 10u3r far Seria Cyliader Size 1 8Fg. Bate A Rating : fressure Hait. Rait 1 Hest ikitwill lise total Per Here Cass REE Bis • Resari (. 7#

Page 9Exhibit Number #9 Test Record date 3/3/06 Calibrated cylinder pressure test at 3000 psi, pressure returned to "O" after test. Test record, date Number of cylinders Perm expansion +1.0% of svstem accuracy March 3, 2006 (4 cylinders retested) 0.2cc 0.4% REPORT NUMBER: 06434025 U.S. DOT/PHMSA/OHME/CE PAGE 1 OF 1 EXHIBIT NUMBER: 9 AIRCRAF: MAINTEMANCE/UPS QUISVILLE, I9 402: SO SRADE LAY S8T/CIC Registration 13*2? PAA - Pass Viscal, Alert: hers, itor: REE ¡as: Saca: 13:03:2000 SUPERVISOR SIGNATORES: - Mi: 3/3/06. apervision i tests were ande. ander dy * Size Service He sating 4.! *3:47 803066780 ViM. er :16 Frie i HOt But 2p lear 50958523211 19:56 3232:1 8. 5CX29 UPS 9.5Cx29 TEET 2495 30 PSI 3130 30/ 126.0 0.0 KA 10:07 515781 UPS B.S0×29 PSI 159.6 c.0 126.0 171.2 PPP 2.0 8.50x29 2485 30 3102 30 0 :30.0 6.0 :59.0 5*41.2 Ppp 381195786 :64.0 6.0 6.0 $.0 :30.0 CiTe.3 Per 09/2033 PSI 0.0 164.0#

Page 10We urgently need to receive an explanation of the tolerance requirements of the EID device that cylinder). Additionally, we request that the probable violations on PHMSA Case No. 06-0257- do not pertain to certain readings (1.e. the permanent expansion reading of the calibrated CRS-CE be dropped, otherwise we may need to consider a formal hearing in accordance with 49 CFR 107.319. I hope we can resolve this matter as expeditiously as possible in order for us to efficiently operate our business and remain compliant with the regulations. Best Regards, Pontasiut Robert A. Stewart UPS Component Shop Supervisor UPS Hydrostatic Shop (RIN number G305) UPS Aircraft Maintenance Hangar 750 Grade Lane Louisville, KY 40213 Fax: (502)-359-7277 Telephone: (502)-359-8274#