Hello Linn:



The recertification is part of the licensing process. As far as the requirement for a degree by ASME that is true ... however ... if you are offering engineering services to the public, a firm is required to have a licensed engineer on staff. The design, construction and repair of a boiler is considered to be an engineering service.



This can be said about anyone and any profession. In the engineering profession our mistakes are usually on the front page of the newspaper or the lead item on the 6 O'Clock news.



For a railroad that is subject to part 230, that would be the FRA and the requirements of Part 230. The burden of compliance with Part 230 is placed onto the owner and operator concurrently. On a new boiler boiler constructed to comply with Part 230, that will be the current ASME Section I and the additional FRA requirements that are the standards. On an existing boiler, that would be the current NBIC, the current ASME Section I, and the edition of Section I under which the boiler was originally constructed. While the contemporaneous edition of Section I may not have been actually followed, it does give an evaluation by the then current practices of boiler construction. The FRA also accepts certain design practices as done by Baldwin in the 20's through 30's.

The FRA performs certain inspections and has stated in Part 230 about notice to the FRA for the various required tests and inspections on jurisdictional locomotive boilers when they are performed by the owner/operator.

For an insular railroad and which is not subject to Part 230, that would be Matt or his equivalent in whatever state the boiler is located.

I will repeat, if someone believes that the Sierra #3 is not safe to operate they should contact the FRA or the State of California.

Sincerely;

pkurilecz

Going back to the boiler front flue sheet that Matt posted a photo of, one other possible problem occurs to me with the location of outside flues on the bottom row being so close to the shell, or in the case of the left side in the photo nearly in contact with the shell. It seems to me that if boiler scale were to build to any extent on this flue and on the shell along with scale dropping from above the crevice between this flue and the shell could easily become filled and the result be a serious hot spot where heat can't transfer possibly resulting in some sort of premature flue failure? Off the original topic, but there may be a whole lot that can be learned about what not to do in this photo.

This has been, and continues to be a great discussion, with one exception...

So far, no one has said what stamp the Sierra No 3 may or may not carry... I repeat... we (this board) do not have the authority to make demands of anyone about what stamp this new boiler may or may not carry...

And in the absence of any information about that stamp or lack of stamp we need to stop discussing Sierra No 3...

We need to continue to discuss ASME, FRA, and state boiler standards...

So how does a boiler meet ASME with a dome throttle?

Mr. Bane,
I found my my stack of #85 photos as manufactured by Benson Mountain Co. If you can standby while we hash out FRA vs. ASME we can attack this horror story to greater depths in the near future.
Matt

For new construction, I refer you to the topic discussed HERE

S.O.

Hello Randy:



Simply stated, at this point in time and in its current location, it does not matter whether or not it has any stamps at all, be they ASME, NBBI or any other organization.

The Sierra #3 is located and operated in California on a railroad under the jurisdiction of the FRA; and, the Sierra #3 is subject to the requirements of 49 CFR Part 230.

This preempts any regulation by the State of California.

Under Part 230, the owner/operator is responsible for compliance with Part 230. Part 230 describes what is required for a Part 230 compliant steam locomotive.

Part 230 does not require the application of the ASME S stamp on a new steam locomotive boiler. Part 230 does not require an R stamp for repairs. The FRA does not require that the NBBI (or an AI or AIA) inspect the boiler and provide a registration number; or, require the filing of an MDR with the NBBI.

If a steam locomotive is subject to Part 230, the FRA can inspect a steam locomotive boiler at any time for the purpose of detemining whether or not the boiler is in compliance.

The FRA requires advance notification of certain locomotive boiler inspections performed by the owner/operator.

A locomotive boiler built to ASME Section I may not necessarily be compliant with Part 230.

A locomotive boiler repaired; or, inspected and evaluated to NBIC requirements may not necessarily be compliant with Part 230.

A locomotive boiler built to Part 230 requirements may not necessarily be compliant with the ASME or the NBIC requirements. See the other post about the location of the stop valve and dome throttles. Also check the difference in requirements for PRV's, low water alarms, fuel shut offs, and, feedwater among others.

======

Other discussions were made about what would happen if the Sierra #3 were to be sold to an insular railroad.

At that point, the Sierra #3 locomotive boiler would be subject to the boiler laws in that state.

Without an ASME S stamp and an NBBI number, an application may have to be made to that state's chief boiler inspector in order to have a "special" operating license issued. Some states allow this; some do not.

Without an ASME S stamp and NBBI registration, the sale of the Sierra #3 to an insular railroad may be problematic. However; this is a business decision as it is concerned with the merchantibility and fitness for purpose of an article in trade. I would refer you to the Uniform Commercial Code for more information about merchantibility and fitness for purpose requirements.

Underwriting and assumption of risk for a boiler failure (so called boiler insurance) may be affected by the lack of an ASME S stamp and a NBBI number. An owner/operator's general liability policy may not cover the casualty loss of a boiler or the incidental loss resulting from a boiler failure. Again, this is a business decision and would depend upon an agreement between the underwriter and the owner.

For a vendor with the capability of applying an ASME S stamp to a locomotive boiler, there may be a question on the assumption of risk by the vendor's underwriter if the vendor were to manufacture a boiler without the application of an ASME S stamp and without the inspection by an NBBI accredited AI or AIA. Again this is a business decision and would depend upon an agreement between the vendor and the vendor's underwriter.

======

Again I repeat, If you have any information that the Sierra #3 is deficient in its design or operation, or believe that the Sierra #3 represents a hazard to the public, I recommend that you contact the State of California or the FRA.

======

Thank you for allowing this discussion to continue, Randy.

Sincerely;

pkurilecz

I contacted a friend at CSRM... From him,

Real information from those directly involved - thanks.

dave

If Linn designed the boiler and bought off on the finished product and the FRA takes no exception with it, then that's more than enough for me!
Linn is one of the most methodical,thorough and well educated in his craft that I know and he "don't do junk"! 'Nuff said.

Hello Matt:

Am I correct in understanding your view point as follows:

NBBI inspectors prevent unsafe boilers from being operated.

NBBI inspected boilers are safe.

An ASME S stamp and an NBBI number are required for a boiler to be safe.

A boiler without an ASME S stamp and an NBBI number is unsafe.

A boiler not inspected by an NBBI AI or AIA is unsafe.

A fired pressure vessel designer (such as myself or Linn), a fabricator (such as Chelatchie or Strasburg or any other competent fabricator) and a buyer (such as the State of California) are unable to design, fabricate and operate safely a locomotive style boiler under the jurisdiction of the FRA due to the fact that an ASME S stamp and/or an NBBI number is not applied to the locomotive boiler and it was not inspected by a NBBI AI or AIA.

The FRA is incapable of ensuring the safe operation of a locomotive style boiler because they do not utilize NBBI accredited AIs or AIAs.

If the NBBI is essential and crucial to the safe design and operation of locomotive style boilers, what comments did the NBBI provide to the FRA when the FRA published its NPRM for 49 CFR Part 230?

If I am missing something; please let me know.

Sincerely;

pkurilecz

Hey guys...enuf already!! Haven't we beat this poor horse BEYOND dead???

If the above careful,complete,factual explanations in part showing the direct involvement of one of the industrys most respected professionals are not enuf...then nothing will suffice!!

Pleeeeeeeeeeeeeeeez!

Ross Rowland

Did they ever find that engine in the quarry?
What's the status of the K4?

OK Ross, my work here is done.

It is my sincere desire that Matt Austin be able to sleep, and sleep well, without worry about the carnage and financial calamity caused by manually fired boilers, be they new, used, lap seam, but strap or bubble gum. I hereby put in a budget request for enough concrete to fill every active boiler in country, and, to ensure that nobody gets hurt with sharp edges, we encase everything in ten layers of bubble wrap.

Again, if the FRA is happy, I am ecstatic.

Well, since the can of worms is open, we'd best be herding the worms.........

Does the boiler on 614 have an ASME stamp?

The questions raised above are to promote a critical thought regarding "Are only ASME boilers safe?" I think it is good to know what Mr. Austin is aiming for, because he may represent a body of opinion that says non-ASME boilers are NOT safe, and only those who have the ASME stamp can design a boiler. That would seem to defy common sense, but rest assured that some out there honestly and religiously believe this. When Mr. Austin suggests a boiler designed by Mr. Moedinger could go "kaboom", that tells me that somebody has an inherent distrust of work done elsewhere---even if the work exceeds ASME standards.

A runaway belief that only ASME boilers are safe could have repercussions in insurance and licensing approval for a LOT of engines out there. So it would behoove us all to understand the concerns of this portion of the ASME coummunity. Hence I hope an answer can be provided to P Kurilecz's queries.

I think all parties are fallible, but will place strong faith in the FRA inspection protocol, as I don't believe there has been a pressure vessel failure attributable to boiler design (not operator error) in a very long time.

Michael Seitz
Missoula MT