HSB Technical Consulting & Service (Shanghai) 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 MAY 0 8 2014 Mr. Ruifeng Yin Authorized Inspector HSB Technical Consulting & Service (Shanghai) Co., Ltd. Room 909, Tower A, Fareast Int'l Plaza 319 Xianxia Road, Shanghai, 200051, China Ref. No.: 14-0074 Dear Mr. Ruifeng Yin: This is in response to your email dated April 6, 2014, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the § 178.45(i)(2) requirements for tension and Charpy impact testing of production cylinders. You request confirmation of your understanding that there are two options for cylinders heat treated in a continuous furnace: 1) tests must be conducted on two tension specimens and three Charpy impact specimens from one cylinder taken from a test lot based on a production period not exceeding 200 cylinders; or 2) tests must be conducted on two tension specimens and three Charpy specimens from a test ring for each four hours or less of production, provided the test lot based on the production period does not exceed 200 cylinders. You are correct. If the required specimens are obtained from a cylinder, the cylinder must be from a test lot based on a production period of not more than 200 cylinders. If the required specimens are obtained from a test ring, each test ring must represent a production time of four hours or less and the test lot based on the production period must not exceed 200 cylinders. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Shane C. Kelley 1 Acting International St · dards Coordinator Standards and Rulemaking Division#

Page 2Drakeford, Carol n PHMSA) From: Sent: To: Cc: Subject: Yin Ruifeng - APAC-Remote-HSBCT <ruifeng_yin@hsbct.com> Sunday, April 06, 2014 11:49 PM INFOCNTR (PHMSA); Drakeford, Carolyn (PHMSA); Lynch, Tom (PHMSA); Wayne. Chaney@dot. gov *$BI Question about 178.45 (i)(2) interpretation ~ ,·ndef:r IL-l PD01t-j Dear all This is DOT inspector (Mr. Ruifeng Yin) come from HSBCT. My costumer is Shijiazhuang Enric gas equipment co; ltd. The question is 178.45(i)(2) said When the cylinders are heat treated in a continuous furnace, two tension specimens and three Charpy impact specimens must be tested from one of the cylinders or a test ring from each four hours or less of production. However, in no case may a test lot based on this production period exceed 200 cylinders. My understanding: there has two options (1) The test is required on 2 specimens and three Charpy impact specimens cut from 1 cylinder taken at random out of each lot of 200 or less. (2) two tension specimens and three Charpy impact specimens must be tested from a test ring from each four hours or less of production, in no case may a test lot based on this production period exceed 200 cylinders. Could you tell me my understanding is right or wrong? Ruifeng Yin Authorized Inspector HSB Technical Consulting & Service (Shanghai) Co., Ltd. l!SB Wnh;tl Slamtunf;; ROOM 909, TOWER A, FAREAST INT'L PLAZA 319 XIANXIA ROAD, SHANGHAI200051, CHINA C:86-15930159237 F: 86-21-6235-1972 !'10NYL.IJ§J?9!QI;>£JJ§t13J!.99r~t§,.£Qt:n IMPORTANT NOTICE: The information in this email (and any attachments hereto) is confidential. If you are not the intended recipient, you must not use or disseminate the information. If you have received this email in error, please immediately notify me by "Reply" command and permanently delete the original and any copies or printouts thereof. Although this email and any attachments are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Global Standards, LLC or its subsidiaries or affiliates either jointly or severally, for any loss or damage arising in any way from its use. 1#

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