Folks,

Relaying a report that showed up on another e-mail list. The individual doing the reporting quoted below is what I consider a "reliable source" that went to the RR Museum of Pa. to check on specific details on GG1 4800 (all emphasis his):

"When I went to look at the GG1s, I was told that I could not climb on either of them and 4800 is totally "off-limits" and is cordoned off to prevent access to EVERYONE!

The EPA has recently 'inspected' the site and tested for PCBs. The 'allowable' PCB concentration for 'Public Sites' is 1 part per million per square centimeter!!!!! 4800 tested at a million parts per million per square centimeter!!!!!! The other G, though testing lower than that, was considerably above the EPA established parameter for safe access by the public. There is a $100 per day per unit FINE for violation of the EPA 'rule'! And it can be retroactive to the beginning of the ownership of the piece of equipment or the rule, whichever came later. The potential fine for the Strasburg Museum (under the 'retroactivity' clause) was in excess of $1,000,000!!!!! Some very very heavy
negotiations are underway on THAT!!! The EPA 'takes no prisoners'!

The 'paperwork' that the Museum got when they accepted the equipment specifically states that all PCBs were removed prior to moving the equipment to Strasburg! The MP-54 unit is as bad as 4800.

In order to go on (or in) ANY of the units with PCBs, the individual MUST wear a special protective suit AND be "certified" to work with or near PCBs. Only two people at the Museum are so 'certified'.

I am not specifically aware of the 'facts' as they apply to the asbestos issue on the steam engines but, I'm pretty certain it's probably just as rigid! I do know there is a program underway at the Museum to remove the asbestos
from, at least, some of the display pieces. Each unit, as it is worked on, will be placed in the restoration shed, "encased" in a cocoon and worked on in special suits. I don't believe (but, I'm not certain of this) that the ultimate
plan is to leave the units 'naked' when the job is complete. For now, the 'urgency' is to clean up the asbestos. I think the cosmetic completion will come later.

Interestingly, the grief and aggravation mentioned by those that have visited recently and posted here, is more than shared by the Museum folks, most of whom are volunteers!!!! They get the verbal abuse from many who come to visit
and are disappointed (or worse) by 'the rules'. In other words 'shoot the messenger'! Staffing has become an issue as a result!"

Now, this report, if true, literally frightens the bejabbers out of me. My understanding was that 4800 specifically retained its transformers, although I have heard for years that they were "cracked" (what that means, I don't know). Other GG1s (with one rumored exception) all had transformers removed at Wilmington Shops.

Multiply the implied hazard of PCBs by how maany GG1s have been preserved nationwide. Start opening the asbestos can of worms again with steam locomotives nationwide. Factor in the impact of such an "incident" as a massive EPA fine to insurance premiums. Consider the potential liabilities at a place like Union, or the B&O Museum, or Sacramento, or Scranton.

Should we panic? Was some EPA geek at Strasburg overzealous? Might we see a couple GG1s scrapped rather than rehabbed?

This is neither an attempt to denigrate the RR Museum of Pa. nor an opening to launch the whole wretched "are asbestos/PCBS a legitimate concern or not?" debate. We just would like facts.



LNER4472-NOSPAM-@bcpl.net

Alexander,

Don't want to question your credibility, but haven't we heard this same story (or a variation of) before? It is always that some museum or organization has been fined for having PCB-laden electric railroad equipment. Unless someone tipped off the EPA, I doubt an inspector just showed up at RRMPA to check the PCB content. No offense, but wouldn't Mr. Kurt Bell have posted on this if in fact it were true? Kurt, are you out there, can you confirm or deny?


david.wilkins@bardstown.com

> Don't want to question your credibility, but
> haven't we heard this same story (or a
> variation of) before? It is always that some
> museum or organization has been fined for
> having PCB-laden electric railroad
> equipment. Unless someone tipped off the
> EPA, I doubt an inspector just showed up at
> RRMPA to check the PCB content. No offense,
> but wouldn't Mr. Kurt Bell have posted on
> this if in fact it were true? Kurt, are you
> out there, can you confirm or deny?

1) The source of this report is, in my opinion, pretty well-placed to know a true story and would not be fabricating this stuff out of thin air. However, I am shielding his identity simply to protect whatever access he has to the Museum at the moment. I doubt the RR Museum of Pa. would react negatively to the revelation of such an incident (especially if the report is completely accurate), but I don't think I can chance it. Employee? Volunteer? Business associate? Something like that. Maybe.

2) Mr. Bell, for reasons I have yet to ascertain, has of late been keeping a VERY low profile on this board and in railfan circles. His former e-mail addresses are now duds, and he seems not to be discussing anything related to the RRMPa lately. Bureaucrats, as you can imagine, are loath to bite the hands that feed them. I have some nagging feeling that he may be under some sort of "gag order", either self-imposed or by some superiors. I may know more about the situation, but a public forum is not the place to discuss what could involve aspects of his private life (in a similar vein, it's none of our business how Steve Lee and the UP get along, or how well Linn Moedinger or Dave Conrad are doing, much as we might care in a general-health-of-the-walking-encyclopedias way).

Let's face it, if this report is true, it's pretty negative news all around, even though none of it is really the fault of rail preservationists (the Museum the people who bought and donated the loco, etc.). Museum officials are (rightfully) scared to death of TV crews showing up and doing a 2-minute report that, in its abruptness, portrays Strasburg as another Love Canal. There are similar fears of bad publicity surrounding any such "bad news", such as a washout ("Is it curtains for the old steam train? Film at 11!"), derailment, etc. But retreating back into a shell and never saying anything about such issues only exacerbates the situation by making said place look like it has something to hide. Such turtles hiding in their shell can only hope that the issues in question never get the attention of the general public; sometimes they luck out, sometimes they don't.


LNER4472-NOSPAM-@bcpl.net

Sandy,

I think you may have some misinformation. PCBs are still allowed to be used in electrical equipment, this includes railroad locomotive transformers. I think the limit for PCB is 1,000 PPM.

As a matter of fact the asbestos is still allowed as well. Both are allowed to exist in older installations. Many large industrial plants had hundreds of tons of asbestos and thousands of gallons of PCBs. The EPA can force a plant to purchase all new transformers, capacitors, and switchgear. As the older equipment fails or is updated the bad stuff is disposed of and replaced with new stuff that has not yet been determined to kill humans. If the PCBs are contained they are probably not a problem.

A measurement of one million parts per million per square centimeter sounds fishy as well. I have never heard of a ppm reading combined with per square centimeter. Next a million parts per million means it is pure PCB and that sound fishy as well. The oil used in electrical equipment is not 100% of any one component.

I don't mean to discredit your source but I think some of the facts are not right.

Tom

> As a matter of fact the asbestos is still
> allowed as well. Both are allowed to exist
> in older installations. Many large
> industrial plants had hundreds of tons of
> asbestos and thousands of gallons of PCBs.
> The EPA can force a plant to purchase all
> new transformers, capacitors, and
> switchgear. As the older equipment fails or
> is updated the bad stuff is disposed of and
> replaced with new stuff that has not yet
> been determined to kill humans. If the PCBs
> are contained they are probably not a
> problem.

*Are there different standards for off-limits industrial settings and public displays? Wouldn't it be entirely possible that the allowance of PCBs/asbestos might be acceptable if 4800 or whatever loco were still in service, but not as a static museum relic (think your car insurance and regulations differing between a "daily driver" and an antique in the garage)? I would fully concede that there are not quite the hazards with an industrial setting as with a public room (or, perhaps, the hazards are considerably different), but frankly I would expect people who have to work with the stuff daily to complain more ferociously than the people who have to pass by the "hazard" once a week/year.

> A measurement of one million parts per
> million per square centimeter sounds fishy
> as well. I have never heard of a ppm reading
> combined with per square centimeter. Next a
> million parts per million means it is pure
> PCB and that sound fishy as well. The oil
> used in electrical equipment is not 100% of
> any one component.

*Conceded. He must have gotten some reading or piece of data incorrect.

> I don't mean to discredit your source but I
> think some of the facts are not right.

*The fundamental question we still haven't gotten an answer to: Is GG1 4800 (or any other loco in the collection) now considered a hazard by the EPA, and will the Railroad Museum of Pennsylvania have to take expensive corrective action (never mind possible fines) as a result? And might the same thing occur with other preserved locomotives as a result of asbestos or PCBs? Or did some EPA flunkie mis-apply the rules?


LNER4472-NOSPAM-@bcpl.net

This is even worse then CFR49.
IMHO the use of "dynamite" headlines and very few facts make this whole subject not one for internet activity. When the facts are known, the procedures explained, and corrective action taken, that is the time to treat this as a learning experience. Henny-Penny or something informative, it's up to you.

PS: one never gains anything by bad mouthing either the EPA or the FRA!

http://ecfr1.access.gpo.gov/otcgi/cfr/otfilter.cgi
lamontdc@adelphia.net

Here's a very simplified explaination. The concentration referenced in terms of parts per million per square centimeter relates to a special test procedure for testing surfaces for contaminants. A specified grid area is wiped with a collector (swab or pad) and the collector is then analyzed for the concentration of the subject contaminant with the result reported as a concentration per unit area. Parts per million (ppm) relates to a concentration of a particular chemical compound (PCBs) or element (lead) in a matrix, either dissolved in a liquid matrix (such as water or oil) or in a solid matrix (such as soil, or perhaps old semi-solid oil).

If the transformers and other electrical gear that contained PCB oil were removed, there might still be residual contamination from leaks or spills during the operating life of the locomotive. The floor, nearby wall surfaces, etc would still be "contaminated" until properly decontaminated. Simply removing these pieces of equipment does not entirely remove the (potential) problem.

Hope this helps a little.

ssyfrett@bellsouth.net

One of the things that trips my alarm button is that any time I have visited the RMPA, climbing on the locomotitves was never allowed, anyway.
It had nothing to do with PCBs; it was simply the fact that they didn't want people climbing on the exhibits, unless the particular locomotive was set up for public cab access...e.g. stairways, handrails, etc.

The cab on a GG1 is so tiny and cramped it should suprise no one that public access there isn't allowed. And nobody but staff has any business whatsoever in the other areas of the unit.

> One of the things that trips my alarm button
> is that any time I have visited the RMPA,
> climbing on the locomotitves was never
> allowed, anyway.

*This individual was supposedly in a position to do so out of the public eye, and was supposedly looking to see if a modification made to the "rest" of the PRR's GG1 fleet was also made to "Old Rivets" 4800. I believe he asked permission, and was told why not. Thereby starts the story.

> It had nothing to do with PCBs; it was
> simply the fact that they didn't want people
> climbing on the exhibits, unless the
> particular locomotive was set up for public
> cab access...e.g. stairways, handrails, etc.

*I believe one of the GG1's (and I think it was 4800) WAS formerly set up for cab access with stairs, etc. Of course, all we're waiting for now is another ADA lawsuit, and those days will be over as well.

> The cab on a GG1 is so tiny and cramped it
> should suprise no one that public access
> there isn't allowed. And nobody but staff
> has any business whatsoever in the other
> areas of the unit.

*As he said, they supposedly said even STAFF aren't allowed in the GG1's without protective suits and training.

Look, the guy wasn't asking to pose in the cab for a picture. He had a legitimate (albeit arguably quite trivial)research query involving accessing the 4800, which was as a prototype in many ways mechanically and physically a "one-off" loco with many differences from the rest of the fleet.


LNER4472-NOSPAM-@bcpl.net

I do not know a lot about pcb's, but believe if they are sealed in the trandformer, they are considered "safe enough", but there needs to be a plan to deal with the pcb's eventually.

Asbestos I do know something about, as I used to remove the stuff on a small scale as a maintenance worker. 1. As long as it is not friable, meaning it is shedding fibres to the air, asbestos is safe enough as it is. At one time, asbestos removal was practiced as a matter of course. Then it was reccomended to remove only when there was a risk that it could be damaged in the future. 2. There are different rules for schools VS public areas like a museum VS private areas. As I recall, the values for schools were 10X stricter than other public areas. 3. The tests for asbestos contamination involves setting up air samplers that draw in air at prescribed intervals over a 24 hr period. the fibres are drawn into a filter, which is later examined by a lab. If possible, the sample area is sealed while the pumps are running.

I will be watching this thread with more than casual interest. In the mid 90's, I was a docent in 4935 at the RMofP. If there were high pcb's in there, I was exposed. I wanted to go in 4800, but I never got the chance.

Per the terms of service agreement, I don't wish to engage into a flame war over GG1s. However, I think some issues regarding the post that started this can be addressed in an adult way. Yes we did previously hear of a rumor of the EPA cracking down on GG1s. We heard on this board before that some owners of GG1s were being fined by the EPA. The former rumor seemed to circulate around some unnamed ones in the northeast. The more important issue surrounds the issue of source credibility. If you do not wish to share your source, and we are hearing nothing from the RRMPA either officially or unofficially, then all we can do is speculate. While speculating regarding of what to do if your museum or organization finds itself in a similar situation is helpful, speculating the specifics of what may or may not be happening to the RRMPA is another issue and somewhat dangerous. I find it strange that you got the report from another e-mail list, but you aren't willing to pass the identity along. Then again, itÂ’s your choice.

Further speculation as to whether Mr. Bell is allowed to post here or not is also speculation, and just that. Maybe we should just keep such speculation under our hats.

Further, no this is not an attempt to silence discussion on the issues related to toxic/hazardous materials and collections management. If such discussion is needed, (I think it is) it should have been done in a hypothetical manner, because you can't/won't name sources. Failure to name sources leaves us with the hypothetical argument, and gets us distracted concerning the credibility of the report.

Anyhoo, if the GG1s were perceived to be that dangerous, I doubt the EPA would allow one to be sitting in a museum. After all, the carbody isn't air or water tight, and the "contaminated" portions are open to the same air we breathe when inside RRMPA. Either way, if true, then it is a problem for owners of large electric locomotives. If not true, then something to think about for such owners as a "worst case" scenario.


david.wilkins@bardstown.com

I recommend that readers of the Interchange pay little or no attention to posts that convey hearsay-- that is, statements by a witness who did not see or hear the incident in question but heard about it from someone else.

Hearsay is rarely reliable; it's usually a volitile mixture of truth and untruth. It's not permitted as testimony in courts of law for just this reason. People can post it, but in my opinion it's not worth our time or attention.

eledbetter@rypn.org

> I will be watching this thread with more
> than casual interest. In the mid 90's, I was
> a docent in 4935 at the RMofP. If there were
> high pcb's in there, I was exposed. I wanted
> to go in 4800, but I never got the chance.

PCBs are not volatile compounds like benzene in gasoline, meaning they are not generally found in the air unless the oil in which they are contained is sprayed/atomized and breathed in. Unless you had excessive dermal (skin) contact or ingested (ate) oil contaminated with PCBs you were likely in no real danger. (Note that the reported concentration was expressed in terms of ppm/unit area. If the concern were in the breathing zone, air samples would have been collected in addition to the wipe samples, and those results would have been expressed in terms of concentration/unit volume of air.) If a fire ever broke out inside one of these units, however, I would make myself scarce, as low temperature combustion of PCBs can result in some byproducts that are worse than the threat of the PCBs.

I am not trying to minimize the health concerns about PCBs, but if you are really concerned about possible exposure, talk to your doctor.


ssyfrett@bellsouth.net

I was at the RRMPA on August 5, and there was a set of stairs up to the south east cab window of the GG1 with no normal internal cab acess. There were no signs that warned of PCB, or any type of contamination anywhere inside.

I feel that if this were indeed true recently, the doors would be locked, sealed,and warning tape strewn all around the property.

I don't recall seeing a dateline on the semi-ambigious email that started this string. Could somebody enlighten me as to a date this supposedly happened?

> "When I went to look at the GG1s, I was
> told that I could not climb on either of
> them and 4800 is totally
> "off-limits" and is cordoned off
> to prevent access to EVERYONE!

> The EPA has recently 'inspected' the site
> and tested for PCBs. The 'allowable' PCB
> concentration for 'Public Sites' is 1 part
> per million per square centimeter!!!!! 4800
> tested at a million parts per million per
> square centimeter!!!!!! The other G, though
> testing lower than that, was considerably
> above the EPA established parameter for safe
> access by the public. There is a $100 per
> day per unit FINE for violation of the EPA
> 'rule'! And it can be retroactive to the
> beginning of the ownership of the piece of
> equipment or the rule, whichever came later.
> The potential fine for the Strasburg Museum
> (under the 'retroactivity' clause) was in
> excess of $1,000,000!!!!! Some very very
> heavy
> negotiations are underway on THAT!!! The EPA
> 'takes no prisoners'!

Thanks. I am not worried, but I am interested. Actually, the inside of 4935 was rather clean. I do not remember seeing any oil spills at all. Little dust here and there, but that's to be expected.