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

of Transportation Washington, D.C. 20590

Federal Railroad Administration

FRA-AIP 200203-B

REVIEW DATE: January 1, 2025

1. GRANTEE: 

 Union Tank Car Company 

175 W. Jackson Blvd. 

Suite 2100 

Chicago, IL 60604 

2. PURPOSE AND LIMITATION: 

a. This approval authorizes the use of an alternative 

inspection and test procedure as allowed by 49 CFR 

180.509(l) Alternative inspection and test procedures. 

(Referred to below as “Alternative Inspection Program.”) 

This letter provides no relief from the Hazardous Materials 

Regulations (HMR) other than specifically stated herein. 

The most recent revision supersedes all previous revisions. 

b. The damage tolerance analysis or service reliability 

assessment performed in the development of this Alternative 

Inspection Program only considered the hazards and risks 

associated with the transportation in commerce. 

 c. Unless otherwise stated herein, this approval consists 

of this Alternative Inspection Program authorization letter 

issued to UNION TANK CAR COMPANY.

 d. This approval to use an Alternative Inspection Program 

is non-transferrable.

3. REGULATIONS AFFECTED: 49 CFR § 180.509(e)(1)(iii). 

4. BASIS: This approval is based on the application of UNION 

TANK CAR COMPANY dated March 4, 2002 and revision request 

dated November 2, 2022, submitted in accordance with § 

180.509(l). 
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5. INSPECTION AND TEST PROCEDURES: 

a. Definitions 

1. Service Reliability Assessment – the quantified 

ability of a tank car or component to remain 

railworthy. A service reliability assessment is 

developed from in-service data. 

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). 

b. BENCHMARK TESTING – UNION TANK CAR COMPANY shall 

develop a sampling plan to measure the adequacy of tank 

shell butt welds within 60.96 cm (2 feet) of the bottom 

longitudinal centerline with an approved Non-Destructive 

Testing (NDT) method at the time of manufacture. This does 

not provide any relief from the requirements of AAR MSRP 

Section C-III Appendix W. For tank cars lacking these 

measurements, UNION TANK CAR COMPANY shall perform the 

required 49 CFR 180.509(c)inspection and tests of tank 

shell butt welds within 60.96 cm (2 feet) of the bottom 

longitudinal centerline at the time of the next 

qualification but not exceeding the maximum allowable 

interval given in 49 CFR 180.509(c)(3) or the maximum 

allowable interval permitted by an applicable approved 

Alternative Inspection Program. The sample size must be 

determined by following recognized industry sampling 

standards. 

For non-UNION TANK CAR COMPANY built cars, at a minimum, 

separate benchmark testing must be developed for each 

underframe manufacturer, and for each different design, as 

needed. 

c. DESIGN LEVEL OF RELIABILITY AND SAFETY – UNION TANK 

CAR COMPANY shall maintain an 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. UNION TANK CAR COMPANY shall 

maintain all documentation used to make such determination 

at its principal place of business and make the data 

available to the Federal Railroad Administration (FRA) or 
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an authorized representative of the Department of 

Transportation upon request. 

For non-UNION TANK CAR COMPANY built cars,at a minimum, a 

separate analysis must be maintained for each underframe 

manufacturer and for each different design, as needed. 

d. SENSITIVITY AND RELIABILITY – UNION TANK CAR COMPANY 

shall develop and execute a sensitivity and reliability 

(POD) study to determine the level of reliability, 

sensitivity, and minimum detectable flaw size for the NDT 

methods and techniques used to maintain the design level of 

reliability and safety. 

For non-Union Tank Car built cars, at a minimum, a separate 

POD study must be developed for each underframe 

manufacturer and for each different design, as needed. 

e. CONTROL – UNION TANK CAR COMPANY shall perform the 

required inspection and test of tank shell butt welds within 

60.96 cm (2 feet) of the bottom longitudinal centerline on a 

representative subgroup of the fleet covered by this 

Alternative Inspection Program approval based on the 

identified crack development and growth rate, utilization, 

and other factors to ensure continued applicability of this 

program. All tank cars in this sample must have benchmark 

testing as defined in section (b) above. These reports shall 

be made available to FRA or a designated representative of 

FRA upon request. The sample size must be determined by 

following recognized industry sampling standards. 

For non-UNION TANK CAR COMPANY built cars, at a minimum, 

separate control sample groups must be developed for each 

underframe manufacturer and for each different design, as 

needed. 

6. SPECIAL PROVISIONS: 

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

receives a package covered by this Alternative Inspection 

Program 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 approval and the HMR. 

b. A copy of this approval shall be maintained at each 
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facility where the package is qualified and/or maintained. 

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

marking and labeling requirements of 49 CFR Part 172, 

Subparts D and E. The car must be identified by a stencil 

or decal placed above the tank car specification number. 

The stencil must have at least 1 1/2-inch high (38.1 mm) 

letters and numbers and display “FRA-AIP 200203.” 

Additionally, the car must have the initial qualification 

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

This interval must be developed from the service 

reliability assessment. The marking must occur at the time 

of the 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 allowable interval permitted 

by an applicable approved Alternative Inspection Program. 

7. 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 law, 49 U.S.C. 5101 et seq. 

a. All terms and conditions prescribed in this approval 

and the Hazardous Materials Regulations, 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 

Alternative Inspection Program in addition to the training 

required by §§ 172.700 through 172.704. 

c. No person may use or apply this Alternative Inspection 

Program, including the display of its number, when this 

approval has lapsed or is otherwise no longer in effect. 

8. REPORTING REQUIREMENTS: 

a. UNION TANK CAR COMPANY shall notify FRA’s Associate 

Administrator for Railroad Safety, Chief Safety Officer, in 

writing no later than 30 days after any incident involving 

tank shell butt welds within 60.96 cm (2 feet) of the tank 

car’s bottom longitudinal centerline conducted under terms 

of this Alternative Inspection Program. 

b. UNION TANK CAR COMPANY shall report in writing to 
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FRA’s Associate Administrator for Railroad Safety, Chief 

Safety Officer, no later than 30 days after notification of 

occurrence, instances of corrosion damage or tank failure 

not considered in the damage tolerance analysis or service 

reliability assessment that adversely affects tank shell 

butt welds within 60.96 cm (2 feet) of the bottom 

longitudinal centerline on any Tank Car subject to this 

Alternative Inspection Program. 

c. UNION TANK CAR COMPANY shall maintain a list of tank 

cars by reporting mark and number operating under this 

approval to include the status of the above-required 

marking and shall report this list to the FRA every 5 

years, or upon request. 

d. UNION TANK CAR COMPANY shall report CONTROL results to 

the FRA every 5 years, or upon request. 

9. LIMITATIONS: 

 a. If a tank car operating under this approval is 

transferred from UNION TANK CAR COMPANY to another Tank Car 

Owner, 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 in accordance with the new Tank Car 

Owner’s qualification and maintenance program. 

10. CANCELLATION 

The FRA may rescind this approval for failure to comply 

with its terms. 

Issued in Washington, D.C.: 

________________________ December 12, 2023 

Karl Alexy 

Associate Administrator for Railroad Safety 

Chief Safety Officer 
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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

03/2002 Original approval

A 09/2020 Updated format; added review terms; added control 

conditions; added limitations;

B 12/2023 Add requirements for applying AIP to non-Unionbuilt tank cars