From: John De Armond
Newsgroups: rec.outdoors.rv-travel,alt.rv
Subject: Re: Propane tank upgrade
Date: Thu, 04 Oct 2001 18:13:52 -0400

Phil Sinewe wrote:
>
> "Hugh" <hughbd1@earthlink.net> wrote in message
> news:3BBC6FCD.7B79F00F@earthlink.net...
> > Phil Sinewe wrote:
> > >
> > > > That's just not so!  A certified propane dealer can install the
> > > > new OPD valve and certify the tank for 5 years.
> > > > 
> > > > Actually, that's not how we (Ohio Fire Department) read the code.
> > > > The tank is always good for its original 12 years.  The 12 year
> > > > issue with a tank is
> > snipped
> >
> > Must be your reading the code wrong Phil. I understand, if
> > the valve is replaced, the tank gets recertified, for five
> > years. Doesn't matter if the tank is brand new. That's from
> > a propane dealer in our area and I got the same story from
> > every other propane dealer I called.
>
> Well, one of us is wrong.

Actually all of you are.

> My opinion, if you have a dealer that wants to stamp a shorter life on the
> tank, find another dealer before he ruins the tank.  Once he stamps the
> date, then the tank is trash on that date.
>
> However, The National Propane Gas Association said they would double check
> and send me an e-mail.  As soon as I get it, I will forward it.

Wrong.  Neither the CGA, the NPGA, the NFPA nor any other private
entity writes the regulations and none of those documents have the
force of law. You'd know that if you read the introduction to any
NFPA. DOT writes the regs in the case of propane cylinders.  Things
like the NFPA can be incorporated by reference but in this case they
are not.

The regulations governing DOT 4b (gas grill type. How did I know? I
walked out and looked at the neck ring markings! Duh!) tanks is
49CFR173.  The relevant part of 173 can conveniently located here:

http://frwebgate3.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=23269330020+1+0+0&WAISaction=retrieve

Because this server is very slow, I have conveniently clipped the
relevant text on hydrostatic testing.

*******

(i) A DOT specification 4B, 4BA, 4B240ET or 4BW (Secs. 178.50, 178.51,
178.55 and 178.61 of this subchapter) cylinder may be retested as
follows:
    (A) For a cylinder with a water capacity of 12 pounds or less by
hydrostatic test using the water jacket method or by hydrostatic test
without determination of expansion (modified hydrostatic test method). A
retest must be performed 12 years after the original test date and at
12-year intervals thereafter.
    (B) For a cylinder having a water capacity over 12 pounds--
    (1) By hydrostatic test without determination of expansion (modified
hydrostatic test method). A retest must be performed 12 years after the
original test date and at 7-year intervals; or
    (2) By hydrostatic test using the water jacket method. A retest must
be performed 12 years after the original test date and at 12-year
intervals thereafter.

**********

You will notice that a tank must be hydrostatically tested after 12
years and then retested either every 7 or 12 years depending on the
technique used. You'll notice that there is no mention of the type
valve fitted.  That is because it is irrelevant to the hydro test
regulation. THERE IS NO EXPIRATION DATE ON A PROPANE CYLINDER!  A
cylinder made in 1950 may still be used if it passes hydro.

----------

It has been entertaining watching everyone shoot from the ass.  Even
with the slow and clunky government servers at gpo.gov, it took me
less than 5 minutes to find this regulation.  I guess for some folks
it's easier to guess than to know.

John

From: John De Armond
Newsgroups: rec.outdoors.rv-travel,alt.rv
Subject: Re: Propane tank upgrade
Date: Thu, 04 Oct 2001 22:01:52 -0400

tom J wrote:

> Just as it is easy for you to quote part of the regulations and not quote
> all the regulations.  If you had kept looking, you would have found the
> visual exception for propane tanks that can be done every 5 years as I
> stated several post ago.  I stand by my original post as being accurate.
> John, I have no bone to pick with you, but this time you didn't give the
> complete picture.  See below:
>
> Regulations:
> ******************************
> (13) A cylinder made in conformance with a specification - exceptions
>
> listed in the table in this paragraph (e)(13) and used exclusively in the
> service indicated may,

If you'd gone ahead and picked up ALL of paragraph 13 including the
(un-legened) table on page 405 of the printed/PDF version of the
reg, you'd see that the "visual hydro" exception is authorized only
for "Liquefied petroleum gas which is commercially free from
corroding components"  and further conditioned (para 11) that the
cylinder be externally protected by a corrosion-resistant coating
such as painting and galvanizing.

Commercial fuel gas propane is NOT known to be "commercially free
from corroding components".  It is frequently wet and may contain
acidic compounds from the refinery or ammonia from
cross-contamination from (now illegal) use of propane transport
equipment for anhydrous ammonia.  The corrosion resistant coating
requirement implies an intact coating.  Paint is no longer intact
once it is scratched or abraded.

So, as is typical for federal regulations, they are confusing,
conflicting and impossible to apply in the real world.  This is
where regulatory guidance comes into play.  When I received my
propane dealer's license, I attended the state fire marshal's
"college of propane knowledge" where I received such guidance.
According to the fire marshal, it was acceptable to perform a
"visual hydro" after 5 years and then do a real hydro 5 years
later.  That would get the cylinder a real hydro every 10 years (the
retest interval back then) while having it visually inspected for
gross damage every 5 years. Other states may do it differently but
that's the way it is in TN.

IMHO, this whole visual hydro regulation is just more BS from a
government that knows there is no real need to test these cylinders
but won't retract their bureaucratic claws.

BTW, Tom, the reason I didn't mention the 5 year visual hydro is
because it was irrelevant to refuting Phil's claim that a tank
expires and becomes trash after one 12 year hydro cycle, which was
the purpose of my post.

John

From: John De Armond
Newsgroups: rec.outdoors.rv-travel
Subject: Re: Propane tanks again..
Date: Fri, 05 Oct 2001 02:10:54 -0400

Hugh wrote:

> Let's try this again, without all the extra "stuff". Dealer
> tells me I can buy new tanks with the OPD valves. Or, I can
> bring my old tanks in and have OPD valves installed. Or, I
> can exchange my old tanks for refurbished tanks.
>
> If I get my valves replaced, I get my tanks back with "new"
> 5 year certification. If I exchange my tanks for
> refurbished, I get 5 year certification. No mention is made
> of any service life restriction. At the end of 5 year
> period, I get my tanks recertified for 5 more years.

What you get back will depend on whether the dealer does a "visual"
or a real hydro.  If he does a real hydro with expansion measurement
you get a 12 year interval.  If he does a hydro without expansion
measurement, you get a 7 year interval.  If he does a visual you get
a 5 year interval.  This is all spelled out in 49CFR173(11) and (13)

What the dealer does will depend on his economics and and his
state.  Here in TN there is strong pressure from the fire marshal to
do full hydro tests.  A dealer who does a lot of cylinder exchange
business will also have an incentive to go for the extended
interval.  I know for a fact that at least two of our local dealers
do full hydros and one operates a full refurb shop (burnout, heat
treating, dent removal, etc.)

That the tank got an OPD valve has no effect on the inspection
interval.  It simply provides a convenient time to do an inspection.

From: John De Armond
Newsgroups: rec.outdoors.rv-travel,alt.rv
Subject: Re: Propane tank upgrade
Date: Fri, 05 Oct 2001 13:07:55 -0400

Phil Sinewe wrote:

> what the federal regulation says.  You jumped me saying I did not understand
> the NFPA code, heck you jumped all of us as the town idiots  Now you tell us
> its confusing, conflicting and impossible to apply.  I'm not confused at
> all.  I've been reading fire codes for 24 years.  I do not find them
> impossible to apply at all.  Until know I did not know you were confused.

Apparently reading and understanding are two different things, as we
see below.

>
> I stand behind my statement 100% , the valve has nothing to do with the 12
> year
> date.  After 12 years, it can be extended for 5 more years with a VISUAL
> inspection.  Then the tank is trash.

Well, I'll give you a C for consistency.  Consistently wrong but
consistent.

A DOT 4b tank does NOT expire.  It may be visualed or hydroed
indefinitely.  Specifically addressed for this type of tank (I'm
tired of quoting paragraphs - you can look it up) is authorization
to repair via either welding or brazing (!).  If a tank is damaged,
it can be welded up or otherwise repaired, re-hydroed and continued
to be used indefinitely.  Dents can be popped.  New rings can be
welded on.  We have a dealer who is set up to do just this type of
work, complete with a burnout/annealing oven used to burn the paint
and contaminants off the old tanks and to anneal repaired tanks.
The ONLY time a tank is "trash" is when it becomes irreparable.
Most typically either gross damage from dropping off a moving
vehicle or gross rusting from allowing the tank to sit in contact
with dirt under a BBQ grill.

> Since we know you are a propane dealer, do you hydrostatic test RV type
> propane cylinders?  If you do, what is the cost to do that and how many do
> you do a day??

If you'd been paying attention you'd know that I sold the welding
products distributorship several years ago and am now in the
restaurant and neon sign businesses.  Back then I farmed my hydro
testing to another nearby dealer (though I frequently did the actual
testing using his equipment.)  Made little financial sense to
duplicate his setup.

> Your final statement tells us all we need to know:
>
> "IMHO, this whole visual hydro regulation is just more BS from a
> government that knows there is no real need to test these cylinders
> but won't retract their bureaucratic claws."

Ok, let's explore this.  You seem to think I'm wrong so I'd like you
to explain to me how forcing a dealer to generate  paperwork and to
beat numbers into the cylinder after LOOKING at it (what a "visual
hydro" consists of) contributes to cylinder safety.  Merely LOOKING
at a cylinder does nothing and documenting that fact also does
nothing.

>
> OK, I'm done.  Final statement, if you find a propane dealer that thinks the
> code and regulation is confusing, he's probably the reason the OPD valve
> came about in the first place, improper filling of propane tanks.  Find a
> different dealer, afterall, its only a large tank of extremely flammable gas
> (comment directed to Neon John the LP dealer).

Really?  DOT had no factual basis for requiring OPDs.  Like many
other regulations, they proffered a hypothesis and then issued
regulations to address that hypothesis without any real evidence.  I
predict that the Law of Untended Consequences will rule and
overfilling incidents will become MORE frequent.  Some percentage of
OPDs, like any mechanical device will fail.  Some other percentage
will be ripped out by their owners.   With dealers believing that
using the 80% valve or scales is no longer necessary, tanks will end
up overfilled and no one will know it until the tank or safety
fails.

Given your record of errors so far in this thread, Phil, I'm sure
that you're unaware that the CORRECT method of filling a portable
tank, that is, by weight, has nothing to do with the type of valve
used.