National Steel Car Limited — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Materials Safety Administration OCT 2 1 2015 Mr. Max Vanderby Director of Production Engineering National Steel Car Limited 600 Kenilworth Ave. North P.O. Box 2450 Hamilton, Ontario LN 3J4 Ref. No.: 15-0133 Dear Mr. Vanderby: This responds to your June 25, 2015 letter and subsequent phone call with a member of my staff regarding tank car head puncture resistance and tank car specifications under the Hazardous Materials Regulations (49 CFR Parts 171-180). Your questions are paraphrased and answered below. Q1. You ask if a tank car built with a 9/16 in thick shell of TC128 material with ½ in full head shields is compliant with § 179.16(c)(1) and does not require the full scale testing outlined in § 179.16(a)? A1. Yes, assuming the head shield is shaped to the contour of the tank and the head shield steel has a tensile strength greater than 379.21 N/mm? (55,000 psi), the tank car meets the requirements of § 179.16(c)(1) and does not require the full scale testing outlined in § 179.16(a). Q2. Would the car mentioned in Q1 above have to undergo physical testing to demonstrate compliance with the impact test requirements for head shield attachments in Section 5.3 of the AAR Specifications for Tank Cars given in § 179.16(c)(2)? Or is there alternative compliance by other than testing methods to demonstrate compliance with this impact test? A2. As required by § 179.16(c)(2) and section 5.3.1.2 of the AAR Specifications for Tank Cars new and untried designs of head shield attachments must meet the design and test requirements of the full-head protection (shields) impact test requirements in Section 5.3 of the AAR Specifications for Tank Cars.#

Page 2Q3. Would this car then be a DOT117J100W1 due to the addition of full head shields and thermal protection? A3. Yes, for a DOT Specification 117 tank car built on or after October 1, 2015 in conformance with § 179.202. The marking requirements for tank cars are found in § 179.22. Section 179.22(c) states that "each tank car that requires a tank-head puncture- substituted for the letter "A" or "S" in the specification marking". resistance system, a thermal protection system, and a metal jacket must have the letter "J" I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553. Sincer Ben Supko Senior Regulations Officer standards and Kulemaking Divisior#

Page 3Webb 17,9.16 Goodall, Shante CTR (PHMSA) Lank Cars From: Betts, Charles (PHMSA) 15-0133 Sent: Friday, June 26, 2015 3:40 PM To: Hazmat Interps Attachments: PHMSA letter Tank Head Puncture Resist mav June 25-15.pdf Please assign this as a HIGH PRIORITY to a specialist for response. Thanks, Charles#

Page 4(100 YEARS MAX VANDERBY TOES OF RELATE DIRECTOR, PRODUCTION ENGINEERING NATIONAL STEEL CAR LIMITED 600 Kenilworth Avenue North HAMILTON, ONTARIO L&N 3J+ P.O. Box 2450 FAX: (905) 514-9878 EXT. 3262 RAIL TRANSP E-MAIL: vanderbym@steelcar.com NATIONAL STEEL CAR 1912-2012) June 25, 2015 Charles Betts Director, Standards and Rulemaking U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 Re: DOT 117 Tank Car Puncture Head Resistance, interpretation of 49 CFR § 179-16 Dear Mr. Charles Betts, National Steel Car would like to request from PHMSA clarification to Specification 49 CFR § 179.16 regarding the standard for Tank Car head puncture resistance. The FRA interprets any Tank Car built with a 9/16 in thick shell of TC128 material with 1/2 in full head shields is compliant with 49 CFR § (1) (c) (not requiring full scale testing outlined in 49 CFR § 179.16 (a) (1 - 3)); therefore, the car is a DOT117J100W1 due to the addition of full head shields and thermal protection. We appreciate if you could confirm the interpretation of this specification. Sincerely: Do Varily. Max Vanderby Director of Production Engineering NATIONAL STEEL CAR LIMITED cc: Ken Dorsey, Karl Alexy, Jamal Hematian, Ken Black#