AllTranstek, LLC — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration January 17, 2023 Larry Loman Director, Engineering AllTranstek, LLC 1101 W. 31st Street, Suite 200 Downers Grove, IL 60515 Reference No. 22-0094 Dear Mr. Loman: This letter is in response to your September 7, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to structural integrity inspections and testing for rubber-lined DOT 111A100W5 tank cars that were qualified for service by a Canadian tank car facility. In your email, you state that these tank cars were constructed with exterior heater coils that cover the tank shell butt welds and that fact complicates the ability to inspect and test the structural integrity of the tank shell butt welds in accordance with § 180.509(e)(1)(iii). You further state that it is your understanding that this is not required for rubber-lined tank cars with reinforced tank shell butt welds until such time the lining is removed in accordance with § 180.509(e)(3). You ask whether the heater coils that cover the tank shell butt welds would allow for the butt welds to be treated as reinforced tank shell butt welds, thereby only requiring inspection at the time of lining removal or application. The answer is no, having heater coils that cover the tank shell butt welds would not constitute reinforced tank shell butt welds. However, this fact would not itself require the tank cars owner to cut the heater coils to allow for inspection and testing of the tank shell butt welds within two (2) feet of the bottom longitudinal centerline. As stated in § 180.509(e)(1)(iii), the tank shell butt welds must be tested unless the tank car owner can determine by analysis—e.g., finite element analysis, damage-tolerance analysis, or service reliability assessment—that the structure will not develop defects that reduce the design level of safety and reliability or fail within its operational life or prior to the next required inspection. Please note the tank car owner must also maintain all documentation used to make such determination at its principal place of business and make the data available to the Federal Railroad Administration or an authorized representative of the Department upon request. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Casey 22-0094 From: INFOCNTR (PHMSA) To: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps FW: 49 CFR 180.509(e)(3) Interpretation Request Friday, September 16, 2022 2:05:49 PM Hi Alice and team, Rachel (HMIC) Please see the following LOI request. They included their mailing address in a separate email. Thank you. From: Larry Loman <loman@alltranstek.com> Sent: Thursday, September 8, 2022 2:47 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Dave Ronzani <ronzani@alltranstek.com> Subject: RE: 49 CFR 180.509(e)(3) Interpretation Request CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Larry Loman AllTranstek 1101 W 31st Street Suite 200 Downers Grove, IL 60515 Thank you and let me know if you need anything else. Larry Larry Loman Director, Engineering AllTranstek, LLC Office: 630-829-9441 Cell: 708-899-8203 loman@alltranstek.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner. Thank you, AllTranstek, LLC. From: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Sent: Thursday, September 8, 2022 11:41 AM To: Larry Loman <loman@alltranstek.com> Cc: Dave Ronzani <ronzani@alltranstek.com> Subject: RE: 49 CFR 180.509(e)(3) Interpretation Request Dear Larry, We have received your request for a written letter of interpretation regarding the hazardous materials#

Page 3regulations (49 CFR Parts 171-180). The hazardous materials regulations are available at the following URL: https://www.phmsa.dot.gov/phmsa-regulations However, before we can submit your request for processing, please respond to this email with: Physical Mailing Address Sincerely, Rachel, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. https://www.phmsa.dot.gov/standards-rulemaking/hazmat/hazardous- materials-information-center From: Larry Loman <loman@alltranstek.com> Sent: Wednesday, September 7, 2022 5:36 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Dave Ronzani <ronzani@alltranstek.com> Subject: 49 CFR 180.509(e)(3) Interpretation Request CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. AllTranstek has a customer shipping Sodium Hypochlorite (Bleach) in DOT 111A100W5 tank cars with a qualified interior rubber lining installed in 2012. Structural integrity inspections are due this year per 49CFR180.509(e) and the subject jacketed cars have exterior heater coils. Twenty (20) of these cars were qualified by a Canadian tank car facility, so Transport Canada was contacted about the inspection of the tank shell butt welds under the exterior heater coils. Shaun Singh of Transport Canada has indicated that the heater coils are not to be cut out for the sole purpose of structural integrity inspection. He also stated that if any tank butt shell welds within 24 inches of the bottom longitudinal centerline are covered by exterior heater coils, these welds still need to be inspected from the interior of the tank unless lined as per clause 9.5.7.4 (TP14877). 9.5.7.4 In the case of tank cars with a lining, the inspection requirements of clause 9.5.7.2.c do not apply to a tank shell butt weld covered on the outside by a reinforcing plate or any other structural element welded to the tank shell until the time of lining removal or application. The email request and response from Shaun Singh of Transport Canada are attached. 180.509(e)(1)(iii) requires inspection of the tank shell butt welds within 2 feet of the longitudinal centerline. Similar to clause 9.5.7.4 of TP14877, 49 CFR 180.509(e)(3) states: The inspection requirements of paragraph (e)(1)(iii) of this section do not apply to reinforced tank shell butt welds until the time of lining removal or application for tank cars with an internal lead,#

Page 4glass, or rubber lining. At the time of lining replacement, the tank shell butt welds will be inspected from the tank interior using the visual and/or ultrasonic inspection method(s). In between lining replacements, during structural integrity inspections, the welds not covered by the heater coils will be inspected from the exterior through inspection ports cut in the jacket using the visual and/or remote visual inspection method(s). Cutting the heater coil to inspect these welds under the coils and the coil attachment fillet welds could do more harm than good because these tank shell butt welds are not known to exhibit cracking or other defects from stress. Question: These cars will be operating or may be qualified in the United States under 49CFR, so can the heater coil over a tank shell butt weld be treated like a “reinforced tank shell butt weld” as permitted by Transport Canada and not be cut/removed for inspection? Thank you, Larry Larry Loman Director, Engineering AllTranstek, LLC Office: 630-829-9441 Cell: 708-899-8203 loman@alltranstek.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner. Thank you, AllTranstek, LLC.#