ultrasonic examination of cng vehicle cylinders as an alternative to periodic hydrostatic testing
TRANSCRIPT
Dated: June 20, 2012 To, Chairman, Oil & Gas Regulatory Authority, 54-B, Old ZTE Plaza, Fazal-e-Haq Road, Blue Area, Islamabad
Subject: VISUAL AND ULTRASONIC EXAMINATION OF CNG VEHICLE CYLINDERS AS AN ALTERNATIVE TO HYDROSTATIC TESTING
Dear Sir,
CNG Safety Rules, 1992 refers to AS 2337.1 standard for hydrostatic testing of CNG
vehicle cylinder. Whereas according to the Clause 7.3.1 of AS 2337.1-2004 standard (copy
attached) hydrostatic testing of Type I CNG cylinder is not required if Ultrasonic examination is
carried out. The Clause clearly states that “Ultrasonic examination is an alternative to pressure
testing, applicable to the normal range of seamless metal gas cylinders, but is not suitable for
welded or composite cylinders.” In fact the name of the Section 7 of the AS 2337.1 is “Pressure
Test or Ultrasonic Examination”.
2. Conducting hydrostatic test and internal visual inspection can create safety problems
which are briefly discussed as under:
a) Hydrostatic testing is only suitable for Type II, Type III, Type IV and welded LPG/CNG
cylinders, as the integrity of welding and damage to the composite plastic fiber
wrapping is difficult to evaluate otherwise. The approved standard for CTL AS 2337.1
clearly exempt hydrostatic testing for Type I cylinders in which Ultrasonic examination is
carried out as an alternative (copy of relevant clause is attached for ready reference)
b) Hydrostatic testing can take the CNG cylinder to its plastic limit which can lead to failure
of CNG cylinder during service. The cylinder is also unnecessarily subjected to 1.5 times
its working pressure in hydrostatic testing during its service life.
c) A hydrostatic test requires disconnection of fuel lines, removal of the cylinder from its
mounting and removal of the cylinder 3-way valve. This process has to be reversed upon
installation of cylinder after the test, introducing many risks associated with it i.e.
improper installation of fuel lines, valve and cylinder, damaging of the cylinder valve or
cylinder neck/mounting, reduction in thread strength, thread damage, rubber pad
damage and leakage.
d) Implementing of a hydrostatic test can increase the chance of internal corrosion as
cylinder is filled with water during testing, any water retained after the test could cause
corrosion or affect engine performance.
e) The most common cause for cylinder rejection in a hydrostatic test is some kind of
problem with the hydrostatic test equipment itself. This includes false reading,
calibration of pressure gauge/relief valve, test interpretation etc. CTL in Pakistan are
mostly using locally fabricated equipment which is a copy of the OEM design and is not
reliable. A split second human error can take a cylinder into plastic stage where it is
permanently deformed due to increase in hydrostatic pressure.
f) If there are defects in the cylinder such as folds, microscopic cracks, gouges or similar
damage, the hydrostatic test results are likely to be the same as for good cylinder.
Worthington CNG Storage Cylinders are a good example of such case; these were tested
at HDIP CTLs prior to installation at CNG station on the directives of OGRA yet failed
during the service even though the cylinders pass the Hydrostatic test requirements.
g) Hydrostatic testing requires emptying of CNG cylinder which results in release tens of
thousands of kg natural gas into the atmosphere. Natural gas is a GHG that is 21 times
more potent than CO2.
h) NZS 5454 and similar vehicle manufacturing standards i.e. ISO 11439, NGV2, have an
extensive array of material, qualification and batch tests to ensure that the materials are
acceptable, the designs are sound and the manufacturing process is repeatable. These
standards have more test requirements than for conventional gas cylinders. The drop
test, gunfire test, pressure cycling test, proof test, burst test and environmental test
provide considerable assurance that the cylinders can sustain damage or environmental
exposure and still remain safe during service life. Hence, there is no need to carry out
periodic hydrostatic testing of Type I CNG cylinder.
i) There was not a single NGV cylinder that has been reportedly rejected because of the
internal corrosion as there are traces of compressor oil in CNG which prevent the
cylinder from internal corrosion. ISO 9078:2006 (E) states that there have been no
reports of steel cylinder failures due to corrosion in NGV Service.
j) Taking into account all the aforementioned factors, it is obvious that requiring a
hydrostatic test only introduces much risk and cost with little, if any, gain. Many
Regulatory Authorities are looking for alternatives to hydrostatic testing because they
realize that it is not adding much value. There is general consensus in the leading NGV
OEM that the risk associated with hydrostatic testing are much higher than its benefits.
3. A pressure vessel inspector can declare the CNG cylinder fit for further use with the help
of visual and ultrasonic inspection tools without Hydrostatic testing. In this regard, standards
like Compressed Gas Association (CGA) C-6.4 (Methods for External Visual Inspection of Natural
Gas Vehicle and Hydrogen Vehicle Fuel Containers and Their Installations) and ISO 9078: Gas
cylinders — Inspection of the cylinder installation, and requalification of high pressure cylinders
for the on-board storage of natural gas as a fuel for automotive vehicles can be included in the
approved list of standards for periodic testing of CNG Cylinders.
4. Ultrasonic testing even identifies small faults, such as cracks, corrosion, pits and gouges
that are not always found during the internal visual inspection required as part of a standard
hydrostatic test. The requirements of internal visual examination are waived off for ultrasonic
testing of cylinders as it produces highly accurate measurements. This give additional benefit
that the cylinders are not required to be de-valved. Furthermore, the residual contents do not
have to be drained in Ultrasonic examination and it provides more detailed analysis than the
standard hydrostatic test.
5. In the view of above, it is requested that Oil & Gas Regulatory Authority (OGRA) may
allow that NGV Type I seamless steel cylinders shall be re-qualified by visual and ultrasonic
inspections after every 5 years or less as an alternative to Hydrostatic testing.
Regards,
Mr. Asim Riaz
NGV Owner/Driver,
B.E Mechanical, B.Sc Math Physics, Master Energy Management,
The writer has about a decade long experience in evaluation, inspections, technical reporting of
CNG cylinders accidents and is well versed with CNG cylinder manufacturing/testing standards.
Cc:
Honourable Federal Secretary, M/o Petroleum & Natural Resources
C.I.E, Department of Explosives, M/o Industries
Registrar, OGRA