{"operation":"document","citation":"22-0094","title":"AllTranstek, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2023-01-26","effective_on":null,"summary":"22-0094 response to AllTranstek, LLC concerning 180.509.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0094.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0094.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0094","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/77236/220094.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJanuary 17, 2023\nLarry Loman\nDirector, Engineering\nAllTranstek, LLC\n1101 W. 31st Street, Suite 200\nDowners Grove, IL 60515\nReference No. 22-0094\nDear Mr. Loman:\nThis letter is in response to your September 7, 2022, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to structural\nintegrity inspections and testing for rubber-lined DOT 111A100W5 tank cars that were qualified\nfor service by a Canadian tank car facility. In your email, you state that these tank cars were\nconstructed with exterior heater coils that cover the tank shell butt welds and that fact\ncomplicates the ability to inspect and test the structural integrity of the tank shell butt welds in\naccordance with § 180.509(e)(1)(iii). You further state that it is your understanding that this is\nnot required for rubber-lined tank cars with reinforced tank shell butt welds until such time the\nlining is removed in accordance with § 180.509(e)(3). You ask whether the heater coils that\ncover the tank shell butt welds would allow for the butt welds to be treated as reinforced tank\nshell butt welds, thereby only requiring inspection at the time of lining removal or application.\nThe answer is no, having heater coils that cover the tank shell butt welds would not constitute\nreinforced tank shell butt welds. However, this fact would not itself require the tank cars owner\nto cut the heater coils to allow for inspection and testing of the tank shell butt welds within two\n(2) feet of the bottom longitudinal centerline. As stated in § 180.509(e)(1)(iii), the tank shell butt\nwelds must be tested unless the tank car owner can determine by analysis—e.g., finite element\nanalysis, damage-tolerance analysis, or service reliability assessment—that the structure will not\ndevelop defects that reduce the design level of safety and reliability or fail within its operational\nlife or prior to the next required inspection. Please note the tank car owner must also maintain all\ndocumentation used to make such determination at its principal place of business and make the\ndata available to the Federal Railroad Administration or an authorized representative of the\nDepartment upon request.\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<<>>\n\nCasey\n22-0094\nFrom: INFOCNTR (PHMSA)\nTo: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps\nFW: 49 CFR 180.509(e)(3) Interpretation Request\nFriday, September 16, 2022 2:05:49 PM\nHi Alice and team,\nRachel (HMIC)\nPlease see the following LOI request. They included their mailing address in a separate email. Thank you.\nFrom: Larry Loman \nSent: Thursday, September 8, 2022 2:47 PM\nTo: INFOCNTR (PHMSA) \nCc: Dave Ronzani \nSubject: RE: 49 CFR 180.509(e)(3) Interpretation Request\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not\nclick on links or open attachments unless you recognize the sender and know the content is safe.\nLarry Loman\nAllTranstek\n1101 W 31st Street\nSuite 200\nDowners Grove, IL 60515\nThank you and let me know if you need anything else.\nLarry\nLarry Loman\nDirector, Engineering\nAllTranstek, LLC\nOffice: 630-829-9441\nCell: 708-899-8203\nloman@alltranstek.com\nCONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain\nconfidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended\nrecipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this\ntransmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy the\noriginal transmission and its attachments without reading or saving in any manner. Thank you, AllTranstek, LLC.\nFrom: INFOCNTR (PHMSA) \nSent: Thursday, September 8, 2022 11:41 AM\nTo: Larry Loman \nCc: Dave Ronzani \nSubject: RE: 49 CFR 180.509(e)(3) Interpretation Request\nDear Larry,\nWe have received your request for a written letter of interpretation regarding the hazardous materials\n\n<<>>\n\nregulations (49 CFR Parts 171-180). The hazardous materials regulations are available at the following URL:\nhttps://www.phmsa.dot.gov/phmsa-regulations\nHowever, before we can submit your request for processing, please respond to this email with:\nPhysical Mailing Address\nSincerely,\nRachel, 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-\nmaterials-information-center\nFrom: Larry Loman \nSent: Wednesday, September 7, 2022 5:36 PM\nTo: INFOCNTR (PHMSA) \nCc: Dave Ronzani \nSubject: 49 CFR 180.509(e)(3) Interpretation Request\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not\nclick on links or open attachments unless you recognize the sender and know the content is safe.\nAllTranstek has a customer shipping Sodium Hypochlorite (Bleach) in DOT 111A100W5 tank cars with a\nqualified interior rubber lining installed in 2012. Structural integrity inspections are due this year per\n49CFR180.509(e) and the subject jacketed cars have exterior heater coils. Twenty (20) of these cars were\nqualified by a Canadian tank car facility, so Transport Canada was contacted about the inspection of the\ntank shell butt welds under the exterior heater coils.\nShaun Singh of Transport Canada has indicated that the heater coils are not to be cut out for the sole\npurpose of structural integrity inspection. He also stated that if any tank butt shell welds within 24 inches of\nthe bottom longitudinal centerline are covered by exterior heater coils, these welds still need to be\ninspected from the interior of the tank unless lined as per clause 9.5.7.4 (TP14877).\n9.5.7.4 In the case of tank cars with a lining, the inspection requirements of clause 9.5.7.2.c do not\napply to a tank shell butt weld covered on the outside by a reinforcing plate or any other structural\nelement welded to the tank shell until the time of lining removal or application.\nThe email request and response from Shaun Singh of Transport Canada are attached.\n180.509(e)(1)(iii) requires inspection of the tank shell butt welds within 2 feet of the longitudinal centerline.\nSimilar to clause 9.5.7.4 of TP14877, 49 CFR 180.509(e)(3) states:\nThe inspection requirements of paragraph (e)(1)(iii) of this section do not apply to reinforced tank\nshell butt welds until the time of lining removal or application for tank cars with an internal lead,\n\n<<>>\n\nglass, or rubber lining.\nAt the time of lining replacement, the tank shell butt welds will be inspected from the tank interior using the\nvisual and/or ultrasonic inspection method(s). In between lining replacements, during structural integrity\ninspections, the welds not covered by the heater coils will be inspected from the exterior through inspection\nports cut in the jacket using the visual and/or remote visual inspection method(s).\nCutting the heater coil to inspect these welds under the coils and the coil attachment fillet welds could do\nmore harm than good because these tank shell butt welds are not known to exhibit cracking or other\ndefects from stress.\nQuestion: These cars will be operating or may be qualified in the United States under 49CFR, so can the\nheater coil over a tank shell butt weld be treated like a “reinforced tank shell butt weld” as permitted by\nTransport Canada and not be cut/removed for inspection?\nThank you,\nLarry\nLarry Loman\nDirector, Engineering\nAllTranstek, LLC\nOffice: 630-829-9441\nCell: 708-899-8203\nloman@alltranstek.com\nCONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain\nconfidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended\nrecipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this\ntransmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy the\noriginal transmission and its attachments without reading or saving in any manner. Thank you, AllTranstek, LLC.","truncated":false,"body_characters":8954}