NK CO., LTD — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Hyun-Joon Ji Assistant Manager Quality Inspection Team NKCO.,LTD 497, Sinpyeong-dong, Saha-gu, Busan 604-030, Korea Ref. No.: 12-0242 Dear Mr. Ji: This is in response to your October 24, 2012 email concerning the requirements for cylinders in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you request confirmation of your understanding of the appropriate lot size for conducting the physical tests on DOT 3AA and DOT 3AAX cylinders. In your letter you describe a scenario in which cylinders are subjected to heat treatment two at a time in a continuous furnace using a conveyor. Specifically you ask if cylinders continuously fed into the heat treatment furnace may be considered the same lot for the purposes of conducting the physical tests in accordance with§ 178.37. Provided each of the cylinders were processed through the same equipment under the same conditions of time and temperature those cylinders may be considered the same lot for the purposes of testing in accordance with§ 178.37. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. ru/v5- . Delmer Billings '4 Senior Regulatory Advisor Standards and Rulemaking Division --- ______ ,_, _______ ... ,_ ... ___ ..... _ .........#

Page 2Leara 3118,3791 Drakeford, Carolyn (PHMSA) 'ulinders Sent: From: hjji@nkcf.com 12-0242 Cc: To: Drakeford, Carolyn (PHMSA) Thursday, October 25, 2012 6:33 AM Subject: [RE]:RE: [RE]:Re: [RE]:Re: [RE]:RE: [FW):RE: A inquire related to DOT Audit at NK-Korea Drakeford, Carolyn (PHMSA) Dear Mr. Charles Betts, Thank you very much for your letter. By the way, I have an additional question as follow : First of all, I would like to explain concretely our heat treatment process for the clearness of a lot size. Our heat treating furnace can heat-treat only two cylinders at a time due to the limit of furnace size. In order to heat-treat more than two cylinders the first 2 cylinders are heat-treated in the furnace and then following 2 cylinders on standby out of the furnace are continuously be entered into the furnace to be heat-treated (continuous furnace type using conveyor). As a result, the heat treatment condition of the first 2 cylinders and the following 2 cylinders is "very similar" not the "100% same" each other. (I believe that the "same heat treatment condition" is possible in the batch furnace type Therfore, could you please let us get your opinion about whether they could be considered or not as a lot (maximum 30) in that case? This is our key point of the question. Best regards, ***************************************************** Direct : +82 (0)51 899 0112 / Fax. +82 (0)51 832 0135 Mobile: +82 (0)10 8382 3533 E-mail : hiji@nkcf.com ************************ ********* • Original Message-- From : <carolyn.drakeford@dot.gov> To : <hiji@nkcf.com> CC : Sent: 2012-10-24 11:53:22 PM Subject : RE: [RE]:Re: [RE]:Re: [RE]:RE: [FW]:RE: A inquire related to DOT Audit at NK-Korea Mr. Hyun-Joon Ji, On behalf of Mr. Charles Betts, Director Office of Pipeline Hazardous Materials Safety, Standards and Rulemaking Division attached is your response to your inquiry below. If you have any additional questions, please do hesitate to contact the Standards and Rulemaking Division at (202) 366-8553. Thank you, 1#