West Building, W35-322 U.S. Department 1200 New Jersey Avenue S.E.

of Transportation Washington, D.C. 20590

Federal Railroad Administration 

FRA-AIP 201901-C 

REVIEW DATE: January 1, 2025 

1. GRANTEE: 

 GATX Corporation 

233 S. Wacker Drive 

Chicago, Illinois 60606-7147 

2. PURPOSE AND LIMITATION: 

a. This approval authorizes the use of an Alternative 

Inspection and Test Program as allowed by 49 CFR § 

180.509(l) Alternative inspection and test procedures. This 

letter provides no relief from the Hazardous Materials 

Regulations (HMR) other than as expressly stated herein. 

The most recent revision supersedes all previous revisions. 

b. The damage-tolerance analysis or service reliability 

assessment performed in developing this Alternative 

Inspection and Test Program (AIP) only considered the 

hazards and risks associated with transportation in 

commerce. 

c. This approval to use an alternative inspection and 

test program is non-transferable. 

3. REGULATIONS AFFECTED: 49 CFR §§ 180.509(d), 180.509(e) 

180.509(f), 180.509(i). 

4. BASIS: This approval is based on the applications of GATX 

Corporation from 2001, May 19, 2010, May 25, 2016, and 

November 19, 2021, submitted per § 180.509(l). This letter 

supersedes the previous approvals dated September 24, 2020, 

October 19, 2001, August 11, 2010, January 23, 2013, and 

March 4, 2021. 
Continuation of FRA-AIP 201901-C Page 2 of 7

5. INSPECTION AND TEST PROCEDURES: 

a. DEFINITIONS: 

1. Service Reliability Assessment – the process, of 

using in-service data to determine the time a tank car 

or component will continue to function as designed 

under specified conditions. 

2. Tank Car Owner - the person to whom a rail car's 

reporting marks are assigned, as listed in the 

Universal Machine Language Equipment Register (UMLER). 

3. Damage-Tolerance Analysis – Determination of the 

probable locations and modes of damage due to 

manufacturing, fatigue, corrosion, or accidental 

damage. The analysis must establish a period of 

time/load cycles during which it is demonstrated that 

widespread fatigue or corrosion damage will not occur 

in the tank car structure. 

b. BENCHMARK TESTING: 

 

1. All GATX tank cars covered by this approval must 

have Ultrasonic Thickness Testing (UTT) measurements 

for every tank car taken at the time of manufacture. 

For tank cars lacking these measurements, UTT 

measurements must be taken at the time of the 

following qualification but not to exceed the maximum 

allowable interval given in 49 CFR § 180.509(f) or the 

maximum interval permitted by an applicable approved 

Alternative Inspection Program. 

2. All GATX tank cars covered by this approval must 

have initial structural integrity weld inspections of 

the welds listed in § 6(a) below taken at the time of 

manufacture. Tank cars lacking these measurements 

should be taken at the time of the following 

qualification. 

c. DESIGN LEVEL OF RELIABILITY AND SAFETY: GATX must 

ensure that the tank car tank thickness and any visually 

detected weld flaws do not decrease its design level of 

reliability and safety. 

d. SENSITIVITY and RELIABILITY 
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1. For tank cars using Visual Inspection and Testing 

(VT) procedures in place of UTT procedures, GATX must 

determine the level of reliability, sensitivity, and 

minimum detectable flaw size for the proposed 

inspection method. For tank cars using VT procedures 

in place of Ultrasonic Inspection and Testing (UT) 

procedures to inspect transverse butt welds, GATX must 

determine the level of reliability, sensitivity, and 

minimum detectable flaw size for the proposed 

inspection method. 

2. For tank cars that will not have the structural 

integrity weld inspections listed in § 6(a) below, 

GATX must determine the level of reliability, 

sensitivity, and minimum detectable flaw size for the 

proposed inspection method at the listed inspection 

sites. 

e. CONTROL:

1. GATX must perform UTT testing on a representative 

sample of the fleet covered by this AIP approval. The 

frequency must be based on the identified corrosion 

rate, utilization, and other factors to maintain the 

design level of reliability and safety and shall be 

made available to FRA or a designated representative 

upon request. The sample size must be determined by 

following recognized industry sampling standards. 

2. GATX must perform structural integrity weld 

inspections on the welds listed in § 6(a) below on a 

representative sample of the fleet covered by this AIP 

approval. The frequency must be based on the 

identified corrosion rate, utilization, and other 

factors to maintain the design level of reliability 

and safety and shall be made available to FRA or a 

designated representative upon request. The sample 

size must be determined by following recognized 

industry sampling standards. 

6. REGULATORY RELIEF: 

a. Inspection of the below-listed welds is not required 

until the car has exceeded 1,000,000 miles: 

1. Longitudinal fillet weld on outboard stub sill 
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reinforcing pad to tank (TCID A2) 

2. Fillet weld on outboard stub sill cutout 

reinforcing pad to tank (TCID A3) 

3. Longitudinal fillet weld on inboard stub sill 

reinforcing pad to tank (TCID A4) 

4. Transverse groove weld on inboard stub sill 

reinforcing pad to bolster reinforcing pad (TCID 

A7) 

5. Longitudinal fillet weld on inboard stub sill 

reinforcing pad slot to tank (TCID A8) 

6. Transverse fillet weld on inboard stub sill 

reinforcing pad (transition reinforcing pad) to 

tank (TCID A15) 

7. Longitudinal fillet weld on termination of the 

inside of reinforcing pad (re-bar) to tank (TCID 

A44) 

8. Transverse portion of fillet weld to the tank on 

bottom outlet saddle (TCID G1) 

9. Transverse portion of fillet weld to the tank on 

sump (TCID H1) 

10. Fillet welds on brake rigging support reinforcing 

pads to tank (TCID Other) 

b. VT may be utilized instead of UT when inspecting 

transverse butt welds of tank car tanks made ASTM A515-GR 

70, ASTM A516-GR 70, AAR TC128 GR B, ASTM A-240 Type 316L, 

ASTM A-240 Type 304L, and ASTM A-240 Type 304. UT must 

still be used on a sampling of high mileage cars. 

c. UTT measurements may be taken through existing 

coatings at the time of qualifications on all tank cars 

except tank cars with specifications 111A60W5, 111A100W5, 

or tank cars constructed of stainless steel or aluminum 

alloys. 

d. After benchmark UTT measurements are taken, GATX may 

follow this AIP using visual inspections coupled with local 

UTT measurements when visible corrosion is observed on the 

interior or exterior of the tank. 

e. Section 180.509(f)(3) - For a localized repair of an 

internal lining or coating where a material corrosive to 

the tank as defined § 180.503 has contacted the tank, GATX 

may use visual inspections to determine if there is 

thickness loss instead of UTT. If thickness loss is 
Continuation of FRA-AIP 201901-C Page 5 of 7

observed, UTT measurements must be taken to determine the 

localized thinning of the tank. 

7. SPECIAL PROVISIONS: 

a. A person who is not a holder of this AIP approval who 

receives a package covered by this AIP approval may reoffer 

it for transportation provided no modification or change is 

made to the package or its contents, and it is reoffered 

for transportation in conformance with this AIP approval 

and the HMR. 

b. A current copy of this AIP approval must be maintained 

at each facility where the package is maintained and/or 

repaired. 

c. Marking of each tank car is required and must meet the 

marking and labeling requirements of 49 CFR Part 172, 

Subpart D. The car must be identified by a stencil or 

decal placed above the tank specification number. The 

stencil must have at least 1 1/2-in high (38.1 mm) letters 

and numbers and display “FRA-AIP 201901.” Additionally, 

the car must have the initial qualification year 

(QUALIFIED) and the subsequent qualification year (DUE). 

This interval must be developed from the Service 

Reliability Assessment. The marking must occur at the time 

of next shopping by a tank car facility, not to exceed the 

maximum allowable interval given in 49 CFR § 180.509(c)(3) 

or the maximum interval permitted by an applicable AIP. 

d. If a tank car operating under this approval is removed 

from the AIP, all AIP markings must be removed. 

8. COMPLIANCE: Failure by a person to comply with any of the 

following may result in suspension or revocation of this 

approval and penalties prescribed by the Federal hazardous 

materials transportation laws, 49 U.S.C. § 5101 et seq.

a. The grantee must comply with all terms and conditions 

prescribed in this approval and the HMR, 49 CFR Parts 171-

180. 

b. Each "Hazmat employee," as defined in § 171.8, who 

performs a function subject to this approval must receive 

training on the requirements and conditions of this AIP in 

addition to the training required by §§ 172.700 through 
Continuation of FRA-AIP 201901-C Page 6 of 7

172.704. 

c. No person may use or apply this AIP, including the 

display of its number, when this approval has lapsed or is 

otherwise no longer in effect. 

9. REPORTING REQUIREMENTS: 

a. GATX must notify the Associate Administrator for 

Railroad Safety, Chief Safety Officer, in writing no later 

than 30 days after notification of any incident involving a 

Tank Car conducted under terms of this AIP. 

b. GATX must report instances of corrosion damage or tank 

failure not considered in the damage-tolerance analysis or 

service reliability assessment on any car subject to this 

approval to FRA within five days of being notified of such 

occurrence. 

c. GATX must maintain a listing of tank cars by reporting 

the mark and number operating under this approval to 

include the status of the above-required marking and will 

report this listing to FRA every five years or upon 

request. 

d. GATX must report CONTROL results (see paragraph 5(d) 

above) to FRA every five years or upon request. 

10. LIMITATIONS: 

 a. If a tank car operating under this approval is 

transferred from GATX to another Tank Car Owner, then the 

tank car will no longer be subject to the relief granted 

under this approval and all the above-required stenciling 

must be removed. The qualification due date must be changed 

to reflect the new Tank Car Owner’s Qualification Interval 

under the new Tank Car Owner’s qualification and 

maintenance program. If the new due date is passed, the 

qualification is due immediately. 

11. CANCELLATION: 

FRA may rescind this approval for failure to comply with 

its terms. 
Continuation of FRA-AIP 201901-C Page 7 of 7

Issued in Washington, D.C.: 

______________________________________ April 8, 2022 

Karl Alexy 

Associate Administrator for Railroad Safety 

Chief Safety Officer 

Address all inquiries to Randy M Keltz Jr., Manager, Tank Car 

Safety Programs, Federal Railroad Administration, U.S. 

Department of Transportation, West Building, 1200 New Jersey 

Avenue, Southeast, Washington, D.C. 20590. 

Photo reproductions and legible reductions of this approval are 

permitted. Any alteration of this approval is prohibited. 

REVISION HISTORY 

REV DATE DESCRIPTION 

 01/2019 Original approval 

A 08/2020 Section 5(b) changed to clarify maximum interval 

allowed to include other AIPs; Added limitations 

section to clarify that the allowances of this AIP 

do not transfer ownership with the tank car if the 

car is transferred; added definition of Tank Car 

Owner to align with 49 CFR. 

B 3/2021 Incorporate terms from GATX AIP 200107, GATX AIP 

201005, and GATX AIP 201201 and update reporting 

language; relocated regulatory relief section 

C 3/2022 Add section 6(e), allowing for the use of visual 

inspection to determine if thickness loss has 

occurred where an internal lining or coating is 

damaged.