{"operation":"document","citation":"12-0176","title":"Georgia Fire Protection — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-12-12","effective_on":null,"summary":"12-0176 response to Georgia Fire Protection concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0176.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0176.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0176","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120176.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nDEC 1 2 2012\nMr. W .A. Andrews\nVice President\nGeorgia Fire Protection\n2090 Tucker Industrial Road, Suite A-6\nTucker, Georgia 30084\nRef. No. 12-0176\nDear Mr. Andrews:\nThis responds to your July 30, 2012letter and September 11, 2012 email requesting further\nclarification of your May 25, 2012letter of clarification under Ref. No. 12-0129 on\nrequalification of cylinders under the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). Specifically, you request clarification of when a cylinder may be retested\nunder § 180.205(g)(5) due to equipment failure that results in a failed outcome. In your\nemail and May 25 letter, you describe two types of failure scenarios that led to your\nrequest: 1) during a test of a 3AA cylinder, the test equipment failed to transfer volume\nfrom the jacket to the weight indicating device leading to the device showing minimal or\nno increase in weight, which results in either an aborted test or a failure at 100%\nexpansion; and 2) during a test of a 3AL cylinder, the test adapter to the cylinder had an 0-\nring failure resulting in a greater than 10% permanent expansion reading. During both of\nthese scenarios your technician became aware of the test equipment failure that you believe\naccounted for an erroneous permanent expansion reading.\nYou explain further that your company uses computerized test equipment that performs\nand records the test and results. Moreover, you provide information from the manufacturer\nof this equipment that corroborates your conclusion of equipment failure. Finally, you also\nprovide the cylinder test result reports associated with these scenarios for our reference.\nIn accordance with§ 180.205(g)(3) of the HMR, the retester must confirm test equipment\nis properly functioning before the onset of any retesting. This accuracy check of the\ntesting system, as well as adherence to any manufacturer maintenance recommendations, is\ndesigned to make a retester aware of any testing system problem(s) prior to the onset of\npressure testing. Also, in accordance with§ 180.205(g)(5), a retester may perform a\nsystem check at or below 90% of the test pressure prior to a retest to look at the testing\nsystem and cylinder for any leaks. However, we understand that test equipment can and\n\n<<<PAGE 2>>>\n\nwill occasionally fail during performance of a cylinder pressure test. Your questions are\nparaphrased and answered as follows:\nQl. Does § 180.205(i)(1)(iv) require condemnation of the 3AA cylinder in\nscenario 1 or does the test equipment failure invalidate the first attempt results and\nallow a retest under § 180.205(g)(5)?\nAl. As previously stated in our response under Ref. No. 12-0129, in the case of a\nmalfunction of the test equipment during a full retest (above 90% of the test\npressure), performance of a repeat test is authorized in accordance with\n§ 180.205(g)(5). However, a cylinder required to be condemned under\n§ 180.205(i) is not authorized for retesting. Section 180.205(i)(1 )(iv) refers to\ncondemnation of a DOT specification cylinder experiencing permanent expansion\nexceeding 10% of total expansion under proper test conditions. The cylinder does\nnot have to be condemned if it can be substantiated that the test equipment failure\nled to a false reading. Note that the reason for this repeat test must be included on\nthe test record in accordance with § 180.215(b )(2). The repeat test must be\nperformed at a pressure increased by 10% or 100 psig, whichever is less. Because\nof the unique circumstance of the equipment malfunction, we recommend\nrecalibrating the test equipment before conducting the repeat test. Also, we\nrecommend performance of a system check at or below 90% of test pressure prior\nto the repeat test to ensure the system is functioning properly. Finally, we caution\nthat at no time should a cylinder retest exceed 110% of the minimum test pressure.\nIf a cylinder is pressurized to more than 110% of the minimum test pressure, it may\ncause embrittlement of the cylinder's sidewall which could result in failure of the\ncylinder in service.\nQ2. Does § 180.205(i)(1)(iv) require the condemnation of the 3AL cylinder in\nscenario 2 or does the test equipment failure invalidate the first attempt results and\nallow a retest under § 180.205(g)(5)?\nA2. See Al.\nI hope this answers your inquiry and clarifies our previous response. If you need\nadditional assistance, please contact this office at (202) 366-8553.\nSincerely,\n7#-ZJ'h-\nRobert Benedict\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\n-eoathe-\n& /?.>0. 2D5\nFire Protection\n~I ir1cfer~\n{')_- /) !1&\nJuly 30, 2012\nUS DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: Robert Benedict, Chief, Standards Development Branch\nStandards and Remarking Division\n1200 New Jersey Ave. SE\nWashlngton, DC 20590 0001\nRefNo. 12-0129\nDear Mr. Benedict:\nI find myself in the unenviable position of requesting a clarification of your clarification\nletter dated July 19, 2012. Your clarification letter would appear to say that a retest is\nallowed and is in order. The South East Region's interpretation appears to say that under\n180.205(i)(iv), we are not allowed to retest the cylinders because the first test results\nshowed a permanent expansion of greater than 10%.\nI will try to ask the question as specifically as possible.\nOn both Example 1 and 2, the pressure test was performed by an automated, computer\ndirected test method. The computer records the test results as an aborted, failed or passed\nindication. In Exan1ple 1, the computer aborted the test but recorded a 1 00% permanent\nexpansion reading. In Example 2, the computer failed the test and recorded a greater than\n1 0% permanent expansion reading.\nDuring both of the tests our technician became aware of a test equipment failure that\naccounted for the erroneous permanent expansion readings that were recorded.\nYour letter appears to agree that the observed test equipment failure would allow a retest\nunder 180.205(g)(5).\nHowever under 180.205(i), both of these cylinders recorded a permanent expansion\nreading of greater than 1 0% during the first defective test attempt.\nThe question is: Does 180.205(i)(iv) require the condemnation of both cylinders or does\nthe test equipment failure invalidate the first attempt results and allow a prescribed retest\nunder 180.205(g)(5)?\nVice- President\n2090 Tucker Industrial Road * Suite A-6 * Tucker, Georgia 30084\n(770) 934-4449 * (770) 934-9974 *Fax (770) 934-4860\nA DeKalb Fire Protection Service, Inc. Company\n\n<<<PAGE 4>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nCc:\nSubject:\nAttachments:\nBillings, Delmer (PHMSA)\nTuesday, September 11,2012 2:01PM\nDrakeford, Carolyn (PHMSA)\nBetts, Charles (PHMSA)\nFW: Retesting restrictions\nAttachment A pdf; Attachment B. pdf; Attachment C. pdf\nDer k;ndereYJ\n1 ~ • .Go5 lin d-ec.s\n/2.-{)205\nCarolyn,\nPlease log into Filemaker and assign for response.\nThanks.\nDel\nFrom: Betts, Charles (PHMSA)\nSent: Tuesday, September 11, 2012 1:33PM\nTo: Billings, Delmer (PHMSA)\nSubject: Fw: Retesting restrictions\nFyi\nFrom: Woody Andrews [mailto:wandrews@georgiafire.net]\nSent: Tuesday, September 11, 2012 09:42 AM\nTo: Betts, Charles (PHMSA)\nSubject: Retesting restrictions\nUnited States Department of Transportation\nStandards Development\nAttn: Charles Betts\nMr Betts,\nWe would like to request a clarification as to when a cylinder may be retested under 180.205(g)(5) due to equipment\nfailure that results in a recorded failed outcome. Does equipment failure invalidate the results of the initial test or is the\nretest prohibited under 180.205(i)(1 )(iv) (specifically, permanent expansion greater than 1 0%) due to the recorded results\nof the inititial test?\nWe have performed retests on cylinders that on the first test attempt have been pressurized to more than 90% of test\npressure and we have experienced equipment failure. The question is does the first recorded permanent expansion\nreading of greater than 10% prevent us from performing the retest?\nBackground.\nWe operate a Galiso REC4 computerized test machine that performs and records the test function and results\nautomatically.\nThere have been two types of failures that created this delima.\nExample #1: On a 3AA 1800 cylinder at an achieved pressure of 3019 psi, during the test the test equipment fails to\ntransfer volume from the jacket to the weight indicating device, the weight indicating device does not show or shows a\nminimal increase in weight, at the end of the test the weight indicating device shows the same weight. The test is either\naborted by the test equipment or fails at 100% permanent expansion.\nAttachment A sample of results of test and data. (items #8 and 9)\nAttachment B. letter from manufacturer confirming test equipment failure.\nExample #2: A cylinder reaches 90%+ of test pressure during an initial test but has a test adapter to cylinder o ring failure\nduring the test resulting in a greater than 1 0% permanent expansion reading, is a retest allowed on this cylinder when the\no-ring defect is apparent or does 180.205(i)preclude the retest.\n1\n\n<<<PAGE 5>>>\n\nAttachment C. sample of results of test and data. (items #29 and 30)\nOur reasoning is:\nThe results of the first test are invalid because of the equipment failure and the greater than 10% results qo not preclude a\nretest.\nUnder the first example it is obvious to us that a cylinder cannot fail at 1 00% expansion and then pass a retest at 2.9%\nwithout the first set of results being invalid.\nUnder the second example the leakage inside the jacket prevented a correct reading of the volume returned to the jacket.\nThe retest results show a total expansion number and permanent expansion results expected of a 3AA cylinder.\nThank you for your consideration,\nWoody Andrews\nGeorgia Fire Protection\nOffice (770) 934-4449\nFax(770)934-4860\n2","truncated":false,"body_characters":9961}