Good afternoon all,

I have been thinking more about Steam operations in the US and am wondering when this sector might get saddled with environmental restrictions. I wouldn't want to see it get closed down. But I think a day may be coming. Is anyone in the business thinking that a proactive approach should be taken to mitigate the environmental concerns so the EPA and the greens don't come down on us? For the number of engines running they are only a drop in the bucket when it comes to pollution but they make a very visible target for environmentalists.

The technology is there to fix this problem. For operations that want to burn coal or wood Livio Dante Porta's Gas Producer Combustion System has done very well on many engines in other parts of the world, basically eliminating smoke and increase efficiency.

And for the oil firing guys. Nigel Day and Phil Girdlestone have both been building light oil/diesel fuel, burner/firing systems which also eliminate smoke and increase efficiency.

If you are unfamiliar with these items please see Martyn Bane's website:

http://www.martynbane.co.uk/modernsteam/modernsteamlocos.htm

I would like to know what people think on these things. I am not just trying to stir the pot here. I really think the preservation community should be more proactive to make sure we don't get legislated out of business. Just look at what is going on in Colorado now with the smoke issue.

I would like to know everyone's thoughts,

It doesn't take a large group of people to make a lot of noise over what they see as pollution. The idea of an uninformed individual crying foul against any organization could cause unnecessary and potentially unfriendly press is unsettling.

I feel it would be preferable to at least have a dedicated response or stance if something ever does come up. Not all operators are in someone's backyard, as in the case of the Western Maryland Scenic and the Durango & Silverton Narrow Gauge Railroad, who have both had issued raised by their neighboring communities with regards to smoke and locomotive emissions.

A valid complaint that could be lodged is that while other successful steam operators have taken efforts to reduce emissions (and even improve efficiency), others have not. I think that's an accusation far more incriminating than "you have taken steps to reduce emissions, but have failed to meet my standards."

This easily seems like a non-issue to some, but there is attention being paid these days to the smoke a locomotive creates. While working on a promotional video for the west coast locomotive group one of their main concerns is showing no imagery of the engine with smoke coming out of its stack, as they'll be presenting the video to a lot of "green" government officials and potential sponsors. To a lot of us, this could be akin to making a non-issue into an issue.

It's better to think of all the potential issues, no matter how trivial, and be prepared to meet them head on, or at least with an honest response like that theThe EPA does not consider regulation of steam locomotives to be necessary. And the smoke is part of the historical experience. And it's not just smoke, or carbon, but, lest we forget, a fine aroma, too.

TrainOrders topic on smoke and steam:

http://www.trainorders.com/discussion/r ... 10,1349398 (edit)

Kelly Lynch

While many of the comments to this point look at the issue of smoke from the locomotive, I find myself worried about other issues as well. What about the "externally lubricated" running gear which drops oil and grease along the ROW and which collects at the shop and station areas? I suspect that you could get fined for oiling around if you did the same thing around a factory or other more closely inspected facility

Stormwater regulations in some areas prevent treated boiler water from being dumped on the ground from boiler washes and make steam cleaning of the locomotive problematic as well. Has anyone run the costs on a oil seperation facility lately?

Even cinders carry heavy metals and other impurities that can cause ground water contamination, forcing the cinders to be disposed of at a landfill($$$).

For probably the past five years or, so, a steam shop foreman friend of mine has said that we need to be preparing for the day that we won't be able to run steam any longer. Not because of the reality, but the perception that somehow that one locomotive is doing more damage (because it can be seen) than all of the cars, factories and trucks combined. The same can be said for other forms of steam locomotive generated contamination where the public perception is of great harm to the environment in the community.

I'm afraid it's just going to get harder and harder...and its just one more thing that keeps me up at night.

Tim Andrews
Chattanooga, TN

Some years ago, Robert Le Massena wrote a lengthy essay for Trains Magazine that made a substantive case that steam locomotives were more environmentally friendly than diesels, based on the composition of their respective smokestack exhausts. Although I would say in all reality that said essay was more a "devil's advocate" discussion than a serious proposal, it's definitely an issue worth long-term examination.

There are some examples of leniency towards steam operations. The steamship Segwin in Ontario has a permit to "shoot ashes" (dump ashes into the lake). At least it still did when I visited in 1996. I was told the lake ferry Badger had a permit as well in 1998.

When we've run railfan trips with photo run-bys, the main request we get from the railfans is, "Make lots of black smoke!!" "Not enough, More Smoke!!"

Now, with our oil-burner, making the smoke they wanted certainly wasn't hard to do, and, at the time, there weren't too many other people around. Now, we have a new development of 250 houses just east of our yard.

I think that one thing all steam operators will need to do is to refuse these requests. Sure, we'll have to sand the flues once in a while, but the best place to do this (i.e. away from any houses) might not be the best photo location. But, only light gray smoke is certainly better than not being able to run at all because of smoke complaints.

One thing I've never been able to figure out is that some of these railfans will complain that some minor part of the locomotive isn't prototypical. Then they'll demand heavy black smoke for the run-by. How prototypical is that??

The Short Line Railroad Association worked with its members to help identify "best management practices" for engine servicing activities back when storm water management first became a big issue. The most obvious answer, of course, was to do as much servicing under roof as possible, which eliminates the storm water in the first place.

Last summer I visited several steam tourist railroads. One fired up, lubricated, and even washed their engine before bringing it out of the enginehouse. Another steamed up outdoors, pouring the coal on heavy while parked upwind from a residential neighborhood. Guess which one is going to make things bad for everybody?

I would think there might be a role for the Tourist Railway Association to develop "best management practices" for the steam crowd.

Alan Maples

Amen Brother Maples.

I recently retired from EPA's Office of Transportation and Air Quality -- before anyone jumps to conclusions or takes any actions about emissions from steam or other historic locomotives, they should at -- a minimum -- read what the regulations say.

After all, EPA doesn't ban the Woodward Dream Cruise, and many of the cars that are involved in it are fuel inefficient and have no emissions controls.

Bob H

Bob,

Can you find a nd post a link to those regulations? I would have no idea where to start to find them.

I would think a logical comment to make to someone who complains about steam locomotives is to point out that years ago there were 40,000 of these things running at once, and now there may be a few dozen on any given weekend, and to impress upon that person how far we have come in cleaning up our environment.

You could also follow that up with a comment to the effect that any offspring they have will pollute the planet more in their lifetime than that steam locomotive will. That won't win friends but its the truth.

I suspect there are two sides to this, the environmental, or regulatory side, and the political or public relations side.

The regulatory side will be easier to address. It is definable and is based on logical public debate. It will be easier for the historic railroad community to influence, much as was done for the new boiler regulations.

It will be likely that occasional operations will receive some sort of historic exemption.

Regular users of steam may have a more difficult time, unless they can prove the historic significance of the locomotives, via acknowledged systems like local, state or national registers. Currently historic buildings have a recognized historic building code and are exempt from many elements of the ADA. Daily users of steam, particularly those tourist roads which are tourist rather than historically based would be the most likely to be regulated, and possibly required to make modifications, and install emissions reducing equipment.

Any line regulated by the FRA may be exempt from some local efforts due to being part of “interstate commerce”

I suspect none of us will be exempt from issues of run off, making the various drips of oil, and other materials a specific target.

The political side will always be more difficult, because it is undefined. While diesel exhaust may be more dangerous it is less visible, so less likely to be subject to a local home owners groups complaints. On the other hand, being good politicians may help us control the regulatory side…

Currently here in California diesel locomotives (operated by the major railroads) have come under increasing criticism and regulation for their contributions to air pollution. For now this has not filtered down to the various tourist lines who also use diesels. At some point it is likely that there will be mandated retrofitting of railroad diesels as technology is defined that can reduce emissions. Even if technically reasonable the cost implications could be significant for a museum, if the regulations are extended to our collections.

Yet another boogeyman hiding under the next bridge.

Hi Everyone:

There is more to the environmental stewardship issue than smoke! We are introducing a "readily biodegradable" Pin, Bearing & Journal Oil called "Chelesic" this spring. It has just passed its biodegradability tests with flying colors and is a spectacular lubricant based on tests at Cass Scenic Railroad last Fall.

The Cass had contamination issues that, at one point, even caused some talk of tearing up the whole railroad!

Roadbed and adjacent stream contamination are real issues, especially with steam locomotives that utilize 100% loss lubrication systems. This extends to older types of solid journal bearings/boxes and traction motor lubrication on diesel locomotives too. Careful selection of lubricants is a must to prevent ground contamination issues from blindsiding unsuspecting railroad managements.

We have dedicated significant resources to developing specialty lubricants that are aimed specifically at heritage and short line railroads. Lubricants that work and are additionally low environmental impact is our sole focus and we know from experience that avoidance of environmental scrutiny and subsequent citations by the authorities is a must for long term survival.

Oil-only absorbent disposable pads are an inexpensive way to capture drips on locomotive service tracks. They're cheap and efficient. I've cleaned up drums of rainwater and residual oil by throwing in a few pads. They float on water but soak up oil like a hungry sponge. There wasn't even a rainbow sheen left on the rainwater afterwards.

- Doug Debs
Golden Gate Railroad Museum

There should be something posted at epa.gov, possibly a press release, and then quite a bit of material somewhere else.

(I didn't work on this project)

Bob H