10% overfill / Plus + rating on Steel LP tanks

[roakey]

Well dangit, I know some of you are getting old 72s tested to a + rating, how are you going about getting an REE for the cylinder? This is some mail I just exchanged with Pressed Steel:

================================

REE information is not available on older product.

Best regards,

T.Ivey Scuba Product Manager
E-mail: tivey@pressedsteel.com
Webstscuba.com

>
Mr. Ivey,

I recently purchased a couple of Pressed Steel's 2400 psi 104s and I notice that the REE for testing to the + rating is now stamped into the neck of the cylinder.

I am the original owner of an older Pressed Steel 72, 3AA2250 cylinder as well. This cylinder's serial number is 47059 with an original hydro date of 1/71. Could you please supply the REE for this cylinder so I can once again get it tested to a + rating. The cylinder is still immaculate and there is nothing in its history that would make me believe that would not pass the testing required for a + rating.

If you have any additional questions please don't hesitate to call me at the number below.

Thank you,

Roger

 

[Cave Diver]

There is a lot of good information on this website regarding tanks, perhaps this page will be of some help...

Tank Fills

 

[John Hoffer]

I don’t mean to open old wounds, but I want to share something I’ve learned about high-pressure tanks that I don’t think is widely known.

I have three LP Steel 93s. I have given some thought of selling two or three in order to buy a one or two HP steel 120s. I just bought my petite wife a PST HP80 a couple of months ago. She loves the tank and I, being a shore diver, have been favorably impressed with its negative buoyancy and lightweight on land.

PST HP steel tanks do not pass the normal requirements issued by DOT. They qualify for an exemption from the requirements, which is why PST HP tanks do not have the familiar “DOT 3AA” markings. Instead, you will find something like “DOT E1234 - 3500.” The E1234 is the DOT exemption number.

No big deal. I surmise that the one reason why DOT permits exemptions may be the risk that the regulations inhibit innovative tank design, new metallurgy, and improved manufacturing methods. It’s not unusual to see regulatory climate trail technological development.

What I find interesting is that these exemptions are good for only two years. Thereafter, the manufacturer must reapply for a continuation of the exemption.

This renewal of the exemption is not required for tanks stamped “DOT 3AA,” that is to say LP steel tanks. (Or for that matter aluminum tanks stamped “DOT 3AL.”)

Should PST go out of business or otherwise fail to continue the exemption, those people with PST HP steel tanks will not be able to fill them or submit them for hydrostatic testing once the exemption expires. Visit: http://diverlink.com/gear/tankmarkings.htm

Reasons to buy PST HP have become either more compelling or less compelling, depending one’s take on this issue. This new knowledge really hits home for me. My three steel LP 93s are made by Coyne Steel Company, which still is in business but no longer selling cylinders in the SCUBA market. I’m glad my three tanks are not exempt tanks.

The other neat tidbit of information I didn’t know is that your LDS can legally overfill your steel LP tank by 10%, even if the most recent hydrostatic tester failed to stamp the “+” on the tank. Once the “+” has been stamped on the tank, its is good for the life of the tank, so long as the tank’s vis and hydro is current. Convincing the LDS of that legality is, unfortunately, another matter since they typically operate at the level of rumor, hearsay, and innuendo. Given the complexity of DOT regulations, that’s almost forgivable. See: http://diverlink.com/gear/tankfills.pdf

I have reviewed the DOT regulations on their website and confirmed that the information concerning “+” fills is valid. I have not had a chance to review DOT regulations regarding the two-year renewal for exempt tanks, but I have no reason to believe the information here is incorrect. I'll get to confirming it eventually.

 

[pescador775]

I would urge the regulator to remove your subject post as containing bogus information, and speculation which borders on nonsense.

 

[Uncle Pug]

Thanks John for the research.

Pesky... go ahead and take your best shot... oh wait, you already did.

 

[Hallmac]

Relax and enjoy your P.S.T. Tanks!

I have been Doing Hydrostatic testing for the last three years. I probably see 150 to 200 tanks a year. ( I know not a lot, but P.S.T. is a favorite in our area.) I have yet to see a P.S.T. fail. I have not seen any refusals issued by D.O.T. on any tank they have produced.
I,m still using a set of 100 HP they make that were made in 80,s under an exemption. So far so good!

Hall

 

[kcanty]

You shouldn't worry about PST going out-of-business.

They have been in business since 1902!! That's
pretty strong.

Best tanks I own. All LP no HP though.

Kell

 

[SDAnderson]

Just because the original holder of an exemption doesn't refile (for any reason, including no longer in business) does not mean that the exemption will not be renewed. Any number of third parties can file for an extension of the exemption. When DOT learns of the business failure of the holder of an exemption, they publish an advisory notice, alerting the public to the current standing of the exemption and letting third parties know that they can file to extend the exemption. Couldn't tell you how often it happens, but it has.

Also, DOT specification is not neccesarily a permanant thing, either. Just ask all those folks with DOT 6351-T6 wind chimes.

Steven

 

[pescador775]

I repeat, the subject post is entirely false. No tester can legally 'plus' rate a tank which does not meet the REE criterion for that tank. To fill the tank above the rated pressure is at the discretion (and liability) of the operator. If the tank is transported interstate by 'common carrier', it is a violation of federal law. To suggest that the E9791 spec will be voided is nonsense.

Edit: Pug, the only person that you are fooling is yourself.

 

[John Hoffer]

Today I called DOT's Hazmat hotline 800-467-4922 and spoke with Kurt Eichenlaub.

After being put on hold a long time so he could research my question and confer with others, he emphatically answered my question.

49 CFR section 173.302a(b) allows for tanks stamped with the "+" to be overfilled 10% EVEN IF THE TANK DID NOT GET A "+" STAMP ON SUBSEQUENT HYDROSTATIC TESTING. If the "+" was originally stamped on the tank, it can be overfilled by 10% so long as the tank's vis and hydro are current.

Obviously, DOT considers the service pressure for a tank stamped 2400+ to be 2640 psi. If the tank was originally stamped "+," subsequent "+" stamping is redundant. After all, nobody expects the hydro tester to stamp "2400."

Mr. Eichenlaub also confirmed what you said earlier, that filling at your LSD and then driving to a dive location is not putting the tank into interstate transport, and therefore the DOT has no regulations on fill limits, albeit state negligence laws apply.