12-Year Cylinder Requalification Proposed by PHMSA

(August 20, 2019) — The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has published a notice of proposed rulemaking calling for a return to a 12-year cylinder requalification period after hydrostatic, aka volumetric expansion, testing, reports the National Propane Gas Association (NPGA).

The proposal is in response to a petition from the association to return to the 12-year requalification period following a hydrostatic test. NPGA submitted the petition after PHMSA changed 49 CFR 180.209(e), reducing the initial requalification period for DOT cylinders from 12 to 10 years. The association comments that “nowhere in that rulemaking process did PHMSA address the changes in any form or provide any rationale or substantiation for the changes.”

The 10-year requalification period following hydrostatic testing took effect in January 2017, but after aggressive pursuit by NPGA, PHMSA released an enforcement notice in March 2017. The notice stated the agency would not take enforcement action against the requalification of DOT-specification cylinders under the 12-year requalification. Instead, the enforcement notice permitted either a 10- or 12-year requalification period. NPGA points out the enforcement notice remains in effect until PHMSA’s latest rulemaking is finalized, which is not the case to date. A copy of the enforcement notice is available on the NPGA website under the Member Dashboard.

Further, in its previous rulemaking, PHMSA also changed the requalification period following a proof pressure test from seven to 10 years, NPGA reviews. And in its latest proposal the agency suggests allowing the proof pressure requalification to remain at 10 years. It also proposes several changes to tables in the regulations in order that they reflect more clearly the requirements in the regulatory language.

(SOURCE: The Weekly Propane Newsletter, August 19, 2019)