CTC Certified Training Co. - Comments

The summary text in the ANPRM regarding P-1515 is mistaken. . There is no reference in my petition to "Permit cylinders that fail requalification to undergo repair and then attempt requalification a second time", as stated in the ANPRM. I was shocked and dismayed to see this completely false statement. There exists an incorrect reference in § 180.205(h)(3) that I was simply correcting. This paragraph says, "Unless the cylinder is requalified in conformance with requirements in § 180.211...". There are no requalification requirements in § 180.211. § 180.211 covers "Repair, rebuilding and reheat treatment of DOT-4 series specification cylinders." I was merely correcting the erroneous reference of "requalified" in the existing text to say "repaired or rebuilt", in order to correspond to the actual requirements of the referenced section. I was in no way suggesting that cylinders which fail requalification may be repaired and requalified a second time. 180.205(h) is the section on cylinder rejection, not condemnation. I also eliminated the words "rejected or" from 180.207(b)(2) in order clarify that a cylinder must be condemned if it fails requalification. This was clearly explained in the "Rational.doc" document that was submitted with the Petition. I do not understand where PHMSA could have come up with this idea; it was not part of my petition. If a cylinder fails requalification, it must be condenmned. This is clearly stated in the rational documnent, and my proposed changes only reinforce this concept. There is no proposed repair for cylinders that fail requalification in my petition. Please remove this erroneous statement from the summary.