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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Tue Jul 16, 2019 6:15 am 

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Brian Wise wrote:
Way back about 1988, the fledgling Niles Canyon Railway put their wood-burning Porter 0-4-0T+T back in service. One day, while sitting in the depot at Sunol, a representative of the Bay Area Air Quality Management office showed up with an opacity card (sp?). He was responding to a complaint about the wood smoke from one of the locals. End result: we converted the locomotive to burn used motor oil rather than take the locomotive out of service. My understanding was, the air quality folks had jurisdiction over our locomotive while it was standing still (same with ships at port). Once we began to move, they had no say. To the best of my knowledge, the NCRY has had no issues with the air quality folks since.


Back in the day, of course, various cities had smoke control regulations on railways, and had inspectors out checking on compliance. I remember a specific story in TRAINS from one of those first-hand memoir stories.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Tue Jul 16, 2019 8:32 am 

Joined: Sun May 15, 2005 2:22 pm
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Alan Walker wrote:
Ron Travis wrote:
If the D&S territory gets into a high fire danger condition again, I assume that they will either be prevented from running trains by the Forest Service or will voluntarily stop running trains due their own liability. Why did it take a big fire to make this point?

It seems that the risk defines the solution, and that solution is to make it 99.9% impossible for a D&S train to ignite a fire. Converting to oil will reduce the number of fires started, so fewer fires will spread to catastrophic levels, but still, the total risk would be unacceptable considering the legal consequences.

In seems to me that converting some engines to oil burners is a marginal precaution just like following the trains with water patrols, a flying helicopter, and a water spray smokestack. What is needed is a robust solution.


A robust solution would be conversion to all diesel operation during fire season or not running at all.


Yes, those would be robust solutions. But what is the chance of a diesel starting a fire? Can they be equipped with devices that reduce the chance of emission caused fires to be almost zero? What happened to the plan to buy new diesels and take delivery last spring?

Another robust solution might be to run a very precise system of fire-spotting cars behind every train during high fire danger. I know they do something like that but it did not prevent the 416 fire (if a D&S engine ignited that fire). I have never heard a detailed explanation of what the trailing fire patrol encountered at the site of the 416 fire ignition. What actually was the trailing fire patrol routine that day?

I also wonder how effective a spark arresting device can be if one were starting with a clean sheet of paper and were freed from the constraints of historical appearance.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Tue Jul 16, 2019 2:44 pm 

Joined: Tue Sep 14, 2004 7:52 am
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Location: Strasburg, PA
Alan Walker wrote:
Frank J. DeStefano wrote:
Crescent-Zephyr wrote:
As for steam locomotives today, the Clean Air Act does authorize the EPA to regulate locomotive emissions as previously mentioned. The point that should concern steam locomotive operators is the definition of "new locomotive". Is a historic steam locomotive that has just gone through an FRA mandated inspection and overhaul a "new" locomotive? What percentage of material must be new material for a "historic" locomotive to become a "new" locomotive? The problem is that there is no bright line established by which you or I can go over a locomotive and say whether it is "historic" or "new".

I also wonder how this affects new build steam locomotives; machines that are produced in the 21st century yet intended for historical interpretation (Leviathan, York 17, T1 all immediately come to mind). As the first two examples I provided are operating under these regulations, I'm assuming there's some clause to the "new locomotive" stipulation?

That's just it-there is no clause.
No clause is needed because steam locomotives are exempt.

From Part 92.1,
“(b) The requirements and prohibitions of this part do not apply with respect to:
(1) Steam locomotives, as defined in §92.2;” Period.

If steam locomotives were to fall under the regulations after an overhaul, 92.1 would include language to the effect of, “Except where stated in 92.8(a)(1)(i)” or something like that.

From Part 92.2, “Steam locomotive means a historic locomotive propelled by a steam engine.”

As far as I have been able to find, the word ”steam” appears nowhere else in Part 92.

The only part of the rule or the definition that is open to discussion is the word "historic". I would argue that any Stephensonian locomotive, including the York or the PRR T1 replica are historic due to their general layout and method of operation (i.e. an inspector wouldn't know that they aren't antiques unless you told him). On the other hand, the ACE 3000 wouldn't be historic due to the difference in it's layout and operation (computerized boiler controls, etc.).

The feds are not coy. If they meant for steam locomotives to be covered, they would have said so.

Further clarification can be found in Applicability of Locomotive Emission Standard Technical Highlights.

This paragraph on page 3 is of interest:
"Exclusions and Exemptions
There are certain types of locomotives that are excluded from these regulations. First, all locomotives powered solely by an external source of electricity, and all historic steam-powered locomotives are excluded from these regulations. These locomotives are also not currently regulated elsewhere by EPA. The regulations do not apply to existing locomotives owned by railroads that are classified as small businesses, as defined below, because these locomotives are not considered to be new locomotives when remanufactured."

As is this one from page 4:
"Definition of Small Railroads
Line-haul railroads with fewer than 1500 employees and switch railroads with fewer than 500 employees are classified as small railroads. For railroads owned by parent companies, the number of employees used to determine small business status is the combined number of employees of the railroad and any parent companies."

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Tue Jul 16, 2019 5:12 pm 

Joined: Sat Oct 17, 2015 5:55 pm
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Ron Travis wrote:
I also wonder how effective a spark arresting device can be if one were starting with a clean sheet of paper and were freed from the constraints of historical appearance.


Here is diagram of a device (which RyPN member Shogo Takizawa provided), installed on Japanese steam locomotives from the early post-war years until today, that I am very curious about. Japan's railroads in general aren't known for wasting money on things that don't work, so I suspect that it has some amount of usefulness, how much is the question. Could a test be performed, say with a thermal imaging camera and some type of particle counter? Intentionally make a lot of sparks go through the stack without the device and then install it and repeat? Also, would these really be that unhistorical looking? I too would not want some complicated vacuum-type contraption up there, but this looks unobtrusive to me.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Tue Jul 16, 2019 8:10 pm 

Joined: Sun May 15, 2005 2:22 pm
Posts: 1417
PMC wrote:
Ron Travis wrote:
I also wonder how effective a spark arresting device can be if one were starting with a clean sheet of paper and were freed from the constraints of historical appearance.


Here is diagram of a device (which RyPN member Shogo Takizawa provided), installed on Japanese steam locomotives from the early post-war years until today, that I am very curious about. Japan's railroads in general aren't known for wasting money on things that don't work, so I suspect that it has some amount of usefulness, how much is the question. Could a test be performed, say with a thermal imaging camera and some type of particle counter? Intentionally make a lot of sparks go through the stack without the device and then install it and repeat? Also, would these really be that unhistorical looking? I too would not want some complicated vacuum-type contraption up there, but this looks unobtrusive to me.


I remember that we had talked about that device in an earlier thread. I don't know anything about it. I get the impression that it is spun by the exhaust gas as if it were a turbine rotor. If so, it seems that the purpose might be to pulverize hot embers so they are cooled by dissipating their heat into the relatively cool outdoor air before they land on the ground. That may be a more effective idea that simply trying to catch all the hot embers with a screen. The spinning rotor would never need cleaning. It would never inhibit the exhaust draft like a screen might.

If that is a steam turbine driven by exhaust steam, it raises the question of driving a rotor for the same purpose by an actual steam turbine motor driven by high pressure steam directly from the boiler.

The typical kinetic approach to the spark arrestor challenge seems to have been to use the exhaust steam and guide it into a cyclonic action. Going a step further and using boiler steam directly to drive a turbine that powers an ember smasher might open new avenues of solutions.

If that Japanese device works the way I think it does, its rotor impingement on the stream exhaust particulate would be dependent on the velocity of the exhaust stream to spin the rotor. That dependency may impose a limitation in the ember smashing. If you break that dependency of the rotor being driven by exhaust steam by driving the rotor directly by boiler power steam, it may get rid of any limitation on ember smashing. The objective would be to allow the total velocity of the exhaust stream unimpeded flow while intercepting it so often that no ember ever gets through that interception process.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Wed Jul 17, 2019 12:18 pm 

Joined: Sat Sep 04, 2004 10:54 am
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Location: Tucson, Arizona
Kelly Anderson wrote:
The only part of the rule or the definition that is open to discussion is the word "historic". I would argue that any Stephensonian locomotive, including the York or the PRR T1 replica are historic due to their general layout and method of operation (i.e. an inspector wouldn't know that they aren't antiques unless you told him). On the other hand, the ACE 3000 wouldn't be historic due to the difference in it's layout and operation (computerized boiler controls, etc.).




Any competent inspector would certainly know that the locomotives mentioned are not antiques. Those locomotives build dates are legal fact of that-they are modern replicas of an antique locomotive. That plus a search on the internet would provide information that the locomotives are new construction. Therefore, locomotives built to Cloke's plans are new locomotives built to an old design-same with the T1 replica. What is questionable would be locomotives that were rebuilt and to what degree.

Bottom line is that whatever the outcome is of the D&S case, it's negative PR that our industry does not need. While the law currently provides some protection to genuine historic locomotives (which the replicas most certainly are not), the law can change. As an industry, we have an obligation to operate our locomotives in a responsible manner to justify the current exemption remaining in place.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Wed Jul 17, 2019 12:49 pm 

Joined: Thu May 24, 2012 1:37 pm
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Quote:
"The typical kinetic approach to the spark arrestor challenge seems to have been to use the exhaust steam and guide it into a cyclonic action. Going a step further and using boiler steam directly to drive a turbine that powers an ember smasher might open new avenues of solutions."


Much of the problem with ember or 'spark' ejection concerns this knotheaded idea of 'ember smashing'.

Cinders in the smokebox were a maintenance headache by the turn of the century (see the Goss treatise on 'locomotive sparks'), and the idea was to provide a larger and larger 'can' receptacle under the smokebox for these to fall in, or be periodically shoved into, then presumably dumped out the bottom.
With a little thought, the MM front end was modified so that screening would break up the 'sparks' so they would blow out in the exhaust and not accumulate. This was somewhat euphemistically called a 'self-cleaning front end', the progress of what was self-cleaned being of no more import than, say, the odd coals dropping from the ashpan during running.

Meanwhile, we might gainfully remember Angus Sinclair's parody locomotive, famously equipped with a (laboriously-described) Carbowallop for capturing the sparks centrifugally and 'returning them to the firebox' Cyclonic separation of 'embers' has a very long technically technical history, little of which has the desired effect of removing luminous particulates from the exhaust without choking it.

Considering the simplicity as well as the advantages, conversion to oil firing is THE sensible answer to a situation like the D&S faces, rather than their attempting to listen to 'solutions' that would make the problem much more extreme, not better.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Wed Jul 17, 2019 3:37 pm 

Joined: Tue Sep 14, 2004 7:52 am
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Location: Strasburg, PA
Alan Walker wrote:
As an industry, we have an obligation to operate our locomotives in a responsible manner to justify the current exemption remaining in place.
I wholeheartedly agree with that.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 7:34 am 

Joined: Sun May 15, 2005 2:22 pm
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Overmod wrote:
Quote:
"The typical kinetic approach to the spark arrestor challenge seems to have been to use the exhaust steam and guide it into a cyclonic action. Going a step further and using boiler steam directly to drive a turbine that powers an ember smasher might open new avenues of solutions."


Much of the problem with ember or 'spark' ejection concerns this knotheaded idea of 'ember smashing'.

Cinders in the smokebox were a maintenance headache by the turn of the century (see the Goss treatise on 'locomotive sparks'), and the idea was to provide a larger and larger 'can' receptacle under the smokebox for these to fall in, or be periodically shoved into, then presumably dumped out the bottom.
With a little thought, the MM front end was modified so that screening would break up the 'sparks' so they would blow out in the exhaust and not accumulate. This was somewhat euphemistically called a 'self-cleaning front end', the progress of what was self-cleaned being of no more import than, say, the odd coals dropping from the ashpan during running.

Meanwhile, we might gainfully remember Angus Sinclair's parody locomotive, famously equipped with a (laboriously-described) Carbowallop for capturing the sparks centrifugally and 'returning them to the firebox' Cyclonic separation of 'embers' has a very long technically technical history, little of which has the desired effect of removing luminous particulates from the exhaust without choking it.

Considering the simplicity as well as the advantages, conversion to oil firing is THE sensible answer to a situation like the D&S faces, rather than their attempting to listen to 'solutions' that would make the problem much more extreme, not better.


Thanks for that information. I will read more in the Gross treatise, and took a look at a detailed thread on the Trains forum. I am not sure if the problem faced by D&S exactly matches the historical problem. For D&S, what is needed is a solution that is nearly perfect in the ability to prevent sparks, or burning material dropped from the ash pan from starting a lineside fire. Not having this solution requires a complete conversion to oil fired motive power, or dieselization, or electrification, or an ending of the rail operation.

Maybe this goal is impossible, but the stakes are great enough to warrant a robust solution. One question is this: If you can pulverize the sparks so they quickly reach atmospheric temperature upon discharge from the stack, why not just throw them out rather than collect them? It seems that their ability to ignite fires depends on a mass sufficient to remain above the ignition temperature until it lands in flammable material on the ground.

So if you pulverize the mass before it is ejected ("ember smashing"), its particles are quickly chilled as they disperse in the outside air. And if this smashing is limited by the exhaust velocity, why not accelerate that velocity with a rotor driven by directly tapping boiler steam?

A big part of this problem is the "tradition" of locomotives starting lineside fires. This will always play a role in any legal claim against a railroad near the site of a wildfire. It will also do this with oil-fired steam, or even diesels. One solution is to be able to make the scientific claim that your locomotives are 100% incapable of igniting lineside fires. Otherwise, if the train that is said to have started the 416 fire were pulled by an oil-burner, it would not have changed a thing. The Forest Service would still be taking D&S to court, and they would have the same chance of winning.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 8:07 am 

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Ron Travis wrote:
Not having this solution requires a complete conversion to oil fired motive power, or dieselization, or electrification, or an ending of the rail operation.

If you can pulverize the sparks so they quickly reach atmospheric temperature upon discharge from the stack, why not just throw them out rather than collect them? One solution is to be able to make the scientific claim that your locomotives are 100% incapable of igniting lineside fires.
Oil burners and diesels are quite capable of throwing red hot chuncks of carbon out the stack. Oil burners can dribble burning oil in the ground. Even electrics cause sparks. So do brake shoes. And for that matter, the cacilitic converters on cars can and do start grass fires. Add to that camp fires, grills, etc. etc.

Pulverising and ejecting cinders is the main feature of the Master Mechanic's front end, hence the nickname "self cleaning". That technology is already in place. They do need to be maintained so there is no hole or crevasse larger than the openings in the screen. I inspected a front end once on an engine that was prone to starting fires and found a rusted through hole you could stick your hand through in the sheet steel baffles, the figurative "smoking gun".

All sorts of man made activities start fires. IIRC, during the drought circa 2003, the forest service prevented horses from participating in a parade in Canyon City, CO, because they were afraid of a spark from the horse shoes starting a fire (it has to be true, I read it on the internet). Also IIRC, the biggest fire in CO that year was started by the forest service when they lost control of a "controlled burn". I wonder if they sued themselves?

In the end, the only way to prevent man made fires in that forest is to bar people from entering the forest, then lightning will still start fires.

Wood burns.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 11:56 am 

Joined: Sat Sep 04, 2004 10:54 am
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Location: Tucson, Arizona
Ron Travis wrote:
One solution is to be able to make the scientific claim that your locomotives are 100% incapable of igniting lineside fires. Otherwise, if the train that is said to have started the 416 fire were pulled by an oil-burner, it would not have changed a thing. The Forest Service would still be taking D&S to court, and they would have the same chance of winning.


That might be something to consider if you have empirical evidence to sustain the claim, such as controlled scientific tests. However, the problem still remains that the railroad has caused numerous lineside fires in the past and that fact can always be presented in the Court. What would be a better argument in reducing culpability would be to demonstrate that when properly maintained and operated, an oil fired steam locomotive significantly reduces the probability of the locomotive to emit sparks or flame that could ignite a wildfire.

As far as fire mitigation, the short term solution is basically to let fires burn unless they threaten infrastructure or human life. For a century, the Forest Service operated under a belief that all forest fires are bad. Since then, we have come to learn that fire is part of the natural life cycle of a forest. The State of Alaska has a number of forest fires every year that we in the lower 48 never hear of. Many of them do not get attended by firefighting crews or are minimally attended to. Why is this? They have a general practice of simply letting the fires burn unless they threaten infrastructure or human life.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 1:42 pm 

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It’s always interesting to hear different views on the subject of rail preservation.

Personally, I hope Durango can continue to operate with coal burning engines. It’s historic to the line just as much as wooden coaches and views from the high line.

But I see the flip side.... if converting to oil is better for the long term operation of steam... that certainly needs to be considered as well.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 4:42 pm 

Joined: Sat Sep 04, 2004 10:54 am
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Location: Tucson, Arizona
Crescent-Zephyr wrote:
It’s always interesting to hear different views on the subject of rail preservation.

Personally, I hope Durango can continue to operate with coal burning engines. It’s historic to the line just as much as wooden coaches and views from the high line.

But I see the flip side.... if converting to oil is better for the long term operation of steam... that certainly needs to be considered as well.


Bottom line is that the days of coal on the D&S are probably numbered. If the Forest Service prevails, they can stipulate the D&S to stop using coal either as part of the settlement or as part of their contract to operate through the National Forest. Realistically speaking, D&S has few options and their choices are mostly between bad and worse. Then there also the supply side issue-coal mines are closing at an increased rate due to market changes. The future of coal long term is not promising. Oil companies don't look to be much better, either. I give coal as a locomotive fuel maybe twenty more years.

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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Thu Jul 18, 2019 4:50 pm 

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Yes, you’ve made you’re viewpoint clear. I can hold out hope since nothing has been decided yet and I can also be sure to get out to Durango this summer to see multiple coal burning engines alive and steaming! Ha.

I’ll still ride D&S behind oil of course ... heck I tried to get out to see the #18! But there is something special when an engine is fired the same way as when it was built.


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 Post subject: Re: Feds sue Durango and Silverton over 416 fire
PostPosted: Fri Jul 19, 2019 5:59 pm 

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Hey, now here's something no one else has brought up: Why not just use torrified biomass as a fuel? I believe the Coalition For Sustainable Rail Project is working on that kind of fuel, and it burns just the same as coal. Not to mention that it has none of the side effects. It could save the D&S millions of dollars from converting the locomotives to oil. (And yes, I already told Al Harper about this.) But to get more serious for a second, something about this entire case doesn't line up. I believe it might of been an Arson, due to the lack of sufficient evidence against the railroad, and for the fact that the D&S has already taken measures to prevent fires.

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