“It was suggested I also request that no exception be taken by the FRA that the locomotive be allowed to operate at Railfest, just to be on the safe side, pending the request for waiver. Unfortunately, it is the request that no exception be taken that was denied by the FRA.”
Mr. Markoff,
I am somewhat confused by the above statement, and am wondering if “what we have here is failure to communicate”. If you currently have flue time which is good until December 2005, there is no need to request that “no exception” be taken to the locomotive’s operation between now and then. Could it be that the request was denied simply because it was superfluous, being a non-issue? I’d sure be inclined to call and ask. Unless there is some other issue that the FRA has with this boiler, it makes no sense that they would want it held out of service at this time. Your request for a waiver for a condition that will not exist until 2006 shouldn’t have any effect on its operation until then.
To the community in general:
Please note that the condition of the flues themselves has absolutely no relevance on the requirement for their removal. The reason that they are removed is to allow an inspector to enter the boiler to inspect the interior of the boiler barrel, throat sheet braces, and other parts that are not accessible while the flues are in place.
With Eureka’s limited in service days, and home in a very dry climate, she would be the perfect candidate to receive the requested waiver since any deterioration of the above parts should be minimal. However, If I understand the situation, Mr. Markoff has already dodged a bullet once by not having to pull the flues circa 1999 when the new rules came into effect, something that other operators tried and failed to do. If another waiver is granted at this time, as a private citizen on the outside looking in, I will be surprised (best of luck, Mr. Markoff).
In closing, everyone please keep in mind, that under the old system, flues were to be removed every five years, not every fifteen (yes, there was an extension process available, but it was a hit of miss proposition, and only good for one year at a time). Also, had the Engineering Standards Committee not been working on the new rules at the time of the failure at the Gettysburg Railroad in 1995, it is quite likely that far more draconian rules could have been put in place, rather than the current system, which on the whole is actually somewhat more permissive than the previous system.