VE T6351 at Hydro Concern

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chrpai

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Cedar Park, TX
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I just don't log dives
I've read threads quoting 49 CFR 180.213(f)(9) saying that 3AL T6351 must be Visual Eddy tested and marked as VE on the tank at the time of hydro.

I have observed something that seems a red flag to me but I want to get a consensus opinion before crying foul.

I have seen multiple Luxfer 3AL tanks with original hydros from the mid 1980's. ( Several that are 1986 ). AFAIK that indicates a T6351 tank and not a T6061 tank.

I have seen these tanks have recent hydros (5/2012) with a certain RIN and they are all lacking the VE stamp.

I have seen other tanks that meet the above scenario but with a different RIN and they have the VE stamp.


Am I correct in thinking there is a problem going on here or is there another possible explanation?
 
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Yes, there is a problem. Your observation is correct a 6351 cylinder should have a VE next to year. It has been over 5 years since the rules went into affect. If the shop does know it by now there is a real problem.

Have a chat with the shop owner and show them them this:

http://www.epa.gov/EPA-IMPACT/2006/August/Day-29/i14255.htm
 
Would would you contact to report this?
 
If they are a Catalina or Clifford cylinder, they do not need to be VE'd as they never manufactured cylinders from 6351 material. Luxfer, Walter Kiddie cylinders are the main culprits. FWIW, USD cylinders were made by Luxfer. Luxfer did a lot of private labeling in the day.
 
I know how to spot the difference between a 6061 and 6351 tank. These are clearly 6351 tanks.

For the USD tanks, you can tell they are Luxfers because of the way the serial numbers are and the initial hydro stamp symbol.
 
Would would you contact to report this?
I think there are a couple of approaches. One would be to contact the DOT Customer Service Center: 202-366-4000, and ask that question. Since the facilities are licensed by DOT, and appear to be performing a licensed function incorrectly, you have the right as a consumer to 'complain'. At the very least, you have the right to inquire.

The challenge to this approach, and pardon my cynicism, is that you may or may not connect by telephone with someone at DOT who actually has a brain. (I do not single out DOT here, just making a general comment about government hiring practices.) If you get an intelligent and motivated person, they can direct / transfer you to the right office.

Another possibility is to ask the ' who do I report this to' question to Mark Gresham, president / owner of PSI - PCI. He is very knowledgeable in this area, and has a lot of contact with numerous federal agencies, including regulatory bodies. Call 425-398-4300. Mark's wife, Sheri, often answers the phone and can easily put you in contact with him. He lives nearby here in NC and is a very approachable / accessible person.
 
Who would you contact to report this?

I have run into this issue before. It was not my tank but one for sale that was clearly a 6351 and I was able to back track the hydro shop info from the RIN number. I contacted a shop owner and had a chat with them about it. They thanked me for the info and said they would correct the problem. That was a 3-4 years ago so it did not bother me too much that they had missed the change.

I would probably take the same approach today but strongly emphasize that the new regulations have been out for over 5 years that they really should have known about the change.

If you contact DOT you probably want to have pictures of the cylinder(s) in question.

FWIW I have also contacted the tank owners as well to tell them their tank was not properly requalified and recommended that they return to the shop for a new hydro or their money back.
 
I got offered a bunch of 80's (All Luxfer, all from the mid -1980's, all with recent hydros (1 year at most), NONE with the VE stamp.

So I say to myself, are these at all worth it?

I am certified and experienced in doing VIPs, but not active, nor do I have to time to do my own tanks, and I don't own or want to borrow the Eddy Equpiment.

Thread, what do you think? Worth it at free (which the last bunch were), worth it at $25, worth it at $35? If so, do I just send them back to hydro and make sure the hydro station does the VE and stamps it this time?
 
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I got offered a bunch of 80's (All Luxfer, all from the mid -1980's, all with recent hydros (1 year at most), NONE with the VE stamp.

Since these were not properly requalified nobody should be filling them.

Personally I got rid of all my 6351's awhile ago as they aren't worth putting the money into. At the time they were worth $20 as scrap.
 
https://www.shearwater.com/products/teric/

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