Me too.


I would expect that it wouldn’t make much difference new or old, other than the ambulance chasers wouldn’t have much luck adding Baldwin Locomotive Works to the law suit compared to a current boiler shop. The investigation into the Gettysburg failure was fairly complex, but didn’t result in the end of the industry, thanks in part to the work ESC had already done by that time.

In my opinion, the feds are set up to have a fairly un-emotional and professional response to something very bad happening, and are not inclined to paint us all with a broad brush due to one unfortunate miscreant’s mis-deeds. If anything causes the end of our industry, I'd bet that it will be the insurance companies that shut us all down rather than the government.

That's the rolling mess that scares me.

Question: All of you nattering nabobs of negativism answer this...were you concerned about #3's original boiler stamping situation, physical condition not being a consideration, or were the folks at Rogers unable to build a boiler. Listen, I do this for a living, hold a national board commision as well as a state, and can tell you is that in the great scheme of things the only thing a cloverleaf is a guarentor of is someone pays the ASME a big, big check to use it.

That's an interesting point of view coming from an Authorized Inspector (I assume you are an AI and that's why you have your commissions) would you mind elaborating? I have been in the pressure vessel and boiler industry for a little over twenty years with an intimate understanding of certain parts of the ASME Code and the relevance it has towards safety placed on it by manufacturers, users/customers and regulatory agencies. I believe the "S", "U" or any of the manufacturing stamps do not come to users very easily (I've been part of and have sat in on many joint reviews over the years) and are a manufacturer's declaration to industry that they intend to meet those minimum standards published in the various Sections of the Code.

Mr. Templin, Please do not take my comment and question personally, I am only interested in your point of view for the benefit of my own education.

Thank you,

S.O.

Stan,
I have a great deal of respect and appreciation for the ASME and its third party enforcement arm the NBIC, and I am a state inspector. FYI the state I work in has a state commission system, and likes you to have the NB commission to go with it. Several years ago, I was told by my super to be in Austin two weeks later, as I was to take my NBIC. "Don't worry, its just a dry run so you will understand the test when you take it then next time...most guys take a couple of times to get it," he says. "Besides, you can go to Columbus for the prep seminars afterword." Long story short I passed first time out, and proved that you don't have to be from Columbus to understand boilers.

I tell you this so that you will understand that while I do respect and enforce the national standards as applicable, they are not the whole total of boiler design and and there are many codes the world over that are quite successful, and do not borrow from the ASME. The original ASME codes were borrowed from earlier codes, based on experience and emperical evidence. In most old time boiler shops, they knew the materials they had on hand, knew what their shop practice was, designed the boiler to a level they felt comfortable with, then whipped out the code calcs to prove it. It is a fairly recent practice to calculate first and then design.

Anyhow, my point is that I know full well that it is quite a process to maintain the use of the ASME stamp...you can't buy them and you don't rent them-they allow you to hold one when their criteria are met, but it is the NBIC system that is required to make sure those are met. It is expensive to be a stampholder, and to maintain it. Last I heard it was tens of thousands annually, books not included (fully one third or more of the cost of any boiler is testing, administrative, and certification fees). And unless you really, really screw up, they won't look at your production, it will be an AI with an NBIC commission. I know of a boiler shop in Indiana that will build you a rivited boiler, of the highest quility, and the shop doesn't have a stamp from anyone but the state, and I wouldn't be afraid of any of them. I believe he builds to the 1918 ASME rivited boiler code, but doesn't pay to use the stamp...is that a code boiler? I know of another boiler maker that had all the right stamps, and the NBIC is quite interested in finding all of his production, and nobody had ever told me what happened to the AI that passed them.

An old boiler man told me that the ASME was the Good Housekeeping Seal of Approval for boilers. I don't think the N&W put cloverleafs on their power, and, unless it was an industrial engine, I have never seen an ASME Stamp on any ICC inspected locomotive. The AAR had their own code of recommended practice, and the ASME left them alone. Are you afraid of the 611 or 765?

Hi Jim,

Thank you for your response and insight. I agree there are some very knowledgeable people/companies capable of building safe and sound locomotive boilers; people and companies without ASME Certificates. Being a Certificate holder is a business decision first. The investment in capital and time is substantial, as you have said, so it makes no sense to expend resources for a Certificate unless you can profit from the investment. One business model that is applied in the new locomotive construction facet of the boiler industry is to have an experienced designer/consultant, perhaps without any ASME or NBBPVI credential, design the boiler then have an ASME Code shop build the actual vessel.

I also agree that there are Certificate holders that have built some very questionable products. Some of them have been discussed on this web site. So how does a customer know the company they are hiring to build a new locomotive boiler is not one of those Certificate holders building bad products? Like buying anything else, it is imperative that the purchaser research the vendors. Reputation goes a very long way. If you have heard of a potential vendor company during the course of polite conversation then that company should probably go on the Request for Quote list. Companies discussed with a measure of venom or companies that you never have heard of may require more vetting.

This conversation has gone a ways off the original question, "Is the new boiler for Sierra #3 ASME Certified?" Getting back to that discussion: has the California bureaucracy adequately represented the best interests of the State's tax-payers during the acquisition of the boiler? I certainly have no idea.

S.O.

Early on in this thread there was a referance to a "P" stamp. I am familiar with an "S", "R", and "V" stamp but what is a "P" stamp?

CCdW

I think the poster meant a PP stamp. The PP stamp is for power piping. In simple terms, power piping is the piping coming off a boiler, up to and including the first valve. Power piping is manufactured to the requirements of ASME Section B31.1 and referenced by ASME Section I. The definition of power piping is much more specific, but for the sake of brevity, I have simplified it. It is worth noting S stamp holders can build power piping, but PP stamp holders can not build power boilers.

S.O.

Hello Stan:

Just used to calling it a P stamp.

Though isn't the section of pipe between the shell and the valve, be it the boiler stop valve or a valve connecting a piece of instrumentation, such as a reflex level glass, come under Section I.

I understand B31.1 applies downstream of the boiler stop valve.

The point about the P stamp is that many holders of the S stamp also build power piping and many of the same outside inspections apply to the use of the P stamp, as well as the Vendor's affidavit of design and construction.

Another point is that there is considered to be a difference between shop built boilers and field erected boilers.

And let's not even go into some of the idiosyncrasies of applying an N stamp to an article.

hth

pkurilecz

Matt, what's the deal with the lower rows of flues? They appear to not be in complete symmetry and the bottom row appears to have the flue on one end right up against the shell and infringing on the weld zone of the shell to the flue sheet. Is this typical work or part of the problems with this boiler?

There is no Code paragraph that says you can't free hand mag drill a tube sheet. There are a few paragraphs that deal with the consequences of that practice, however. I found my stack of OR&L #85 boiler pictures, but that is another saga for another day.

Do you or anybody have any friends close to Jamestown that can verify a Code stamp on the #3? Should/must be on the backhead above the firedoor.

Sorry Matt, I am up in N.E.Ore., but would love to go to Jamestown, Ca. sometime. I am not a boiler maker, but have helped with a few firebox repairs. The flue layout that I asked about just looks like sloppy work to me, even if it is code compliant. Why wouldn't a person carefully measure for each row of flues, and chalk line or using a straight edge mark the center line of each row, them carefully measure and center punch the location of each flue hole to be cut?

I would bet anything that there is an MDR or its equal for the boiler for the #3-the new form 4s would need it.

In the example you cite, this boiler had a legitimate S stamp from the ASME. We also know this maker has quite a few boilers out there of questionable quality, and the location of many isn't known.

Question, since you take umbrage at my previous statements...what assurance did the cloverleaf on the boiler in the photo provide? Did its maker steal the stamp, have a counterfit, or was he an authorized stamp holder? This is just further proof that documentation is no substitute for a concientious, knowledgeable inspector and inspection regimen(don't go getting a big head there, Captain Code Jockey).

I am just stating the fact that an S stamp is meaningless if the vessel underneath it is crap, and by the same token if a vessel is well built to all applicable standards, and satisfies the jurisdiction its under, if it doesn't have an S stamp, it isn't neccessarily crap, either. If the FRA is satisfied so am I. And so so should you be, and don't go tattling to Columbus.

This information is excerpts from the NBBI webpage and should clear up a few things as to what the role of the Inspector is. Note that the NB is composed of the various state officials who regulate the use of boilers within their states.

Functions

The National Board is comprised of chief boiler inspectors representing government agencies from across North America. Their functions include:

o Promoting safety and educating the public and government officials on the need for manufacturing, maintenance, and repair standards.
o Offering comprehensive training programs in the form of continuing education for both inspectors and pressure equipment professionals.
o Enabling a qualified inspection process by commissioning inspectors through a comprehensive examination administered by the National Board.
o Setting worldwide industry standards for pressure relief devices and other appurtenances through operation of an international pressure relief testing laboratory.
o Providing a repository of Manufacturers’ Data Reports through a registration process.
o Accrediting qualified repair and alteration companies, inservice Authorized Inspection Agencies, and owner-user inspection organizations.
o Investigating pressure equipment accidents and issues involving code compliance.
o Developing installation, inspection, repair, and alteration standards (National Board Inspection Code).

{bold emphasis added}

Logo and Marks Policy

This policy establishes requirements for the authorization of organizations to use National Board marks or symbols. It applies to National Board programs for authorization to register, authorization to list, authorization to apply the National Board mark on pressure relief devices, authorization for repairs/alterations described in the National Board Inspection Code, and certificates of authorization for owner/user inspection organizations described in the National Board Inspection Code.

The National Board does not "approve," "rate," or "endorse" specific items or activities. Such statements are not permitted. Statements which so indicate have no basis in truth and are in violation of this policy.

{Bold emphasis added}

I do not think that anyone who posts on or reads this bulletin board is interested in anything except the safe operation of steam locomotives.

The design of a steam locomotive boiler is quite involved and by necessity quite detailed. I have my own concerns about the derivation of some of the design formulae used in designing or determining the MAWP of some aspects of locomotive boiler design.

The question that remains to be answered Matt, is what exactly is your concern over whether or not the Sierra #3 has an ASME S stamp applied; and, whether or not the Vendor which manufactured the boiler holds an S stamp authorization? Is it a matter of jurisdiction that there may be power boilers which are not subject to inspection by the NBBI? If this is the case, did the NBBI make any comments to the FRA when the FRA published its NPRM on Part 230 in the Federal Register? I believe that if the NBBI had made a good case for its role in boiler safety, then it is likely that the FRA would have included an NBBI AI or AIA in the certification process for the submission of an FRA Form 4.

I would be interested in hearing anyone's comments on the role of the NBBI in the repair of a locomotive style boiler and the evaluation of the MAWP for a locomotive style boiler.

The boiler which you reference as needing to have the marks ground off, I do have some questions. I think it is great that the NB was able to find these nonconforming boilers. When the attempt was made to do so, what notification was given to the owner? From the owner's perspective, he purchased a boiler that was represented to him as conforming with the ASME B&PV requirements. Did this boiler manufacturer go out of business or declare bankruptcy? Where was the AI when the paperwork was completed? What was ASME's response to this? What was the outcome on the other boilers?

You had also stated: "Everyone involved in these in-house policing actions at the National Board are required to sign a non-disclosure statement with regards to the events of these "Internal Inquisitions". Does this mean that acts of fraud or possible malfeasance by AI's are not made public? How am I to rely on the ability and competence of an AI or an AIA if I do not know what complaints or investigations have been made of them? Is this a matter of "just trust us"?

If a licensed engineer is even investigated for possible violation of a state's engineering laws and regulation, public notice is made.

I believe that it has been adequately discussed that the Sierra #3 is under the jurisdiction of the FRA. I believe that any questions concerning the operational safety of the Sierra #3 should be addressed to the FRA and not just posted to this board.

I am more concerned over the fact that the FRA will accept completed Form 4's that were not prepared by a licensed engineer.

Personally, I am glad that there is an NBBI as it harmonized the legal requirements for boiler design and operation across the 50 states prior to the federal government utilizing the commerce clause for similar purposes. Prior to the establishment of the NBBI there were concerns about the construction of a boiler in one state and shipping into another state. At that time the federal government did not get involved in it except for the ICC as the railways did not want to contend with multiple jurisdictions and requirements.

Currently I hold an engineering license in one state. In order to provide engineering services in other states, I must have a license in that state, or work under the direct supervision and direction of an engineer licensed in that state. I am personally responsible for every piece of work that bears my seal.

If I prepare design or repair recommendations and then someone changes those recommendations, I am still responsible. I would be placed in the position of explaining to my state board why I did not ensure that my design recommendations were followed.

I don't mean or intend to be harsh or critical, but let's look critically at what we are trying to accomplish. This being; 1) what is required to have a locomotive boiler operate safely; 2) What assurances do owners of locomotive style boilers have that their vendors are capable of properly doing the work; and, 3) what assurances do locomotive boiler owners have that their locomotive (and not just the paperwork) is in compliance with Part 230?

I am just trying to educate.

hth

pkurilecz

PS: The flue sheet shown in Matt's photo is an excellent example of what not to do. It is very sloppy work. Also of note is the lack of stays in the flue sheet at the 4 and 7 o'clock positions. There is a limit as to how far the flues can be from the shell before additional stays are required. Because of the lack of uniformity in the flue layout, each flue and the area around the flue would have to be evaluated. Not knowing the dimensions on this flue sheet, I cannot state whether or not stays are required; only that it represents an area of concern to me.

The overlap of the flues at the flue to shell weld are also a concern. This would have to be evaluated to see if the weld in this area is of sufficient strength.

The stay design in the upper portion of the flue sheet is also a concern. I am assuming that the large opening in the upper portion of the flue sheet is for the pipe or operating rod extending to a possible steam dome throttle. If this is so, I would be concerned about the reinforcement required around this opening.

One of the refreshing things about the ASME is that they do not require a degree for someone to design a boiler. What they do require every three years is an actual demonstration that the "S" stamp holder is capable of designing and building a vessel to the code. Proof by doing seems to be a novel concept today.

I know many degreed and licensed engineers. Some are very capable, knowledgeable, practical, and ethical people. Others couldn't figure out how to screw a light bulb in and if they could they would probably electorcute themselves. Degrees and licenses are only as good as the people who hold them and if those same people had the same knowledge and no paperwork, they would do just as good - or bad - a job.

No system is perfect and all are subject to the whims of whoever administers that system, but ASME's continual recertification process at least creates an environment where people must routinely run the guantlet to show they are qualified. The process also provides for a review of past practices to ensure that they are up to snuff. Can you cheat the system? Of course you can, and some people have a mentality that figures its better to expend more effort in cheating than would be expended in following the rules. Welcome to the human race.

I think the jist of Matt's question is that if a boiler is made by someone who does not need to adhere to an established standard, what standard are they held to and how is that to be verified.