The New FRA Steam Regulations
|By Stephen A. Lee|
The new FRA Steam Locomotive Rules (CFR49 Part 230) took effect January 18, 2000. Is this the end of the world? No. Don't panic, but do prepare yourself.
First, quit listening to rumors and get a copy of the rule. You can download it from Steam Central or the Tourist Railway Association web site. Find a quiet place and read it thoroughly. Then read it again. Give copies of it to everyone on your staff who works on steam locomotives and require them to read it. FRA is planning to hold seminars at several locations around the country to explain the rules and answer questions.
Check with your FRA office to find out when and where the one nearest to
you will be held and attend.
You may be asking yourself how and why these new rules came about (translation: "Who the hell came up with this?"). It's a long story.
While steam locomotive boilers (except the really ancient ones) were constructed to ASME codes in effect at the time, there were no repair codes for locomotive boilers; each railroad and each builder had its own policies, practices and procedures. To further muddy the waters, the AAR had recommended standards, as did many of the professional organizations developed by the crafts, such as the Master Boilermakers Association. In 1911, the Interstate Commerce Commission issued the first set of steam locomotive inspection rules, which also contained some practices. These rules, modified several times over the years and in concert with the many individual practices and recommended practices of the many different entities, governed the railroad industry for generations.
As the railroads dieselized and time passed, the people who worked under those standards retired and passed on, oftentimes taking with them a wealth of knowledge and experiences. In addition, steam locomotive construction for US railroad ceased in the 1950s, but boiler construction, inspection and repair continues to evolve and advance in all other areas. That had led to a few horror stories, in which Code-approved shops had in good faith done locomotive boiler work that did not meet any kind of precedent or sound practices, simply because the shops didn't know what they were dealing with.
About 10 years go, a small group of steam engine owners, operators, and mechanics got together to discuss the future of steam. Such subjects as maintenance and repair standards and lost skills were kicked around, among others. Every one there knew of a few horror stories and near-misses and those were discussed at length, as well. Subsequently, and not claiming to represent anyone but themselves, this group set about researching boiler inspection and repair practices from the industry outside of railroading. To that end, they enlisted the help of the National Board of Boiler and Pressure Vessel Inspectors (NBBPVI). This organization sets international standards for inspection and repair on all kinds of boilers and pressure vessels, from peanut roasters to nuclear power plants, and it works closely with the American Society of Mechanical Engineers (ASME), which sets the standards for all newly-constructed boilers and pressure vessels.
The group set about working with NBBPVI to write a set of steam locomotive boiler and firebox repair standards for possible inclusion in the National Boiler Inspection Code (NBIC). That would give Code shops a reference and standards to adhere to when dealing with locomotive boilers. This project took roughly 5 years of research, writing, give-and-take, arguments, snits, discussions, compromises, and so forth. Meetings were held 3 or 4 times a year, usually for not more than 3 days each as that was the demonstrated limit of attention spans and, sometimes, civility. The final result was adopted by NBBPVI and is now Appendix 3 of the NBIC. In the meantime, the groups was formalized as the Engineering Standards Committee. While on a roll, so to speak, the group forged ahead (uninvited, again) and wrote a proposed update to "Part 230" (full name: Title 49, Code of Federal Regulations, Part 230 "Inspection and Maintenance Standards for Steam Locomotives") which, it was hoped, would change the rules to more reflect the way steam locomotives are used today, as opposed to how they were used 60 years ago. This rewrite was submitted to FRA, where it found it's way to the bottom of someone's desk drawer and languished there.
In the midst of this came the Gettysburg accident. It's not necessary to recount that incident here, except to comment that it proved that complacence can bite, and it put the spotlight on modern steam locomotives. The National Transportation Safety Board and FRA both investigated the incident, and both issued reports. NTSB, which can issue recommendations but cannot implement them, called for mandatory low-water alarms on all steam locomotives, for licensing and certification of all persons who run, fire, service, maintain, or repair steam locomotives, and for water treatment programs to be prescribed by law. NTSB also recommended updates in the rules and more educational programs. NTSB pointed out that many of the skills are passed down from generation to generation, and that much has been lost in the process. Along the way, FRA remembered the draft changes ESC submitted, dusted them off, formed a joint agency-FRA task force, and began a 4-year process of rewriting and updating Part 230.
Which brings us to January 18, 2000. What are the big changes?
First are the minimum requirements. The new rule allows 1 year for operators to bring their locomotives into compliance with these. For example, if your locomotive has only 1 water glass, you have until January 17, 2001 to get a second one installed. If your locomotive does not have a water level indicating device on the tender water tank, you have one year to install a dipstick or sight glass or petcocks or drop hose or whatever device you choose to meet the requirement. Note that the selection of what kind of said device to install is left up to you.
If a locomotive operates under conditions requiring it to have a speed indicator, one must be installed by January 17, 2001. (This requirement is based on the fact that speeding above a certain level can result in decertification of the engineer, and it only makes sense to give the engineer a device to monitor his speed to avoid that.) Notice that the rule specifies a speed indicator, not a speed recorder or event recorder. Recording devices may be installed if the operator desires, but are not required.
Second is clarification of passages governing boiler inspections, flue removal, and Form 4 calculations. As mentioned in the new rule, these got confused over the years, and much mythology was created. The new rule attempts to simplify things.
The new inspection requirement is that every fifteen years or 1472 "service days," the boiler shell must be fully inspected, an ultrasonic thickness (UT) survey of the boiler and firebox must be performed and documented, and a new Form 4 calculated from the results of the UT survey and measurements. (A service day is defined as "any day the locomotive has steam pressure above atmospheric pressure and a fire in the firebox.") That's a lot of work, and it can't be done overnight. To minimize the "gotcha" factor, this provision is phased in, and can be retroactive in some circumstances.
Let's discuss the phase-in first. FRA will continue to consider requests for flue removal time extensions as provided under the old rules until January 18, 2002. After that, FRA probably will not consider such requests and will insist on full compliance with the new inspection requirements before the locomotive can be operated.
Second, the possibility of retroactivity. Operators of locomotives that had a full interior and exterior boiler inspection on or after September 25, 1995 have until January 18, 2001 to submit a request and supporting documentation to FRA to bring those locomotives under the new rules. The operator must submit documentation that the boiler received a full inspection, an ultrasonic thickness (UT) survey of the boiler and firebox, a new Form 4 calculated from the results of the UT survey and measurements, and documentation of how many service days the locomotive accrued since the inspection took place. FRA will review the request and the documentation and will notify the operator how many service days remain in the locomotive's inspection cycle. In other words, if you did the full inspection on old #97 in June, 1996, you've had it fired up 76 days since then, your documentation checks out and FRA agrees, the clock for that locomotive will start in June 1996, meaning that as of March, 2000, your locomotive has used 3 years and 9 months and 76 service days. It has 11 years and 3 months or 1,396 service days,
whichever comes first, until it has to be fully reinspected.
Now for the bad news. If an inspection was done after September 25, 1995 but no UT survey was performed, or the boiler inspection or the service days cannot be documented, you will probably have to do it again. Without a UT survey, you cannot prepare an accurate Form 4. Without documentation of the service days used, FRA cannot be certain how much the locomotive has been used. Similarly, if only a partial inspection was performed (e.g. the lagging and jacket were removed but the flues were not, or vice versa), you have a problem.
Of course, any locomotive now undergoing restoration must comply with the new rules from the day it is fired up again. And the old tale that "...it was overhauled just before it was put into the park so it should still be like new..." or "... it hasn't run for 10 years but it only ran two months before they parked it and it was overhauled before that..." will not fit the new rules, either.
Third are the new and deleted requirements.
A new requirement is that FRA be notified when certain boiler inspections and tests will be performed, so that they have the opportunity to attend and observe. Iif the agreed-upon appointed day arrives and the FRA inspector doesn't show, the inspection can proceed without him (or her).
Some sections, such as those dealing with journal bearings, were deleted in favor of consistency with other FRA rules governing the same items. The sections on cab curtains were deleted entirely; you can install them if you want, but it's no longer mandated.
Finally, the new rules require changes in the forms submitted to FRA and in the paperwork carried aboard the locomotive. FRA provides suggested examples of the new forms and the information it requires on the forms in Appendix C to Part 230. (Locomotives that travel far from their home base should be accompanied by copies of all up-to-date paperwork, just in case the local FRA inspector wants to see it.)
On the bright side, it is no longer necessary to have any forms notarized, and no longer necessary to file monthly out-of-service reports. It is very important to keep all paperwork and required FRA submissions current; failure to do so can result in FRA considering the locomotive retired, and if that happens, you could be faced with performing another full boiler inspection before you (or anyone else), can run it again. Service days especially must be accounted for, as so much of the inspection schedule is based on them. (Keep in mind that a banked fire is still a fire; any day the engine sits with the fire banked is a service day.)
Now, let's cover a couple of specific questions that may come up.
Form 4: The rule requires a new Form 4 to be calculated from the measurements and UT survey of the boiler as it currently stands, not when it was built new. This is to verify the maximum safe working pressure of the boiler in its current condition. An FRA mechanical engineer will scrutinize all Form 4's, the supporting data and the calculations. In other words, don't simply change the date on an old Form 4 and submit it, don't try to use the Form 4 from some other locomotive, and don't try to fudge your numbers. Any such actions could be considered willful violations. (This is as good a place as any to point out that the new rule contains a schedule of fines and penalties for violations, willful and otherwise.)
If, in the course of crunching the numbers, you find that the boiler cannot be operated at the current maximum working pressure, you have a decision to make. Let's say that old #97 has operated at 220 psi since the day it was built. However, during the course of the inspection and the resulting calculations, you discover that the boiler can now meet the required safety factor only if it is held to a maximum of 200 psi operating pressure. You can derate the boiler to 200 psi and continue operating it, or you can repair it so that it can continue to operate at 220 psi. The choice is yours.
Flues: In neither the old nor the new rules does the requirement to remove the flues have anything to do with the condition or life expectancy of the flues. The flues must be removed in order to fully clean and thoroughly inspect the interior of the boiler. The flues you remove can, if they are in good condition, be safe-ended and reinstalled. Under both the old and new rules, flues can be safe-ended twice.
There is much mythology about flues, and it's been aggravated by loose use of inappropriate terms such as "flue time" or "the flues expired," or "the FRA is making us replace the flues." The flues are not in question, the interior of the boiler shell is. There is no substitute for a meticulous examination of every sheet, seam, opening, reinforcement, nozzle, and rivet in the boiler, and the only way to do that properly is to strip the boiler inside and out so you can physically get at everything.
The decision to safe-end and reinstall the old flues or to install new flues or do a little of both is left to the locomotive owner/operator, as it was under the old rules. This allows flexibility for choices to be made based on labor costs, etc. as they pertain to an individual operation. Flues should be carefully cleaned and inspected before safe ending and reusing; cinder cutting and erosion of the interior (especially in the area where the ends of the superheater units lie) and pitting of the exterior can render a flue not worth safe ending.
Other flue-related myths have built up over the years. Research indicates that until the last 15 or 20 years of regular steam service, railroads were generally unable to get a full 4 years of service out of a set of flues. Flues often wore out due to cinder cutting, longitudinal splitting, cracking in the beads, severe pitting and other problems before the 4-year limit was reached, so engines were stripped, inspected and reflued more often than required by law. The provision in the Interpretations to the old Part 230 allowing a limit of 48 months of service within a 60 month period was not instituted until 1948, and it was in recognition of the fact that by that time steam was being used irregularly on many railroads.
And the process isn't finished. The ESC is developing a calculations guide for FRA, which will help operators with the mathematical formulas and methods for new Form 4's. ESC is also gathering Standard Practices and Recommended Practices books. These are being scanned electronically as part of two projects. One is the eventual development of one Suggested Practices Manual; the other is for inclusion in NBBPVI's new library on steam locomotive boilers, which will house all references that can be located. In addition, Appendix 3 of the NBIC is reviewed and updated as necessary. Other projects are also in the works, including efforts at reinstating some ASTM material standards for certain items that have been dropped over the years because they weren't used in anything but locomotives. One example is the standard for rivets.
There will be some growing pains and probably a few unintended consequences. But overall, the new rules should make more sense for everybody, and provide a higher level of safety for the people who work on the engines as well as for those who come to admire them and ride behind them. And that, after all, was the point of the exercise.
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Stephen A. "Steve" Lee is the head of Union Pacific's corporate heritage fleet, which includes 4-8-4 844 and 4-6-6-4 3985 as well as UP's E9s and DDA40x 6936. The opinions expressed here are his own, and not those of Union Pacific.
What's your reaction? Send your comments to firstname.lastname@example.org.
From John E. Bush:
"Many thanks to Steve Lee for his time, eloquence and humor in addressing an important step in the future of steam operations in this country! As Steve correctly noted, locomotives today are not operated as they once were and the legions of experienced mechanical personnel are long gone.
Operators of steam locomotives today must keep at the forefront of their collective minds the FACT that lawyers representing plaintiffs in injury cases which allegedly result from improper maintenance and operation will be subpoenaing maintenance records and training schemes as part of their "discovery." Such, if found wanting, will be used against the defendant!! Imagine the jury who is informed that a fully viable FRA system existed at the time of "the occurrence" but the failure to follow "even these most basic tenets of safe, responsible locomotive operation and maintenance" resulted in the horrible injuries suffered by the plaintiff. Goodbye!!!
In addition, the insurers providing the necessary Liability coverage for our collective operations will, rightly, be expecting and seeking compliance with the new regs., and rigorous adherence will provide them with a strong basis for defense of our organizations against allegations of injury.
Creation of an up to date set of rules and regulations coupled with strict adherence is a gratifying and necessary step ahead. Thanks to all who have been part of this effort!!"
From M. L. "Pete" Deets:
"Many thanks to the committee that went through the work and agony of getting the rules refined & in place. We once again have a solid guide instead of opinion and foggy memory. Steve is right, obtain and read the rules and then read them
again. They are very understandable. To me, the preamble is just as valuable as the rules because it lends some intent rather than just a cold rule."
From Marty Knox, Chief Mechanical Officer, Huckleberry Railroad:
"I just finished reading Steve's explanation of the "New" Part 230. It is the best writing I've seen on the subject, and I'm glad to see it on your website. I thought you might be interested in how one tourist rr is dealing with the new Part 230.
O nce the new Part 230 was adopted and the effective date announced, I decided to go ahead and perform the full 1472 day inspection [on ex-D&RGW 2-8-2 464]. There were several factors in this decision. Being narrow gauge, the Huckleberry falls in that gray area of a "non-system", but "non-insular" tourist railroad. For years we ran under the State of Michigan rules - we had never had a visit from an FRA MP&E inspector. I might have argued the case that we were under the state, but we cross a four-lane county road with lights and gates.
464 was retubed in 1989, and had 54 months of service. We might have gotten a flue extension - the again, it might have been turned down. We had her apart for new tires; we are building a new tender tank. But, I had hoarded my repair money last year, and had a chunk I had to use or lose. So, we had a local boiler outfit come in and remove the old tubes, and we purchased the new ones. Over the past month we stripped the lagging and jacketing; last thursday we removed the cab. A contractor is coming next week to baking soda blast the interior. We are buying an ultrasonic thickness gauge to do the thickness survey.
But today my crew shifted their attention to our 4-6-0 [ex-WP&Y 152]. We have some minor work to do on her, the biggest job being to drop the main drivers for inspection and work on her hub liners. She was re-tubed in June of 96; we did a UT examination at that time, but we still need to update the Form 4. We will be petitioning for special consideration, but for now we will do an annual inspection before we start running on Mother's Day."
From Kurt Bell, Librarian / Archivist, Railroad Museum of Pennsylvania:
"After reading Steve Lee's commentary about the revision in CFR49 Part 230, it is refreshing to see professionalism once again flourish in the steam field! Lee and his peers who served on the FRA Task Force for Steam are to be commended for their work. All too often we hear of "corners cut," poor attitudes and ameturism when it comes to steam locomotive maintenance and operation. The new regulations assure us all that the "right" way is the "safe" way. Many in the steam field informally call it the final answer to the "Peckerhead syndrome." Three cheers for Steve and his contemporaries for making steam safer for the public and the crews who run them."
From Al Phillips, legendary itinerant steam man for almost 30 years:
"My thanks to all who were involved in the project. I know there were a lot of thankless hours put in by a relatively few people, and all the rest of us should recognise and appreciate their efforts. Thanks gang!"