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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 7:05 pm 

Joined: Sun Aug 22, 2004 10:52 pm
Posts: 337
Location: Las Vegas, NV
Donald Cormack wrote:
Quote:

Let it be known that a service day is defined as any day the locomotive has steam pressure above atmospheric pressure and a fire in the firebox. So do explain how "test steaming" exempt from being classified as a service day as you're suggesting? Without following the proper channels of what the 1,472 day inspection requires, the locomotive is out-of-service (in this case, retired) and thus cannot be steamed legally with the exception of a waiver signed by the FRA, which would have to come with proper documentation i.e a previous boiler survey (Form 4).



I'm focusing on the "and" in the first sentence of the quote above. If the boiler was filled with steam from a stationary source, and there wasn't really a fire in the firebox, then it wouldn't be a service day, right?

Greg

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 7:41 pm 
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Posts: 2696
Location: Pac NW, via North Florida
This leads me to wonder, how many times has someone really decided to fire up a steam engine without the proper documentation or inspection, and run it anyway?
I'd read that SP 5021 was fired up without proper paperwork in the 60s and 70s, but I have no idea how accurate that is. I do know for sure that a small privately-owned switch engine was fired up without any official inspections at all (won't name when/where but I was there to see it with my own eyes and heard the owner laughing about it) in the 80s because he was looking to sell it at the time and always "wondered if it'd just steam up" and it did. I didn't know much about the true unforgiving nature of locomtives at that time and I realized things could have ended in tears from the way I now realize the guy was running it.

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:20 pm 

Joined: Fri Mar 21, 2008 11:12 pm
Posts: 95
Location: Boulder, CO
The Georgetown Loop just returned ex-West Side Shay #9 to operation. Even though it had run occasionally on the Midwest Central up until two years ago, a full 1472-day inspection was completed by the Loop, resulting in a quarter million dollars in restoration work over a year-and-a-half time span. A Form 4 will be filed (if it has not already been filed). The Loop stumbled a few years ago under the previous management, which brought the FRA knocking at their door. During the 31 years previous to that, when the Ashbys ran the railroad (until 2004), every effort was made to stay up with all the then-applicable regulations, and the FRA left them alone.

The FRA is not here to make your life miserable. Compliance will save your posterior in the event that a mishap occurs. If you're not in compliance and a smart plaintiff's attorney gets a hold of that fact, you're mincemeat. That's how it is. So stop gnashing your teeth over the 1472-day requirement. Smile, do the inspection, pay the bills, and realize you now have 15 years to pay attention to your business and make a buck with a safe and reasonable reliable locomotive.

Mike


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Shay#9 7-6-12 005.jpg
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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:23 pm 

Joined: Sat Jul 25, 2009 9:49 pm
Posts: 36
hamster wrote:
Retired loco, NOT EVER run under Part 230, INDUSTRIAL trackage.......methinks that someone decided that since they were NOT part of the general system they could just go ahead without the FRA. Probably there was not much time on the flues when the loco was retired and it ran just fine last time, so what the hey! Just this once!

OBVIOUSLY, if there is any interest in actually running this loco, all the FRA regs will have to be dealt with.

And who knows? Maybe the local FRA guy told them to go ahead, once....


CFR 49:
§ 230.2 Applicability.

An operation will not be considered insular if one or more of the following exists on its line:

(i) A public highway-rail crossing that is in use;

(ii) An at-grade rail crossing that is in use;

(iii) A bridge over a public road or waters used for commercial navigation; or

(iv) A common corridor with another railroad, i.e., its operations are conducted within 30 feet of those of any other railroad.

In terms of steam regulation this railroad is not "industrial" nor "insular". If you refer to the attached image it can be observed that for the locomotive to move from shop area "A" to be photographed under steam on bridge "B" it must cross at grade road "C" or Broadway Street. It is very much a public road providing access to two (2) public parks.
Remember, the Georgetown Loop Railroad was taken under the FRA umbrella (primarily steam regulations) because their trackage crosses a public road by BRIDGE.

The attempts at defending or excusing this perceived situation is beyond disappointing. The locomotive was retired in the 60's, placed at the museum in the 70's and moved to this RAILROAD last december. The boiler exterior/interior was not inspected....period.

As Cormack pointed out:
§ 230.17 One thousand four hundred seventy-two (1472) service day inspection.

(a) General. Before any steam locomotive is initially put in service or brought out of retirement, and after every 1472 service days or 15 years, whichever is earlier, an individual competent to conduct the inspection shall inspect the entire boiler.

Testing can occur on the locomotive under steam after such time that these requirements have been met including:

§ 230.16 Annual inspection.

(b) FRA notification. FRA Regional Administrators shall be provided written notice at least one month prior to an annual inspection and shall be afforded an opportunity to be present. If the Regional Administrator or their delegate indicates a desire to be present, the steam locomotive owner and/or operator will provide a scheduled date and location for the inspection. Once scheduled, the inspection must be performed at the time and place specified, unless the Regional Administrator and the steam locomotive owner and/or operator mutually agree to reschedule. If the Regional Administrator requests the inspection be performed on another date but the steam locomotive owner and/or operator and the Regional Administrator are unable to agree on a date for rescheduling, the inspection may be performed as scheduled.

This all means in order for a locomotive to be steamed, even to be "tested", when under the the jurisdiction of the FRA, it must go through a complete boiler inspection (interior and exterior) performed by someone designated by the locomotive "owner/operator" AS WELL AS an FRA witnessed hydrostatic test.

The contentions that this locomotive was "almost new" when parked are irrelevant. Myth, lore, legend and word of mouth anecdotal commentary until such time as the physical object at hand presents evidence to confirm what everyone "knows" about the condition.

This ambivalently dismissive attitude towards such a blatant disregard for safety or human life is not something which should be taken lightly, cannot be taken lightly. There is absolutely no way to know the condition of a boiler unless it is inspected, WHAT IF something failed on the boiler as the locomotive was crossing the PUBLIC grade crossing for the two parks resulting in a death of a person or persons stopped in their vehicles?

If this "it's no big deal" attitude towards such a disregard for safety of self, others and adherence to the law is a barometer for the degradation of professionalism in this industry then well, "I weep for the future of steam here in the U.S.".


John


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Last edited by john creasing on Fri Jul 06, 2012 8:37 pm, edited 1 time in total.
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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:29 pm 

Joined: Fri Mar 21, 2008 11:12 pm
Posts: 95
Location: Boulder, CO
Just a minor quibble... The Georgetown Loop came under FRA jurisdiction because of a derailment.

Mike


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:32 pm 

Joined: Fri Dec 17, 2010 2:41 pm
Posts: 166
If there was a "Like" button for Mr. Creasing's post I would have broken the left click button off my mouse!


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:48 pm 

Joined: Sun Sep 12, 2004 1:41 pm
Posts: 834
Location: Bowling Green, KY
mikerowe wrote:
Just a minor quibble... The Georgetown Loop came under FRA jurisdiction because of a derailment.

Mike


Not to get to far off subject here but, the Loop was ABLE to come under the FRA because of what John mentioned. It CAME under the FRA as a result of a campaign launched by disgruntled former management and employees. The derailment would have gone un-noticed by the FRA if it were not for individuals "spotlighting" the operation for the feds.

I quote two regional (for GT, CO) inspectors.

It's all in the wording, your statement was not entirely wrong.....but not entirely accurate either.

That shay is another example of a locomotive "in great shape". The idea for getting it out there started in 2008 with an idea hatched by Steve Torrico. The locomotive had only been in service for 2 years or so after a "full and thorough rebuild". My gut instinct that it was likely a bucket of bolts with many unresolved issues seems to have panned out.

Cheers, Jason


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 8:49 pm 

Joined: Sun Jun 17, 2007 8:03 pm
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Location: Warszawa, Polska
One blown ancient tube or steam pipe is all it takes to ruin your day... I wouldn't trust my life to 50 year old boiler tubes and steam pipes...

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 9:11 pm 

Joined: Thu Apr 14, 2005 9:34 pm
Posts: 2836
Location: Copenhagen, Denmark
So many emotions. I enjoy a little pleasure seeing this engine run, but the rational side of me raises so many questions. How many of us are aware of rebuilds that grew in expense because a) the original specification was found deficient or b) invisible flaws are found on castings or welds.

Vague memory holds a number of engines in the last few years on this forum that have required new dry pipes. Imagine #28 careening through a grade crossing with a broken dry pipe.

I am afraid the museum's position will be interesting.

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Fri Jul 06, 2012 11:19 pm 

Joined: Fri Mar 26, 2010 11:28 am
Posts: 135
Can I borrow all your hot air this coming winter? I really would like to save on my heating bill.

Why doesn't someone just CALL the railroad and ask? Novel concept in 2012 to pick up the phone.

I am surprised no one here is connected somehow with someone at the railroad...since so many seem to be connected to every other steam operation and repair shop in the US.

Let your fingers do the walking guys...I am sure they can use the rest from their normal routines.


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Sat Jul 07, 2012 12:02 am 

Joined: Mon Aug 23, 2004 9:04 am
Posts: 301
Location: Lawrence, Mass.
softwerkslex wrote:
Was the engine built with two water gauges? Because it has two now.


At the risk of throwing out more speculation in lieu of actual facts, this view of the backhead of sister engine DM&IR 347 (on display at the Minnesota Museum of Mining in Chisolm, MN) shows only one water glass.

http://www.flickr.com/photos/jterry618/4734299994/

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Sat Jul 07, 2012 9:24 am 

Joined: Sun Aug 22, 2004 7:19 am
Posts: 6464
Location: southeastern USA
[quote="john creasing § 230.17 One thousand four hundred seventy-two (1472) service day inspection.

(a) General. Before any steam locomotive is initially put in service or brought out of retirement, and after every 1472 service days or 15 years, whichever is earlier, an individual competent to conduct the inspection shall inspect the entire boiler.

Testing can occur on the locomotive under steam after such time that these requirements have been met including:

§ 230.16 Annual inspection.


This all means in order for a locomotive to be steamed, even to be "tested", when under the the jurisdiction of the FRA, it must go through a complete boiler inspection (interior and exterior) performed by someone designated by the locomotive "owner/operator" AS WELL AS an FRA witnessed hydrostatic test.
John[/quote]

Interesting John.... by my read this says nothing about steaming, just about what conditions are necessary to "bring a locomotive out of retirement" or to "initially put it into service." I scanned my copy quickly and....please find a citation and correct me if I'm wrong... there's no specific prohibition on steaming a retired locomotive's boiler if you aren't "bringing it out of retirement" or "initially putting it into service." The "service day" definition applies to locomotives that are in service. Show me by citiation why we must assume that any combination of fire and pressure demonstrates it is either going into service or leaving retirement and I'll stop questioning the wording.

I also notice there's no requirement that rails be spiked to ties. Doesn't mean it's a good idea to save the cost of spikes.

I'm an antique from the old hydro-and-hammer days, and I'm aware that some really scary things slipped through the cracks back then. Lots of things didn't...and many times nothing scary was going on. It's nice to know for sure. I'm also aware that what is legal isn't necesarily wise, and that what is wise and practical isn't always legal. Knowledgeable people can rationally reach a conclusion that a course of action is reasonable or not - ignorant people shouldn't be allowed to make such decisions. I wouldn't assume that anybody anywhere was doing anything unsafe or illegal given the lack of specific information about the people and circumstances or the latitude in the wording of the regulations. I prefer evidence rather than feelings based on skimpy factoids before making accusations, and on specific well-worded regulations for guidance.

dave

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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Sat Jul 07, 2012 11:15 am 

Joined: Sun Aug 22, 2004 1:51 pm
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Location: Somewhere east of Prescott, AZ along the old Santa Fe "Prescott & Eastern"
For all the back-and-forth we're seeing here, it appears--appears--that this whole incident comes right down to a hideous "gray area" of exactly what you want to call this incident or this stage of repair or restoration--whether it's retired, being tested, etc. If you try to come down on them from one direction, they can scurry the other way and claim the other thing.

No matter how finely you attempt to write ANY government regulation, someone will attempt to figure out an end-run around it. It doesn't matter if you write a CFR that stretches to twenty million pages; someone will force you to write fifty thousand more pages to fine-tune it because someone tries to exploit the gray areas.

What this will come down to is 1) whether local railroad, boiler, or industrial safety regulators HEAR about this incident, and 2) whether they want to, or have to, apply enforcement as a result. If someone akin to the notorious "James Riffin" were involved, the matter could take far more time in court than the matter is worth. (But, of course, with a "Riffin," it would be likely that this wouldn't be a one-off incident, either.)

I'm on a first-name basis with my city's Liquor Control Board chairman, because I write about the local beer industry. I've asked him about hair-splitting interpretations of arcane and otherwise inapplicable regulations (example--do state alcohol labeling regulations prohibit a brewpub from putting their house-made beer in a 64-ounce "to-go" growler labeled for another brewpub?). His reply: "Look--I've got bars that are acting as havens for drug dealers. I've got bars serving food without the proper licenses. I've got bars' neighbors petitioning me to shut down bars and stores they consider a nuisance. I've got better %$#@ing things to do with our inspectors' time than worry about what a bar is putting into the customer's jug WHILE HE'S STANDING THERE watching them fill it and paying more than he'd pay in a retail store!"

The FRA inspector may have better things to do. Ditto the Minnesota boiler inspectors. Maybe they'll get a finger shaken at them. Maybe they'll get a monetary fine. Let's discuss it if and when it happens.


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Sat Jul 07, 2012 11:26 am 

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Location: Chicago USA
Do the regs actually specify what it means to inspect the "entire" boiler?

Steve


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 Post subject: Re: DNE 28 2-8-0 Under Steam!!
PostPosted: Sat Jul 07, 2012 7:43 pm 

Joined: Sun Sep 12, 2004 1:41 pm
Posts: 834
Location: Bowling Green, KY
Perhaps they don't, but Websters does.

Cheers, Jason


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