Interpretation ID: nht93-4.36

DATE: June 17, 1993

FROM: Han Dinh -- Project Manager, Delivery & Customer Services Equipment Engineering, Research and Development, United States Postal Service

TO: Steven P. Wood -- Office of Chief Counsil (Counsel), Rule Making Division

TITLE: ANSI/AGA NGV2 Standard

ATTACHMT: Attached to letter dated 8/16/93 from John Womack to Han Dinh (A41; Part 303)

TEXT:

The U.S. Postal Service is in the process of converting our postal fleet to operate on alternative fuel; mainly compressed natural gas, as it is required by the Clean Air Act and Energy Policy Act.

As a background, The U.S. Department of Transportation (DOT) has a standard for the fuel tanks that are all-steel and all-aluminum pressure vessels, as well as vessels which are reinforced with composite. Since the standard was not intended for vehicular fuel tank usage, the cylinder makers have to obtain approval of exemption from Title 49 of the Code of Federal Regulation.

In the past, we required the manufacturers of the cylinders to obtain DOT exemption (i.e., Press Steel Tank Company has DOT-E-8965 or SCI Company has DOT-E-8725) so they can be considered as a supplier.

The American Gas Association, with help from industry, has generated a standard called NGV2, which is referenced by the National Fire Protection Agency Standard NFPA-52 as an acceptable standard and has also been adopted by the American National Standards Institute (ANSI). The National Highway Traffic Safety Administration (NHTSA), a branch of DOT, is in the process of NGV2 review.

This brings us to the point of our concern. The Brunswick Composite Tank Company has informed us that they have just passed the NGV2 standard; and we believe they are the only company with this claim. In the near future, we are planning to release an RFP for converting 1400 vehicles to compressed natural gas. We would like to ask your office for a recommendation as to which standard we should require (DOT exemption cylinder or NGV2 cylinder). Your guidance in this matter would help us a great deal. If you have any questions, please contact me at (703) 641-7138 or Chris Nikpora at (703) 641-7416. We would appreciate it very much if you could respond to us before July 1, 1993.