No, not yet as the locomotive has not yet been placed into service. In the case of a new locomotive or a locomotive being brought out of retirement, the initial 15 year period shall begin on the day that the locomotive is placed in service
or 365 calendar days after the first flue tube is installed in the locomotive,
whichever comes first.
All they have done is test fire it, The test fire days will count as "service days" however. Once all the requirements of the annual inspection are complete, then the locomotive can be returned to service. I do not believe that the tubes have been installed for more than 365 days, so the clock has not started yet just yet.
Mike Ramsey