O.K.
I give this hydro guy a lot of credit for being the only one I know of who does the 10% overfill calcs for the plus rating on my steel 72s, but now I have a problem.
The story:
I have a steel 72 with a 1/2" NPT opening which has an internal lining. The tank is beautiful- clean galvanizing, no boot marks or corrosion, the liner looks beautifully solid and shiny with no discoloration at all. I took the cylinder to a LDS to have it sent in for liner removal and hydro. That was two months ago.
I called the LDS to find out what the status was on my tank, and the hydro guy returned my call. He said that he couldn't hydro the cylinder because he was unable to complete the inspection of the cylinder because of the lining. He said that he is unable to remove liners through a 1/2" NPT opening. He also said that no one can. So, he said, the tank was condemned and put in the scrap pile.
I never stated that I would relinquish ownership of the cylinder for any reason, nor did I sign any waiver.
I have reread the applicable parts of CFR 49, and cannot find where there is a legal basis for confiscation.
------------------------------------------------------
His reasoning:
He was required to "remove from service" the cylinder (which, I understand, he believes means confiscation for destruction) because it failed visual (i.e. has an liner which neither he, nor anybody, else is supposedly able to remove).
------------------------------------------------------
My reasoning:
a) The cylinder didn't "fail" visual because (as he said) a visual could not be performed.
(CFR49, Sec.180.205,(f),(2): "(2) For each cylinder with a coating or attachments that would inhibit inspection
of the cylinder, the coating or attachments must be removed before performing the visual inspection.",
and CFR49, Sec.180.205,(f),(3): "Each cylinder subject to visual inspection must be approved, rejected, or condemned according to the criteria in the applicable CGA pamphlet.") (Note: The "applicable CGA pamphlet" would be C-6, which carries a $156 price tag- give me a break! Nothing like keeping us in the dark.)
b) The cylinder remains the property of the owner as acknowledged by the wording of the regulations.
(CFR49, Sec.180.205,(i),(2),(iii): "As an alternative to the stamping or labeling as described in this paragraph (i)(2), at the direction of the owner, the requalifier may render the cylinder incapable of holding pressure.",
and CFR49, Sec.180.205,(i),(3): "No person may remove or obliterate the "CONDEMNED" marking. In addition, the requalifier must notify the cylinder owner, in writing, that the cylinder is condemned and may not be filled with hazardous material and offered for transportation in commerce where use of a specification packaging is required.")
Neither of these make any sense if the object was to confiscate the cylinder for scrapping.
--------------------------------------------------
Questions:
1) Has anyone had a liner removed from a cylinder having a 1/2" NPT opening?
2) Is there anything in CGA C-6 which would specify rejection or condemnation of a cylinder due to the presence of a liner, or is it assumed the liner would be removed before a visual could be performed?
(CFR49, Sec.180.205,(f),(1): "The visual inspection must be performed in accordance with the following CGA Pamphlets: C-6 for steel and nickel cylinders (incorporated by reference; see § 171.7 of this subchapter);...")
I don't have a copy of CGA C-6, and I see the CGA charges $156 for a copy. I cannot find any web site showing the document.
3) Am I missing something?
Thankyou in advance.
I give this hydro guy a lot of credit for being the only one I know of who does the 10% overfill calcs for the plus rating on my steel 72s, but now I have a problem.
The story:
I have a steel 72 with a 1/2" NPT opening which has an internal lining. The tank is beautiful- clean galvanizing, no boot marks or corrosion, the liner looks beautifully solid and shiny with no discoloration at all. I took the cylinder to a LDS to have it sent in for liner removal and hydro. That was two months ago.
I called the LDS to find out what the status was on my tank, and the hydro guy returned my call. He said that he couldn't hydro the cylinder because he was unable to complete the inspection of the cylinder because of the lining. He said that he is unable to remove liners through a 1/2" NPT opening. He also said that no one can. So, he said, the tank was condemned and put in the scrap pile.
I never stated that I would relinquish ownership of the cylinder for any reason, nor did I sign any waiver.
I have reread the applicable parts of CFR 49, and cannot find where there is a legal basis for confiscation.
------------------------------------------------------
His reasoning:
He was required to "remove from service" the cylinder (which, I understand, he believes means confiscation for destruction) because it failed visual (i.e. has an liner which neither he, nor anybody, else is supposedly able to remove).
------------------------------------------------------
My reasoning:
a) The cylinder didn't "fail" visual because (as he said) a visual could not be performed.
(CFR49, Sec.180.205,(f),(2): "(2) For each cylinder with a coating or attachments that would inhibit inspection
of the cylinder, the coating or attachments must be removed before performing the visual inspection.",
and CFR49, Sec.180.205,(f),(3): "Each cylinder subject to visual inspection must be approved, rejected, or condemned according to the criteria in the applicable CGA pamphlet.") (Note: The "applicable CGA pamphlet" would be C-6, which carries a $156 price tag- give me a break! Nothing like keeping us in the dark.)
b) The cylinder remains the property of the owner as acknowledged by the wording of the regulations.
(CFR49, Sec.180.205,(i),(2),(iii): "As an alternative to the stamping or labeling as described in this paragraph (i)(2), at the direction of the owner, the requalifier may render the cylinder incapable of holding pressure.",
and CFR49, Sec.180.205,(i),(3): "No person may remove or obliterate the "CONDEMNED" marking. In addition, the requalifier must notify the cylinder owner, in writing, that the cylinder is condemned and may not be filled with hazardous material and offered for transportation in commerce where use of a specification packaging is required.")
Neither of these make any sense if the object was to confiscate the cylinder for scrapping.
--------------------------------------------------
Questions:
1) Has anyone had a liner removed from a cylinder having a 1/2" NPT opening?
2) Is there anything in CGA C-6 which would specify rejection or condemnation of a cylinder due to the presence of a liner, or is it assumed the liner would be removed before a visual could be performed?
(CFR49, Sec.180.205,(f),(1): "The visual inspection must be performed in accordance with the following CGA Pamphlets: C-6 for steel and nickel cylinders (incorporated by reference; see § 171.7 of this subchapter);...")
I don't have a copy of CGA C-6, and I see the CGA charges $156 for a copy. I cannot find any web site showing the document.
3) Am I missing something?
Thankyou in advance.
).
