Independent Inspection Agency IIA Annual Meeting IIA Annual

Independent Inspection Agency (IIA) Annual Meeting IIA Annual Meeting Webinar May 16, 2018 1330 - 1430 Presented by : PHMSA Staff Pressure Vessels Division (PHH 33) Pipeline and Hazardous Materials Safety Administration (PHMSA)

015 IT Portfolio PHMSA's mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. 2

Discussion Points Ø DOT / Transport Canada - cylinder reciprocity. Ø Acoustic Emissions / Ultrasonic Examinations approvals & Transport Canada. Ø Process for DOT RIN holders to be added to Special Permits for AE/UE testing. Ø Chemical Analyses and tests § 107. 807

I. DOT / Transport Canada - cylinder reciprocity. PHH 33

DOT / Transport Canada - cylinder reciprocity (cont. ) Ø Federal Register / Vol. 82, No. 60 (3. 30. 2017) Ø DOT RIN Holder can requalify comparable Transport Canada cylinders. Ø An IIA review is not required if already registered with PHMSA (§ 107. 805(f)(2))

DOT / Transport Canada - cylinder reciprocity (cont. ) Ø Table 1 of the § 171. 12(a)(4)(iii) entry identifies specifications considered “equivalent”. Ø TC-8 WM or TC-8 WAM among the Canadian cylinders that do not directly correspond to DOT specification cylinders.

DOT / Transport Canada - cylinder reciprocity (cont. )

II. Acoustic Emissions / Ultrasonic Examinations approvals & Transport Canada. Ø Reciprocity referenced by this FR does not address Acoustic Emission/ Ultrasonic testing. Why? Ø Holders of DOT Special permits authorizing the Ultrasonic examination may request a modification of that SP to authorize the examination of TC cylinders.

Acoustic Emissions / Ultrasonic Examinations approvals & Transport Canada. (cont. ) Ø Possible option - DOT Special Permit holders to get a COE from Transport Canada and then apply to approvals. Ø IIAs should not be including TC specification cylinders in their letter of recommendations

III. Process for DOT RIN holders to be added to Special Permits for AE/UE testing. Ø RIN Holder needs to contact the owner of the special permit. Ø The Special Permit owner will then request an amendment to include the RIN holder to the Special Permit, as an authorized tester. Ø Only the Special Permit owner can make that request to Special Permits Branch. Not vice versa

III. Process for DOT RIN holders to be added to Special Permits for AE/UE testing (cont. ) Ø Responsibilities of the Special Permit Owner: § Verify that the RIN holder has a valid RIN before submitting a request to specialpermits@dot. gov § This constitutes a modification so the Special Permits Branch would request an application.

IV. Changes in Non-Technical Information Ø Labs where Chemical Analyses and tests IAW § 107. 807 are performed need to be included on cover letters. Ø Instances where there has been changes and they have not been submitted.