Qantas — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 MAR 0 3 2017 Mr. Neil Smith Cabin Fleet Manager - International & Domestic Fleets Qantas C Wing Level 4 10 Bourke Street Mascot NSW 2020 Australia Reference No. 16-0147 Dear Mr. Smith: This letter is in response to your September 7, 2016, email and subsequent conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification requirements in§ 180.209(b)(l) for a specification DOT 3AA cylinder. Specifically, you state that your company uses DOT 3AA cylinders filled exclusively with oxygen. Based on your company practices, the cylinders are routinely refilled before the pressure falls below 50 psi and are requalified every 10 years instead of 5 years in accordance with§ 180.209(b)(l). You also reference the July 26, 2016 Notice of Proposed Rulemaking (NPRM) titled, "Hazardous Materials: Miscellaneous Amendments Pertaining to DOT Specification Cylinders (RRR)" [HM-234; 81 FR 48977], which proposes to amend some of the requalification requirements in § 180.209(b ). We have paraphrased and answered your questions as follows: Q 1. You ask if a DOT 3AA cylinder is subject to the hammer test requirement in § 180.209(b)(l)(iii) at the time ofrefill. You note that your company interprets the meaning of "refill" as it applies to § 180.209(b) as filling an oxygen cylinder when it contains less than 50 psi. Al. The answer is yes. If your company wishes to requalify a DOT 3AA cylinder every 10 years instead of every 5 years, as outlined in § 180.209(b )(1 ), the cylinder must meet all applicable requirements, including the hammer test, prior to being refilled. The HMR is silent on the definition of "refill" for this exception, but generally "refill" has meant the filling of a cylinder regardless of the pressure at the time of refill. As it is currently written in the HMR and as a condition to allow a 10-year requalification period instead of a 5-year period, the cylinder must pass the hammer test in accordance with CGA C-6 before each refill. The test protocol calls for the cylinder to be empty prior to performing the hammer test. For the purposes of the HMR, a cylinder containing a permanent Division 2.2 gas is empty when the pressure is less than 29.0 psig at 20 °C.#

Page 2Q2. A2. Q3. A3. Q4. A4. You ask if an internal inspection is required each time you refill a DOT 3AA cylinder. The answer is no. There is no regulatory requirement to conduct an internal inspection each time a cylinder is refilled. However, there is a requirement to internally inspect a DOT 3AA cylinder at the time of requalification. Specifically, § 180.205(f)(l) requires that a steel cylinder be visually inspected in accordance with CGA C-6, which requires an internal inspection be conducted each time a cylinder is requalified or if the cylinder fails the hammer test. Please note that ifthe cylinder is subject to the hammer test at the time of refill, such as is required in§ 180.209(b)(l), failure of the hammer test may present conditions rendering the cylinder unsafe and subject to testing and inspection in accordance with § 180.205(d)(l). You ask if it was PHMSA's intention in the HM-234 NPRM [81 FR 48977] to remove the authorization to requalify a DOT 3AA cylinder every 10 years. Specifically, you reference the table in§ 180.209(a), which proposes to list a 5- or 12-year requalification period for a DOT 3AA cylinder. The answer is no. The§ 180.209(a) table should specify a 5-, 10-, or 12-year requalification period for a DOT 3AA cylinder. This was an inadvertent error and will be amended in the publication of the final rule. You ask if it was PHMSA's intention in the HM-234 NPRM to restrict those cylinders removed from aircraft from the 10-year requalification period exception as outlined in § 180.209(b )(1 ). The answer is no. It is not PHMSA's intention to restrict cylinders removed from aircraft from the 10-year requalification in § 180.209(b ). This will be addressed in the final rule. I hope this information is helpful. Please contact us if we can be of further assistance. Si:~~l~y , // .. /· - ,, .!/ irk De · nde en Chief, Standard Development Branch Standards and Rulemaking Division#

Page 3Goodall, Shante CTR (PHMSA) From: Sent: To: Attachments: Importance: Betts, Charles (PHMSA) Wednesday, September 07, 2016 9:46 AM Goodall, Shante CTR (PHMSA) image2016-09-07-092814.pdf High Please log and assign to a specialist for response. Please treat this for expedited handling. Thanks, Charles 1#

Page 4[)ear Mr Betts Please find attached a letter requesting clarification on CFR 180. 209. Yours sincerl y \ ,,.,q,..,. ··w~ . t~ ... , .... ,~ Neil Smith Cabin Fleet Manager -International & Domes tic Fleets Engineering Services I Qantas Airways Umited Address C Wing Level 4, 10 Bourke Street, Mascot NSW 2020 Aust ralia Phone +61 2 9691 0548 I Mobile +61402 38 65 69 I Email: ne i l. smith@.MD!~.H9fll·au#

Page 5~QANTAS Facsimile Transmission From ~ Fa x Numbm 001112023665713 Fax Number Email > company Company ~> Ad d ress Address i> Telephone Telephone t> Total number of pages inclusive of this Sheet 8 Date 07.09.16 •Confidentiality. Tho? 1nformnnc.n corta1ned 1n th.1?58 1jc..:um>?nt; is i:c·n!rd·:r.ua! and s in t ~nljed tor .;i ~ · clu:ue ust- vi the adrJr~~SO:-!? na;n-?1J a:.:io·;~ 11 :.:rt-Jn :as-s-s 111s .:!lsr:· !-:9211·1 ;nqlo.:~-:-d l' vou ar'!? n.)'. tn.a ad•jresst-t-. any disc!i)sur-:: r~pr..:du.:t;.:.•n. d1s t roun1.~n u (!htir J;ssi:m1n t10n er JS~ c~ :r 1s ccrnrr.v' ct::t1·:.-n s s:rct!j pr ... r-1t1t~c If you !"£!\·-:-re·.<::1\~·: m1; ~Subject FAD: Mr Charles Betts Clarification of CFR 180.209 Qantas Airways Limited ACN 009 661 90 1#

Page 6Qantas Engineering._ Charles Betts Director Standards and Rulemaking Department of Transport By Fax: +1 202 366 7435 Neil Smith Cabin Fleet Manager Engineering Services Qantas Airways Limited Address C Wing Level 4 1 O Bourke Street Mascot NSW 2020 Australia 7 September 2016 Dear Mr Betts, I wish to seek clarification of Qantas Airways' understanding of the existing regulation and NPRM of 49 CFR 180.209 per PHMSA-2011-0140 (HM-234). Qantas operates cylinders that are manufactured to the DOT 3AA specification (ref Figure1), they are used exclusively for oxygen, have a capacity of 11cu foot and manufactured by Avox Systems Inc. These cylinders are maintained under an approved System of Maintenance, to a vendor supplied, Component Maintenance Manual, CMM 35-31-55. When we have viewed the proposed changes in the NPRM, Qantas reassessed the maintenance of these cylinders and wanted to confirm our understanding of this requirement, especially for the hammer test and requirements for a 10years interval between Hydrostatic Test. The CMM refers to DOT requirements per 49 CFR180.209 to determine the additional conditions required to certify the cylinders to 10years (nominally 5years) between Hydrostatic Test (HT). Cylinders conforming to these additional criteria are identified with a star shaped stamp. The 1 Oyear option has been chosen by Qantas. Figure 1 - Typical oxygen cylinder with 3AA DOT marking One of the requirements per 49 CFR180.209 (b) (iii) is Before each refill. the cylinder is removed from any cluster, bank, group, rack or vehicle and passes the hammer test specified in CGA Pamphlet C-6 (I BR, see §171 .7 of this subchapter). ···-··-······-······ ······················· · ·· ~---- -------------.. -- __...,, .. ~ . .-. .. ' • Qantas Airways Limited ABN 1 6 009 661 9C l qantas.com#

Page 7Qantas Engineering._ The referenced CGA (Compressed Gas Associated) C-6 document shows the requirements of the Hammer Test. 6.2 Hammer test The hammer test is a valuable indicator or internal corrosion and is a convenient test that can be made without . removing the valve before each charging or the cylinder. The hammer test should be perfom1ed on empty un- pressurized cylinders. The hammer test consists of tapping lhe cylinder sidewall with a light blow using a 112 lb (0.23 kg) ball-peen hammer or equivalent. A cylinder will normally have a clear ring. A dull ring would indicate internal eorrosion, : liquid, or accumulation of foreign material in the cylinder. Such cylinders shall be inspected internally In accor- . dance with 6.4 . . NOTE-The hammer test Is not 11prlir.Rh1A on ;;il11min11rn r.ylinrlf.lrs . ..... .. .. . ······· ............ .............. . If fails hammer test I or in doubt, inspect per 6.4 6.4 Internal Inspection Cylinders shall be inspected internally at least every time the cylinder is periodically retested, or when they fail the hammer test before filling, or when there is reason to believe that there is internal contamination, or corro· sion. 6.4.1 Preparation for inspection The Interior of cylinders shall be prepared for inspection by removing dirt, scale, or other condition as neces- sary to permit the inspection of the internal surface. Cylinders with interior coating shall be examined for de- fects in the coating. If the coaling is defective, it shall be removed. A goo· d inspection light of sufficient intensity to clearly illuminate interior walls is mandatory for internal inspec- tion. Cylinders containing hazardous materials shalt be purged to remove residual gas or liquid before being examined with a light. • Qantas Airways Limited ,< 3 N 1 6 '.J09 661 901 qantas.com#

Page 8- - - · -- ·-----·u ------·--Z!' ._ ... Qantas Engineering .. . Within Qantas we complete the requirements per the vendor CMM, which aligns with CGA 6.4. 1. B. DOT-3AA·1800 Steel Cylinder (Refer to 500 thru 5000, IPL Fig. 1; 500 thru SOOA, IPL Fig. 1 B). (1) Look at the last and inillal cylinder hydrostalic test dates found on the cylinder crown, near the cylinder neck. Hydrostatic tests must be performed as noted In Table 5003 using appro11ed procedures by service locations ha11ing up-to-date United States Department of Transportation approval. Additional hydrostatic tests may be required in your country. (2) DOT·3AA·1600 steel cylinder service-life is given in Table 5003. ( t) Do a dleck of the cylinder surfaces for either heal or fire damage. (2) Do a check of the cylinder for dents, gouges, digs or bulges. NOTE: It may be necessary to remove any heavy paint coatings from the exterior surface of the • ~y fi ndt:r t~· : cc::«:-<:t1y cht: \~ ~~r ~1ents , 9;.. ·;t.:g<!r :; , C:g~~ ·':; f ~ ul~ $. (3) Make sure that identification plates and waming labels can be read and are not damaged. (4) Do a check of the cylinder neck tor craci<s, distortion, contamination or thread damage. (5) Put a Bright Inspection Light (Table 5002) inside the cylinder and do a check for contamination and corroded surfaces. (8) Make sure the inside of the cylinder does not have an odor. Furthermore, the Bright Light Inspection ensures that there is NO corrosion/contamination and is completed at each Hydrostatic Test (currently every 10years) and when a regulator is overhauled (every 5years) and when the cylinder is returned to the workshop with less than 50PSI. The Hammer Test 1 s part of the qualification to 10years. it is not required for qualification to 5years per the existing regulation. The Qantas interpretation of the term, refill, is the filling of the oxygen cylinder when the cylinder has less than 50PSI. Empty to full- refill. The term 'top up' is used when oxygen is added between 26PSI and 1 BOOPSI. Qantas typically uses the 50PSI for our in-service criteria and 26PSI for new cylinder deliveries, with reference to the document below: From OEM (Original Equipment Manufacturer) documentation The OEM, Avox, describes in SIL-35- 126 NEW US DEPARTMENT OF TRANSPORTATION (US DOT) RULE HM224B FOR AIR SHIPMENT OF CHEMICAL OXYGEN GENERA TORS AND CYLINDER ASSEMBLIES THAT CONTAIN COMPRESSED OXYGEN INTO AND WITHIN THE US, that when a partially filled bottle is received, than it is to be charged There is NO indication in this documentation for a further Hammer Test prior to charging the cylinder; steps as follows: • Qantas Airways Limited ABN 16 009 661 901 qantas.com#

Page 9Qantas Engineering._ ( 4) After arrival at destination (a) Charge the cylinder assembly to full operating pressure before placing into service. (b) Remove the shipping tag (PIN 10015660; see Figure 3) from the neck of the cylinder. (c) Verify that the cylinder is charged to full operating pressure. (d) Check the cylinder assembly for leaks. (e) Issue an EASA Form 1 or equivalent as required. m Add statement to block 13 on the EASA Form 1 or equivalent stating that service was performed in accordance with the CMM and the SIL. (g) Add in block 12 of the EASA Form 1 or equivalent "Inspected/Tested. " (h) Sign on the right side in block 20. (j) Install in aircraft or place in stores ready for service. The NPRM for the revision of 49 CFR 180.209 removes the requirement for the Hammer Test. This is in part due to the Hammer Test noi being an effective tool to determine corrosion and there is NO control of the filling operation, post qualifying the cylinder, extract below . . . .. . .. . . . .. . .. . .. .. . . . . ·;: ::- ;.::::: :; :;; : : : :: ::; : : : : ~ ;.; ::; ;; :- :::: :; :;:: ~-.' o.e.tell: Bcfors e11 d1 r • ! 1l l ' ~·' . · .......... ............ ..................... ..... .-.... ·· -·: . . · ~: rCJ"10v crdir 01n . .......................... ,, ... j :::-&;~):1 : >;::1 :·-: :.:v-! ;. : :~:. : : ~#·. :.•.:.:.· '.::-.:: s .; .~:~ 4! ~Y. J ::: ~ .. ~,~ . : ('~#~ ;: :-.~$. c ~ ! ~!);~ . S'·) .. ~ '. . .:.·.: : ::. .. ~.·1 -:.~ ::.· •n v -J>..lv.-~·~: <. .-. ~ · Rational for submitred changes to 49 CFR J 80.200 - 215 180.209 (b)(l)(ii) Removed hammer test. I have never heard of a single cylinder being condemned for corrosion that was detected by the hanuner test. Furthennorc, no one is disassembling banks of cylinders in order to do the hammer lest "each time it is filled". And more importantly, that is a fill operation, not part of the requalification. It is more appropriate to simply disallow these applications from the 10 year test. Added "cascade" ' · · .. ) .,, .. ) .\ .. ..... , .~ ~~ -;- . ..,...,..,. ,,, ... . ... ~. ;;.;,.. ................ ....... ....... .... .. .. ... .. ... ... . The last sentence above is significant, as the qualification to 10years should not be subject to a 'fill operation' that the qualification has no control over. The NPRM is written to remove these cylinders as candidates for 1 Oyear interval between HT. The NPRM in 49 CFR 180.209 (a) Periodic qualification of cylinder for DOT 3A, 3AA has removed the option for 10years, giving a 5 or 12year option. ~equ . .:ii; ~ . .-~:i~ ; p psr . .::·IJ ~,.~~i::;ur~ h:-<:~ pr~:;~· t :rn ::p:~:,.~i I 1. ~· f ~;;:: SJ .! G~:r; :'.: :'Y;} ... . . ..... . S/'3 ~i : :i -r ,:; fc~:·\::r6 µ:(' ;~:l:..tQ , tl~!:~p: r:n::r;~".·tr~· !.. 5~· '.':? ~~-~ry': ~ ~ . ! ~~ ~ :,t:;1 ~\:~f l~ . :} .. • Qantas Airways Limited /1 n ~i 1 & OO'! 66. ~J· qantas.com#

Page 10~ QANTAS However, in 49 CFR 180.209 (b) There remains requirements to meet a 1 Oyear requalification 1 o years instead of every 5 ars provided e cylinder conforms to all of the 1 conditions: In 49 CFR 180.209(ii) the requirement is for the "cylinder not used in any cascade, bank, group, rack or vehicle." The existing requirement for 49 CFR 180.209 b(iii) "the cylinder is removed from any cluster, bank, group, rack or vehicle". Qantas has understood this to advise that the cylinder is removed from its location and filled away from its installation. Many of the cylinders Qantas have installed are single cylinders and we also note that the DOT differentiates between vehicles and aircraft in other rules but the term aircraft is not mentioned in 49 CFR180.209 b(iii). Qantas conducts an internal examination of the cylinder with a bright light, which is a superior inspection for corrosion than the hammer test. If the understanding above is correct, we would consider that Qantas can remain certifying the 3AA cylinders to 1 Oyears. Could the DOT please clarify the option to requalify cylinders to 1 Oyears and confirm that a bright light corrosion inspection is required only at re-fill (lower than 50PSI) not 'top-up'. If possible Qantas would like to arrange a telecon, at your convenience, to discuss this topic with your representative(s). Yours sin Neil Smith Cabin Fleet Manager - International & Domestic Fleets Engineering Services Qantas Airways Limited Phone +61 2 9691 0548 I Mobile +61 402 38 65 69 I Email: neil.smith@qantas.com.au • Qantas Airways Limited ABN 16 009 661 901 qantas.com#