{"operation":"document","citation":"13-0042","title":"City Machine and Welding, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-05-22","effective_on":null,"summary":"13-0042 response to City Machine and Welding, Inc. concerning 173.302a, 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0042.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0042.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0042","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130042.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMAY 2 22013\nMr. Kent Carroll\nCity Machine and Welding, Inc.\nP.O. Box 51018\nAmarillo, TX 79159\nRef. No.: 13-0042\nDear Mr. Carroll:\nThis is in response to your February 7, 2013 email requesting clarification ofthe requirements for\nthe marking of a plus(+) sign on DOT 3A, 3AX, 3AA, 3AAX, and 3T cylinders as specified in\n§ 173.302a(b) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically, you ask if a cylinder that passed the permanent expansion requirement, but exceeded\nthe elastic expansion rejection limit (REE) may be returned to service (1) at the same or a lower\nservice pressure or (2) 10 % in excess of its marked service pressure.\nThe + sign is added following the test date marking on a cylinder to indicate that a cylinder\ncomplies with§ 173.302a(b) and is permitted to be filled to a pressure 10% in excess of its\nmarked service pressure. All of the conditions in§ 173.302a(b) must be met, including\ncompliance with either the average wall stress or the maximum wall stress limitations shown in\n§ 173.302a(b)(3).\nIf a cylinder has less than 10 % permanent expansion as demonstrated by the volumetric\nexpansion test(§ 180.205(i)(l )(iv)), but fails the REE examination, the+ sign may not be marked\non the cylinder after the requalification test date marking since the cylinder did not comply with\nthe average wall stress requirement. In this case, the cylinder may be returned to service at its\nmarked service pressure. As specified in§ 180.205(c)(3), for DOT specification cylinders, the\nmarked service pressure may only be changed upon approval from the Associate Administrator for\nHazardous Materials Safety and in accordance with written procedures specified in that approval.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\n[[~· .\nDelmer Billings ~\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n.E,rakeford, Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA)\nSent:\nTo:\nSubject: Friday, February 08, 2013 2:08 PM\nDrakeford, Carolyn (PHMSA)\nFW: Cylinder service pressure change\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Kent carroll [mailto:kcarroll@cmwelding.com]\nSent: Thursday, February 07, 2013 5:54 PM\nTo: INFOCNTR (PHMSA)\nSubject: Cylinder service pressure change\nMr. Betts,\nWe are a requalification facility (RIN 8620) and as part of re-affirmation of our current process, we would like\nto seek interpretation with regards to disposition of a cylinder which has passed the permanent expansion\nrequirements but failed the elastic expansion rejection limit.\nThe chain of references & cross references is listed below for convenience.\n• As part ofhydrostatic testing of3T ,3A, 3AA & 3AAX cylinders, we follow 49 CFR 180.205 and\n180.205 (c) (3) for service pressure changes.\n• 180.205 requires complying with relevant sections of part 173 & part 178.\n• 49CFR 173.302a, references CGA Pamphlet C5\n• 49CFR 171.7 lists CGA pamphlet C5 -1991 edition as referenced version in CFR.\n• CGA pamphlet CS under appendix A has a flow chart for service life control.\n• For the scenario of a cylinder passing the permanent expansion requirements but failing the elastic\nexpansion rejection limit, the flow chart references Section 2.5\n• Section 2.5 refers to Section 2.2\nThe point we would like to confirm is that in the scenario stated earlier, we can ultrasonically measure the wall\nthickness per the cylinder manufacturer's supplied procedure for the purposes of returning the cylinder back in\nservice with a lower service pressure\na) b) same as marked service pressure or a lower pressure\n10% in excess of marked service pressure.\nThanking you in anticipation .\nBest regards,\nKent Carroll\nCity Machine & Welding, Inc.\n1\n\n<<<PAGE 3>>>\n\n(806)358-7293 phone\n(806)358-7906 fax\nkcarroll@cmwelding.com\nThis e-mail, including any attachments, is intended solely for the person or entity to which it is addressed and may contain confidential, proprietary and/or non-public\nmaterial. Except as stated above, any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or\nentities other than an intended recipient is prohibited. If you receive this in error, please so notify the sender and delete the material from any media and destroy any\nprintouts or copies.\nNo virus found in this incoming message.\nChecked by AVG- www.avg.com\nVersion: 9.0.932 I Virus Database: 2639.1.1/5587- Release Date: 02/07/13 01:37:00\n2","truncated":false,"body_characters":4708}