{"operation":"document","citation":"21-0054","title":"TCIX Rail — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-08-25","effective_on":null,"summary":"21-0054 response to TCIX Rail concerning 179.13, 179.201, 180.509.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0054.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0054.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0054","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/75806/210054.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 25, 2021\nKeenan Moore\nFleet Management Specialist\nTCIX Rail\n911 NW Loop 281 Suite 316\nLongview, TX 75604\nReference No. 21-0054\nDear Mr. Moore:\nThis letter is in response to your March 26, 2021, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to minimum plate thickness\nrequirements for DOT-111 tank cars. Specifically, you ask what minimum plate thickness\nshould be used when determining the permitted thickness reduction adjustments in accordance\nwith § 180.509 and the Association of American Railroads (AAR) Manual of Standards and\nRecommended Practices (MSRP) Section C-III Specifications for Tank Cars (M-1002).\nYou state that you use the minimum plate thickness provided in § 179.201-1 for DOT-111 cars;\nhowever, you note that the MSRP has additional thickness requirements listed for tank cars\nconstructed after 2004, based on how the tank car is equipped (e.g., shell material type, jacket,\nhead shield, etc.).\nWe have paraphrased and answered your questions as follows:\nQ1. You ask what minimum plate thickness should be used when calculating permitted\nthickness reductions in accordance with the thickness test requirements provided in\n§ 180.509(f).\nA1. For compliance with the HMR, and for tank cars that do not exceed 263,000 pounds\ngross weight on rail, the thickness values in § 179.201-1 of the HMR must be used to\ncalculate the required minimum tank shell or head thickness, or value “B,” as provided in\n§ 180.509(f). As authorized by the Federal Railroad Administration (FRA), tank cars that\nhave a gross weight on rail up to 286,000 pounds must adhere to the requirements\nspecified in the approval notice titled “Operating Certain Railroad Tank Cars in Excess of\n263,000 Pounds Gross Rail Load” (76 FR 4250). Note that the AAR may have additional\nminimum thickness requirements for the use of interchange railroads. You may use the\ncontact information provided below to confirm AAR’s tank car requirements.\n\n<<<PAGE 2>>>\n\nQ2. In the event that the specifications provided in Chapter 2 of M-1002 must be used as the\n“required minimum tank shell or head thickness after forming,” you ask whether PHMSA\nwould develop new specification classes that include those additional requirements (e.g.,\nshell material type, jacket, head shield)—similar to what is provided in the specification\ntable provided in § 179.201-1—or if those specifications would become grandfathered\nrequirements that would result in noncompliant cars being phased out as they reach their\n50-year end of life period.\nA2. The answer is no. Except for tank cars containing poisonous-by-inhalation material, the\nrequirements for a tank car exceeding 263,000 pounds are currently provided in\n§ 179.13(a). No new specification is needed, as the tank cars built to AAR S-286 meet\nthe DOT specification minimum thickness requirement.\nQ3. You ask whether there would be a difference in the interpretation of the minimum\nthickness requirements between PHMSA and AAR that might result in noncompliance\nfindings from Bureau of Explosives/ Transportation Technology Center, Inc.\n(BOE/TTCI) auditors and the FRA to various parties, depending on how they interpret\nthese requirements.\nA3. A PHMSA Letter of Interpretation—such as this letter—is intended to clarify the HMR\nand is not used to determine compliance with the regulations. Noncompliance findings\ncannot be determined within the scope of a letter and are not established for tank car\nspecification compliance by this Office. The FRA Tank Car Team, Motive Power and\nEquipment (MP&E) Division and AAR’s BOE/TTCI auditors should be contacted\nregarding their individual enforcement policies for a nonconforming tank car. The FRA\nTank Car Team can be reached by email at hmassist@dot.gov, and a list of AAR points of\ncontact is available at. https://aar.com/standards/boe_contacts.html.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nCasey\n21-0054\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: 2004+ 286K DOT-111 Minimum Thickness Question\nDate: Wednesday, May 19, 2021 4:55:04 PM\nAttachments: image003.png\nimage009.png\nimage011.png\nHi Alice,\nPlease see below for an interpretation request.\nIs it possible to assign this request to Leonard Majors or Alex Cheng in PHH-22? They were the primary people\nspearheading the research in Keenan’s question.\nPlease let me know if you have any questions.\nRegards,\n-Breanna\nFrom: Keenan Moore [mailto:keenan@trinitychem.com]\nSent: Wednesday, May 19, 2021 1:34 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: RE: 2004+ 286K DOT-111 Minimum Thickness Question\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open\nattachments unless you recognize the sender and know the content is safe.\nBreanna,\nPlease see Physical Mailing address below. Thank you all for your help.\n911 NW Loop 281 Suite 316 Longview, Texas 75604\nPlease & Thank You,\nKeenan Moore\nFleet Management Specialist\nKeenan@TCIXRail.com\nOffice: (903) 653-4077\nCell: (903) 241-4079\nFrom: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSent: Tuesday, May 18, 2021 3:08 PM\n\n<<<PAGE 4>>>\n\nTo: Keenan Moore <keenan@trinitychem.com>\nSubject: RE: 2004+ 286K DOT-111 Minimum Thickness Question\nDear Keenan,\nWe have received your request for a written letter of interpretation regarding the hazardous materials regulations\n(49 CFR Parts 171-180). The hazardous materials regulations are available at the following URL:\nhttps://www.ecfr.gov/cgi-bin/text-idx?\nSID=1d49a3b137cb1b6fc45251074e634b44&tpl=/ecfrbrowse/Title49/49tab_02.tpl\nHowever, before we can submit your request for processing, please respond to this email with:\nPhysical Mailing Address\nSincerely,\nBreanna, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal guidance may be requested in\naccordance with 49 CFR 105.20. https://www.phmsa.dot.gov/standards-rulemaking/hazmat/hazardous-materials-\ninformation-center\nFrom: Keenan Moore [mailto:keenan@trinitychem.com]\nSent: Friday, March 26, 2021 10:08 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nCc: Fleet Management <fleetmanagement@trinitychem.com>\nSubject: 2004+ 286K DOT-111 Minimum Thickness Question\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments\nunless you recognize the sender and know the content is safe.\nBreanna,\nPlease see relevant sections of the CFR and MSRP C-3-Chapter-2 below and attached. My question is what\nminimum plate thickness should be used when calculating reductions allowed per CFR49.180.509(f). This amounts\nto what thickness should be used for item “B”. Typically, I would use the highlighted column (Minimum plate\nthickness) below from 179.201-1 (For DOT-111 cars), but MSRP C3-Chapter2-2.5.3, has additional thickness\nrequirements listed for newer (2004+) cars depending on how else the car is equipped (shell material type, jacket,\nhead shield). Are these thicknesses from Chapter 2 to be used in this calculation as item B or should the 179.201-\n1 table below be used as item B, making the Chapter 2 thickness an item A (overpackaged with additional\nthickness)?\n\n<<<PAGE 5>>>\n\nA few additional thoughts.\nIf Chapter 2 is to be used as item B for the calculation, then shouldn’t that result in new DOT Specification classes\nthat require those additional requirements (shell material type, jacket, head shield) similarly to the 179.201-1\nspecification table below specifically the last “References” Column? Or make reference to Chapter 2-2.5.2.3 in\n180.509(f) Fig A for a reminder to what minimum plate thickness should be used for certain cars.\nOr is this considered a type of grandfathered requirement that will result in noncompliant cars (less than 2004\nordered) being phased out over time as they reach their 50yr EOL? Which would eventually require the 179.201-1\ntable thickness being revised by 2054 to match the Chapter 2 thickness (for cars that are 286K).\nWill there be a difference in opinion between the Feds and the AAR regarding how this is handled, resulting in\nnoncompliance findings (from BOE/TTCI auditors and the FRA) to various parties depending on how they interpret\nthis?\nC3-App D-2.1.8.2 Fig.D.1 does not mention Chapter 2 thicknesses and only specifies the 179.201-1 table.\n\n<<<PAGE 6>>>\n\n§179.201-1 Individual specification requirements.\nIn addition to $179.200, the individual specification requirements are as follows:\nMinimum\nDOT\nSpecification' Insulation\nBursting\nthickness\nplate\nTest\nReferences\npressure\nBottom Bottom (179.201\npressure (psig)\n(inches)\n(psig)\noutlet washout +**)\n111A60ALW1\nOptional\n240\n60 Optional Optional 6(a).\n111A60ALW2\nOptional\n240\n60 NO\nOptional.\n111A60W1\nOptional\n240\n16\n60 Optional Optional 6(a).\n111A60W2\nOptional\n240\n60 No\nOptional.\n111A60W5\nOptional\n240\n¾16|\n60 NO\nNO\n3, 6(b).\n111A60W6\nOptional\n240\n16\n60 Optional Optional 4, 5, 6(a), 6(c).\n111A60W7\nOptional\n240\n60 No\nNo\n4, 5, 6(a).\n111A100ALW1 Optional\n500\n100 Optional Optional 6(a).\n111A100ALW2 Optional\n500\n100 No\nOptional.\n111A100W1\nOptional\n500\n16\n100 Optional Optional 6(a).\n111A100W2\nOptional\n500\n16\n100 No\nOptional.\n111A100W3\nYes\n500\n100 Optional Optional 6(a).\n111A100W4\nYes (see\n500\n179.201-11)\n716/\n100 NO\nNo\n6(a), 8, 10.\n111A100W5\nOptional\n500\n\"16\n100 No\nNo\n3.\n111A100W6\nOptional\n500\n16\n100 Optional Optional |4, 5, 6(a) and\n111A100W7\nOptional\n6(C).\n500\n100 NO\nNo\n4, 5, 6(c).\n'Tanks marked \"ALW\" are constructed from aluminum alloy plate; \"AN\" nickel plate; \"CW,\" \"DW,\" \"EW.\"\n\"W6,\" and \"W7\" high alloy steel or manganese-molybdenum steel plate; and those marked \"BW\" or \"W5\" must\nhave an interior lining that conforms to 5179.201-3.\n[Amdt. 179-52, 61 FR 28680, June 5, 1996, as amended by 66 FR 45390, Aug. 28, 2001; 68 FR 48571, Aug. 14, 2003]\n\n<<<PAGE 7>>>\n\n(f) Thickness tests. (1) The tank car owner must ensure that each tank car facility measures the thickness\nof the tank car shell, heads, sumps, protective housing (i.e., domes), and nozzles on each tank car by using a\ndevice capable of accurately measuring the thickness to within ‡0.05 mm (#0.002 inch).\n(2) The tank car owner must ensure that each tank car has a thickness test measurement:\n(i) At the time of an internal coating or lining application or replacement, or\n(ii) At least once every ten (10) years for a tank that does not have an internal coating or lining. or\n(il) At least once every five (5) years for a tank that does not have an internal coating or lining when:\n(A) The tank is used to transport a material that is corrosive or reactive to the tank (see Appendix D of this\npart) or service equipment as defined $180.503, and\n(B) The remaining shell and head thickness is tested and determined to be at or below line C in Figure A\nof this paragraph.\nEigure A\nTank and Shell Thickness Qualification Frequencies\nAdditional thickness\n10 year inspection interval\n5 year inspection interval\nF\nA E\nLocalized reductions only\nView or download PDF\nWhere:\nA. As-built tank shell or head thickness with additional thickness\nB. Required minimum tank shell or head thickness after forming per part 179.\nC. Inspection frequency adjustment point (design minimum shell or head thickness, minus ½ of the table value in paragraph (g)\nof this section).\nD. Condemning limit for general corrosion (required minimum shell or head thickness, minus the value in paragraph (g) of this\nsection).\nE. Condemning limit for localized corrosion (required minimum shell or head thickness, minus the table value in paragraph (g)\nof this section, minus 1.58 mm (16 inch)). See Note 1 in paragraph (g) of this section for diameter limitations and\nminimum separation distances.\nF. Allowable shell or head thickness reduction (table value in paragraph (g) of this section).\nG. Additional thickness reduction for localized areas in paragraph (g) of this section.\n\n<<<PAGE 8>>>\n\n2.5 Requirements for DOT/TC Tank Cars Weighing Over 263,000 Ib GRL\n2.5.1 All Class DOT/TC Tank Cars\nthe gross weight exceeds 263,000 lb.\nParagraph 2.5 applies to all Class DOT and TC tank cars ordered after December 31, 2003, when\n2.5.1.1 Cars must comply with all requirements of the Office Manual of the AAR Interchange\nRules, latest version.\n2.5.1.1.1 Cars must be in conformance with the truck requirements located in MSRP\nStandard S-286 as required in the Office Manual of the AÅR Interchange Rules, Rule 88.\n2.5.1.2 Shippers are reminded that regulations limit the gross weight of Class DOT/TC tank cars\nto 263,000 Ib and that a federal exemption is required to operate these cars at heavier weights.\n2.5.1.3 In addition to the design loads described in MSRP S-286, all REPOS loading, including\n1.09 above the loading used for 263,000 Ib cars.\norizontal and vertical coupler loads, used for fatigue calculations must be increased by a factor of\nand must have a \"life-cycle\" maintenance plan for cars. This must identify inspection items,\n2.5.1.4 Car owner must identify appropriate areas of inspection for fatigue, corrosion, wear, etc.,\nIMPLEMENTED 08/2018\ninspection methods, acceptance criteria, and inspection frequencies. The car owner or designee\nmust have written procedures that ensure that work performed on cars conforms to federal and\nAAR requirements.\n2.5.1.5 New cars may not be equipped with reconditioned truck components.\nover 263,000 Ib are not authorized.\n2.5.1.6 Class DOT/TC cars with tanks constructed of aluminum or nickel plate with gross weight\n2.5.2 Class DOT/TC-111 Nonpressure Tank Cars\nAppendix E, paragraph 9.2.\n2.5.2.1 Class DOT/TC-111 cars must be equipped with top fittings protection in accordance with\nwhere the applicant can demonstrate that a non-reclosing device affords an equivalent level of\n2.5.2.2 Class DOT/TC-111 cars must be equipped with reclosing pressure relief devices, except\nsafety.\ncriteria:\n2.5.2.3 Class DOT/TC-111 cars with carbon steel tanks must meet one of the following minimum\n• Tanks are constructed of normalized 'TC128 steel at least 7/16 in. thick and equipped with\nsteel jackets and 1/2 in. thick steel jacket heads.\n• Tanks are constructed of normalized TC128 steel at least 1/2 in. thick and equipped with\n1/2 in. thick steel half-head shields.\n• Tanks are constructed of normalized ASTM A516 steel at least 1/2 in. thick and equipped\nwith steel jackets and 1/2 in. thick steel jacket heads.\n• Tanks are constructed of normalized ASTM A516 steel at least 5/8 in. thick and equipped\nwith 1/2 in. thick steel half-head shields.\n\n<<<PAGE 9>>>\n\nPlease & Thank You,\nKeenan Moore\nFleet Management Specialist\nKeenan@TCIXRail.com\nOffice: (903) 653-4077\nCell: (903) 241-4079","truncated":false,"body_characters":14963}