Interpretation Response #15-0133 ([National Steel Car Limited] [Mr. Max Vanderby])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/21/2015

Company Name: National Steel Car Limited

Individual Name: Mr. Max Vanderby

Country: CA

View the Interpretation Document

Response text:

October 21, 2015

Mr. Max Vanderby
Director of Production Engineering
National Steel Car Limited
600 Kenilworth Ave. North
P.O. Box 2450
Hamilton, Ontario L8N 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/mm2 (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.

Q3. 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-resistance system, a thermal protection system, and a metal jacket must have the letter "J" substituted for the letter "A" or "S" in the specification marking".

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.

Sincerely,

Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division

179.16(c)(1), 179.16(a), 179.16(c)(2), 179.22, 179.22(c)

Regulation Sections