Technical Comments to Draft 15 February 2011 SGS-12 Req uest or JASI C Ref. Clause No./ Annex B.5.1.1.2 Text B.5.1.1.2 Cycle Life. Baseline Initial Pressure Three (3) randomly selected new container shall be hydraulically pressure cycled to 125% NWP without rupture for 22,000 cycles or until leak occurs (B.6.2.2.2 test procedure). Leakage shall not occur within the initial number of cycles (#Cycles). For the 15 years service life, the required #Cycles cannot be greater than 11,000, and it could be set by the Contracting Party at a lower number but not lower than 5,500 cycles. JASI C B.5.3.1.2 Proposed change by the Requestor Three (3) randomly selected new container shall be hydraulically pressure cycled to 125% NWP without rupture for four times of the initial number of cycles ( 4 X ( # Cycles) ) or until leak occurs (B.6.2.2.2 test procedure). B.5.3.1.2 Fueling port label: A label shall be provided close to the receptacle, a) For gaseous hydrogen: Fuel for example, inside a refilling hatch, type, NWP, date of removal from service of containers. showing the following information: Contracting parties may specify a) For gaseous hydrogen: Fuel type, additional labeling NWP, date of removal from service requirements. of containers. 1/3 Comment (justification for change) The design philosophy of LBB is to keep the damages minimum when the container comes to break down at worst case in the presence of flaw or defect. Therefore, it is extremely important, from the standpoint of safety, to verify that the container begins to leak before burst. Type 2 containers, in particular, may break without LBB when circumferential wrap (hoop wrap) is too tight. The number of repeating until breaking has a statistical distribution in containers or production lots. If two times of the initial number of cycles ( 2 X ( # Cycles) ) is introduced, there is possibility that some containers do not reach LBB condition. These containers may bring hazardous accident if they come to break down. Four times of the initial number of cycles ( 4 X ( # Cycles) ) is used in Japanese standard and others. It is necessary to have enough evidence and experience If two times is introduced in gtr. Our understanding was that the sentence “Contracting parties may specify additional labeling requirements” should be moved to Part A. However, the draft is not modified accordingly. On the other hand, the above sentence is contained in B.5.1.5 (Labeling). We need to harmonize the language about “additional labeling requirements” between container label and receptacle label. Technical Comments to Draft 15 February 2011 SGS-12 B.5.1.3.5 B.6.2.5.2 JASI C B.5.1.3.5 Residual Strength Burst Test (hydraulic). The storage container will undergo a hydraulic burst test in accordance with test procedure B.6.2.2.1 to verify that the burst pressure is within 20% of the baseline burst pressure determined in B.5.1.1.1). B.5.1.3.5 Residual Strength Burst Test (hydraulic).The storage container will undergo a hydraulic burst test in accordance with test procedure B.6.2.2.1 to verify that the burst pressure is within 20% of the baseline burst pressure determined inB.5.1.1.1). B.5.1.3.5 The containers with plastic liner shall be sectioned and the liner and liner/end boss interface inspected for evidence of any deterioration, such as fatigue cracking, disbonding of plastics, deterioration of seal, or damage from electrostatic discharge. B.6.2.5.1 Fire Test (Pneumatic) B.6.2.5.2 Engulfing fire test: Please find attached file. It is necessary to confirm no blister by this inspection. This test is same as ANSI/CSA NGV2-2000. As Japan does not have any test criteria examples (we only have the OK examples), we are currently studying those criteria. We believe it is necessary to clarify the definition of test specimen. Please see attached power point document. ※Japan will propose language to justify the inclusion of Method 1, Method 2, and the engulfing fire test, including definition of bare container and shielding components. 2/3 Technical Comments to Draft 15 February 2011 SGS-12 B.6.2.1.5 Coating test. For containers with external environmental coatings, coatings shall be evaluated as follows: a) adhesion strength based on ISO 4624; the coating shall exhibit an adhesion rating of 4. b) flexibility based on ASTM D522 Method B with a 12.7 mm mandrel at the specified thickness at -20C; the coating shall exhibit no apparent cracks c) impact resistance in accordance with ASTM D2792. The coating at room temperature shall pass a forward impact test of 18 J. d) water exposure based on ASTM G154 using an exposure of 1000 hours. There shall be no evidence of blistering. The adhesion shall meet a rating of 3 when tested in accordance with ISO 4624. e) salt spray exposure in accordance with ASTM B117 using an exposure of 500 hours. There shall be no evidence of blistering. The adhesion shall meet a rating of 3 when tested in accordance with ASTM D3359. B.6.2.1.5 Coating test. For It is necessary to define the applicable container. seamless steel containers with This test is expected to be applied to seamless external environmental coatings, steel containers. coatings shall be evaluated as follows: B.6.1.XX Post-Crash Hydrogen Add the sentence in the current This language was accepted at Task Force meeting in Berlin. Container Installation Integrity draft gtr text. The container shall remain attached to the vehicle at a minimum of one attachment point. 3/3