Minor update, drilled 3/8 fairly easily with a handheld drill and no pilot hole, of course much easier (and nice spirals) when using a small pilot hole. The holes were for some lower strength eye-bolts for tying down light stuff and tarps, and I was able to put these holes into 'non-load bearing' areas, considering both weight and towing forces.
Spark test looked like the "low carbon/cast steel" and "wrought iron" from the previously linked pics.
Thanks for all the info-
Dave