Sam:
Thanks for your concern, but 49CFR230 will have no effect on the 2001 season. That said, it will have an impact on the C&TS, and all FRA-regulated railroads, by 2002.
Below is the text of a brief I prepared for the Commission which was discussed at the July 29 Commission meeting in Chama.
The legislatures are already expecting us to come forward with a $200,000 request from each state for capital improvements. (This "telegraphing" was part of our lobbying efforts last winter.) The revised total will be approximately $560,000 for the coming fiscal year.
I would like to point out that this is 100% capital improvement money, and that the request is coming from the Commission, not RGRPC or the Friends. (The agreement between the Commission and RGRPC states that the Commission is responsible for capital improvements, and any new Federal requirements.) Operating subsidies for RGRPC are NOT being requested.
JAC
Boiler Work required by the Revision of FRA 49 CFR 230, “Maintenance and Inspection Standards for Steam Locomotives; Rule”
Background
On November 17, 1999, The Federal Railway Administration issued a revision of Title 49 of the Code of Federal Regulations, Part 230, related to the maintenance and inspection of steam locomotives. First proposed by steam locomotive operators in 1990 and recommended by the National Transportation Safety Board in 1996, the new rule was made effective January 18, 2000, and its provisions are being phased in over two years.
The major benefit to the C&TS of the rule change is the timetable under which inspections are performed. But the biggest impact on the C&TS is the requirement that all locomotive boilers be thoroughly inspected by January 18, 2002, or the locomotive cannot be operated after that date.
This “new requirement” is actually a clarification of the old rule, which evolved from 1911 through 1978. There was an implicit, though not explicit, requirement to keep all paperwork related to the locomotive boiler current with its actual condition. But most locomotive operators simply filed the “Form 4 – Boiler Specification Card” that was calculated when the locomotive was built with the FRA whenever an inspection was performed. (FRA Form 19, “Report of Alteration or Welded or Riveted Repair,” was used if a boiler was altered or repaired.)
FRA’s concern is that many locomotive boilers may not actually be as thick as described in the locomotive’s Form 4, or may have cracks or grooves in the boiler shell. It is also concerned that new calculations be done by a competent person, and FRA has hired a Mechanical Engineer to double-check figures as they are filed with FRA. The end result is the determination of the “Maximum Allowable Working Pressure” for the boiler. The MAWP may be the same, higher, or lower than the “traditional” MAWP for that locomotive.
The Impact on the C&TS
Put simply, at a minimum the C&TS must, for each steam locomotive that it will operate after January 18, 2002, do the following:
a. Remove all exterior lagging, appliances, brackets, etc. from the boiler.
b. Remove all flues. (This will require removing the draft appliances in the smokebox.)
c. Perform a boiler thickness survey, recording the results for later forwarding to a competent analyst AND FRA.
d. Perform a “minute” visual inspection for any cracks or grooving.
e. Make any alterations or repairs indicated by the thickness survey to maintain existing MAWP.
f. File the new Form 4 calculations, and supporting data, with FRA for checking.
g. Reassemble the locomotive.
RGRPC has already had the boiler thickness survey and Form 4 calculations done for K36 locomotive 488. The findings were that, in order to operate the locomotive at its “traditional” working pressure, additional diagonal bracing is required in the boiler interior, a new steam dome cover must be fabricated, and some staybolts must be replaced with thicker bolts. (This is similar to what the D&SNG has found for their K36s.)
It is safe to assume that all of our K36s will require this work. To return the locomotive to service without making these alterations, the MAWP of the locomotive would have to be lowered, and thus the amount of tonnage the locomotive can pull would be reduced.
Nos. 463 and 497 will require inspections as well. These are older boilers, and because they are of a different design it is impossible to predict what, if any, alterations will be required when the Form 4 calculations are complete.
Recommendation
RGRPC recommends making the alterations required to keep the K36 locomotives at their “traditional” MAWP, and estimates that the inspection and alterations will cost approximately $140,000 per K36 locomotive. A budgetary figure of $140,000 can be applied to 463 and 497 as well, but may have to be adjusted later. If any serious alterations are found to be necessary for 463 or 497, they will be addressed at that time.
As this is a Federal mandate, RGRPC recommends treating this boiler work as a separate project, outside the scope of RGRPC’s obligation for normal maintenance. RGRPC will meet its obligations by performing running gear overhauls and other locomotive maintenance and inspections. The boiler work could be contracted back to RGRPC or to an outside vendor, at the Commission’s discretion.
Locomotive 488’s work is already partially funded by the states (the need for alterations was not known at the time of last year’s appropriation request), and the locomotive should be fully compliant with the new rule by the opening of the 2001 season. This will leave five more locomotives to be inspected by opening day 2002 if all six are expected to be active at that time.
However, in view of the time and capacity constraints, as shown by the chart we recommend completing work on the three remaining K36s (484, 487, 489) prior to opening day 2002, followed by 497 (also by opening day 2002 if possible). We would then proceed to carry out the boiler work on 463 during the 2002 season. Under this plan the funding request to the states for this FRA mandated locomotive work would be for $560,000 in fiscal 2002 and $140,000 in fiscal 2003.
