{"operation":"document","citation":"09-0198","title":"UPS Aircraft Maintenance Hangar — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-12-14","effective_on":null,"summary":"09-0198 response to UPS Aircraft Maintenance Hangar concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0198.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0198.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0198","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090198.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Ave., SE\nU.S. Department Washington, DC 20590\nof Transportation\nPipeline and Hazardous Materials\nSafety Administration\n-DEC 14 2009\nMr. Robert A. Stewart\nUPS Component Shop Supervisor\nUPS Hydrostatic Shop\nUPS Aircraft Maintenance Hangar\n750 Grade Lane\nLouisville, KY 40213\nRef. No.: 09-0198\nDear Mr. Stewart:\nThis is in reference to your August 13, 2009 letter in which you again ask about possible\ntolerance requirements for the permanent expansion reading for the calibrated cylinder.\nAs stated in my previous responses, the cylinder requalifier must use a calibrated cylinder or\nother approved method to verify the accuracy of the test equipment system. When the\ncalibrated cylinder is pressurized, the test equipment must be verified as accurate within\n± 1.0% ofthe calibrated cylinder's pressure and the corresponding expansion value shown on\nthe cylinder calibration certificate. When the pressure is released, this calibration process\nrequires that the calibrated cylinder exhibit no permanent expansion as specifically stated in\n§ 180.205(g)( 4).\nWith regard to your reference to the Compressed Gas Association (CGA) C-l, currently the\nHMR do not incorporate the publication by reference. We may consider incorporating by\nreference this publication or certain provisions ofthe CGA C-I publication in a future\nrulemaking.\nI hope this information is helpful. Please contact us ifyou have additional questions.\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice ofHazardous Materials Standards\n\n<<<PAGE 2>>>\n\nAugust 13,2009\nVIA UPS NEXT DAY AIR\nOffice ofHazardous Materials Standards\nRegulatory Review and Reinvention\nHattie Mitchell, Chief\n400 7th St., S.W.\nWashington, DC 20590\nDear Ms. Mitchell,\nThank you for your letter dated July 8, 2009, in which you responded to our\nquestions from (Ref. No.: 07-0059) dated Apri16, 2007. However, I must disagree\nwith your responses.\nYou state in AI. \"This is a separate requirement and is not related to the test\nequipment + 1.0% accuracy requirement. Thus, the HMR do not specify a\ntolerance in determination ofpermanent expansion of a calibrated cylinder when\nused to demonstrate the accuracy of a retest system. Any permanent expansion\nmay indicate entrapment ofair or other malfunction of the equipment.\"\nParagraph (g) (4) which specifies that the calibrated cylinder must show \"no\npermanent expansion.\" was discussed in great length at the last Compressed Gas\nAssociation conference. It was determined at this conference that the calibrated\ncylinder is an integral part ofthe test equipment and there should be a tolerance\nfor \"Zero expansion\" for the calibrated cylinder during the calibration ofthe\nsystem. In CGA pamphlet Cl Tenth Edition Paragraph 5.5.1 Verification\nrequirements \"The calibrated cylinder shall return to zero within + .1% ofthe\ntotal expansion ofany point or + .1 cc which ever is greater.\" PHMSA personnel\nhave been involved with the Compressed Gas Association for a very long time.\nWhile I recognize that C-l is not currently incorporated within 49 CFR, the\nparticipants in the C-l subcommittee are recognized as the industry leaders in\nhydrostatic testing, and included personnel from PHMSA. No true clarification\nfor \"Zero expansion\" has been one ofthe reasons it has not been incorporated. I\nam pleased that the CGA has recognized the disparity in reading and interpretation\nbetween the Burette vs. the Electronic test systems. However, I still do not feel\nthat this is an accurate quantitative specification for \"Zero expansion\".\nAlso, as a point of clarification, the end result of air in the expansion lines will\nresult in negative expansion, not positive permanent expansion.\n1\n\n<<<PAGE 3>>>\n\nIn A2 you state. \"The requirement is the same regardJess of the type of equipment\nused. The calibrated cylinder must show \"no permanent expansion.\" Thi mean\nthat the water level in the burette or the weight bowl must return to the same point\nwhere it began - not slightly higher or lower. Rounding is not permitted when\ndetermining whether the calibrated cylinder has shown permanent expansion. Any\nvolume of water measured in the ErD above zero (or the original reading)\nindicates pennanent expansion of the calibrated cylinder. If this occur, the\nequipment has not been proven to be accurate in accordance with the HMR.\"\nI have never read or heard the term \"rounding\" ever used in 49 CFR or in any\nCGA document. he term used in 49 CFR and eGA C-l i \"reading\". According\nto 49 CFR lS0.205(g)(3) (ii), The expansion-indicating device, as part ofthe\nretest apparatus, gives a stable reading ofexpansion and is accurate to + 1.0% of\nthe total expansion ofany cylinder tested or D .icc, whichever is larger. The\nexpansion -indicating device itself must have an accuracy of+0.5%, or better, of\nits full scale. When you are reading a Burette the reference point indicator should\nbe positioned so that measurements can be taken conveniently at eye level. Burette\nread ing (at bottom of meniscus) i. read to the nearest: marked increment or\nmidpoint between marked increments. When reading a Icc burette the Burette\nsystem would be considered calibrated with (. Icc, .2cc, .3cc .4cc) expan ion at\n\"Zero\". This is accomplished by the adjustment panel which is moved so the\nmeni cu of the water column in the graduated burette is at the same level as the\nreference point indicator of the test panel. As you can see from the photo's it is\nvirtually impossible to read the .1 cc, .2cc, .3cc and Acc on the burette.\nHere are three photos' that illustrate the difficulty of reading a lee increment\nburette.\n2\n\n<<<PAGE 4>>>\n\n-..\n....J\nZ\n<.\n!f\"J\nCI\nI\nJ\n~\nEnlarged photo to show cale reading on burette and cale\n3\n\n<<<PAGE 5>>>\n\nThose photos of an actual burette system show that readings of. Icc, .2cc, .3cc and\n.4cc readings would be impos ible to make on a burette ofthe size required for the\nexpansion of our calibrated cylinder. However, these are the very readings that\nPHMSA has cited as violations on our electronic expansion measuring device. You\nstated, 'The requirement is the same regardless of the type of equipment used.\"\nHowever, a demonstrated by these photos, the retest facility using the above burette\nwould not be facing the violations that you have leveled against UPS, bee au e they\ndon't have the ability to see those readings.\nHere are two photos of UPS high precision test system capable of reading 0.1 cc\nthrough its full range .\n.lcc reading on UPS Galiso Recortest Hydrostatic Test System\n4\n\n<<<PAGE 6>>>\n\nI\nUPS System calibrating \"Zero Expansion and Zero Pressure\"\nAfter seeing both test systems in the photographs, it is obvious there is a big\ndifference in reading the expansion levels between the less accurate burette te t\nystem and the preci e electronic test system.\nNow that the CGA (which is made-up of the industry experts and PHMSA per onnel)\nha identified that there should be a tolerance for \"Zero expansion\" I feel it is in the\nbest interest ofthe PHMSA to accomplish a field study or, scientific hop study to\nestablish an accurate tolerance for \"Zero expansion\".\nDuring these uncertain economic times the PHMSA should be doing everything\npossible to ensure an even playing field. Companies with burette sy terns should not\nbe given an unfair competitive advantage over the highly accurate computer systems.\n5\n\n<<<PAGE 7>>>\n\nI feel it is time to dismiss for the Notice ofthe Probable Violations on PHMSA Case\nNo. 06-0257-CRS-CE. Due to the corrective actions taken by UPS, the lack oftimely\nresponse from PHMSA and the \"Double Standard\" (Burette vs. Electronic) UPS has\nendured. I hope we can resolve this matter without having to request a Formal\nAdministrative Hearing in accordance with 49 CFR 107.319.\n;;::;:s~\nRobert A. Stewart\nUPS Component Shop Supervisor\nUPS Hydrostatic Shop (RIN number G305)\nUPS Aircraft Maintenance Hangar\n750 Grade Lane\nLouisville, KY 40213\nTelephone: (502)-359-8274\nFax: (502)-359-7277\n6","truncated":false,"body_characters":7965}