Re: Asking for explanation

Brett B Wrote:
-------------------------------------------------------
> "A key difference however, is that the Como
> operation does not cross any public highways. EBT
> has a significant crossing just between the yard
> and the station. It's the difference between
> simply needing a state boiler certificate to allow
> occasional steam-ups, and the need to conform to
> the 49 CFR Part 230 rules"
>
> If you would be so kind, when you get a chance, to
> explain these regulations and what effect they
> bring, I would appreciate it. Thank you for the
> dialog

Hi Brett,

In simple terms, a steam locomotive that is operated on an "insular" railroad (one that does not cross public highways or connect to a major rail system) is governed primarily by the rules established by the boiler inspector in the state in which the operation is conducted. Each state has its own rules with regard to the criteria for obtaining a boiler certificate, but in general, it would likely involved a physical inspection of the machine, a review of the maintenance records and perhaps a steam-up or hydrostatic test. They typically don't routinely require a very invasive tear-down.

If the railroad is not insular.....and EBT is not insular.....then the rules of the Federal Railroad Administration (hence 49 CFR Part 230) apply. Under Part 230, a steam locomotive requires an extensive boiler inspection every 1,472 operating days, or every 15 years....whichever comes first. That inspection requires the boiler to be stripped down and surveyed with ultrasound. The flues generally have to be cut out to do it. A Certified Professional Engineer must then recalculate the maximum operating pressure for the boiler. It's a big deal, typically costing hundreds of thousands of dollars. For most tourist railroads, it takes the locomotive down for a year or more.....sometimes years. Places with full-time, well-equipped shops (Strasburg, C&TS, Cass, D&S, etc.) can often get it done more quickly, but even then, we're talking several months. And of course, anything that does not pass inspection specs must be fixed. If the boiler has thin spots, repairs must be made. Firebox sheets are often found with problems and replacing those is very labor-intensive, and requires special skills.

Bottom line, a good analogy is that a steam engine on an insular railroad is regulated a bit like an amusement park ride. A steam engine regulated by FRA gets treated more like an commercial airliner. Operating like Como does is not currently an option for EBT, so when the 1472 on Locomotive 15 runs out, she's done until another inspection is accomplished.

Apologies to the experts out there as I know I've glossed over a very complex topic......but I think for the purposes of the question Brett asked, it's probably close enough.

/Kevin Madore