Waivers and relieve of rules.

I see the LIRR is trying to get out from safety requirements of FRA rules.

Petition for Waiver of Compliance

In accordance with part 211 of Title 49 Code of Federal Regulations
(CFR), notice is hereby given that the Federal Railroad Administration
(FRA) received a request for a waiver of compliance with certain
requirements of its safety standards. The individual petition is
described below, including the party seeking relief, the regulatory
provisions involved, the nature of the relief being requested, and the
petitioner's arguments in favor of relief.

Long Island Rail Road

[Waiver Petition Docket Number FRA-2003-15638]

Long Island Rail Road (LIRR) seeks a waiver of compliance with the
Passenger Equipment Safety Standards, 49 CFR 238.303 (e)(15)(i), for
their fleet of ``M-7-EMU'' passenger locomotives, as it pertains to MU
type locomotives equipped with dynamic brakes found not to be in
operating condition during performance of the exterior calendar day
inspection. LIRR states these EMU

[[Page 49840]]

locomotive braking systems operate differently than more traditional
style MU equipment. The LIRR letter of request indicates that the
braking system on this equipment utilizes axle mounted disk brakes
which provide 80% of friction braking effort, tread brakes which
provide 20% of friction braking effort, and additional dynamic braking
effort to a speed of 3 mph. If the waiver is granted , LIRR would treat
any failure of dynamic braking system on the EMU equipment as if it
were a traditional locomotive with defective dynamic brakes [49 CFR
238.303(e)(15)(ii)].
Interested parties are invited to participate in these proceedings
by submitting written views, data, or comments. FRA does not anticipate
scheduling a public hearing in connection with these proceedings since
the facts do not appear to warrant a hearing. If any interested party
desires an opportunity for oral comment, they should notify FRA, in
writing, before the end of the comment period and specify the basis for
their request.
All communications concerning these proceedings should identify the
appropriate docket number (FRA-2003-15638) and must be submitted to the
Docket Clerk, DOT Docket Management Facility, Room PL-401 (Plaza
Level), 400 7th Street, SW., Washington, DC 20590. Communications
received within 45 days of the date of this notice will be considered
by FRA before final action is taken. Comments received after that date
will be considered as far as practicable. All written communications
concerning these proceedings are available for examination during
regular business hours (9 a.m.--5 p.m.) at the above facility. All
documents in the public docket are also available for inspection and
copying on the Internet at the docket facility's Web site at http://dms.dot.gov
.
Anyone is able to search the electronic form of all comments
received into any of our dockets by the name of the individual
submitting the comment (or signing the comment, if submitted on behalf
of an association, business, labor union, etc.). You may review DOT's
complete Privacy Act Statement in the Federal Register published on
April 11, 2000 (Volume 65, Number 70; Pages 19477-78). The Statement
may also be found at http://dms.dot.gov.

Issued in Washington, DC, on August 12, 2003.

DEPARTMENT OF TRANSPORTATION

Federal Railroad Administration


Petition for Waiver of Compliance

In accordance with part 211 of Title 49 Code of Federal Regulations
(CFR), notice is hereby given that the Federal Railroad Administration
(FRA) received a request for a waiver of compliance with certain
requirements of its safety standards. The individual petition is
described below, including the party seeking relief, the regulatory
provisions involved, the nature of the relief being requested, and the
petitioner's arguments in favor of relief.

Long Island Rail Road

[Waiver Petition Docket Number FRA-2003-16265]

Long Island Rail Road (LIRR) seeks a waiver of compliance with the
Locomotive Safety Standards, 49 CFR part 229. Section 81(b), for their
fleet of ``M-7-EMU'' passenger locomotives and Dual-Mode Locomotives
(DM30) that requires that locomotives equipped with third-rail shoes
shall have a device for insulating current collecting apparatus from
the third-rail. LIRR is requesting that FRA extend a previously granted
waiver, LI-80-15, covering M1 & M3 Electric Multiple Unit passenger
cars to include newly acquired M7 cars and DM-30 locomotives. The
request indicates that the LIRR continues to utilize the Electric
Operating Instructions (CT290) for rail isolation and de-energizing,
which was the basis for the granting of the original waiver.
Interested parties are invited to participate in these proceedings
by submitting written views, data, or comments. FRA does not anticipate
scheduling a public hearing in connection with these proceedings since
the facts do not appear to warrant a hearing. If any interested party
desires an opportunity for oral comment, they should notify FRA, in
writing, before the end of the comment period and specify the basis for
their request.
All communications concerning these proceedings should identify the
appropriate docket number (FRA-2003-16265) and must be submitted to the
Docket Clerk, DOT Docket Management Facility, Room PL-401 (Plaza
Level), 400 7th Street, SW., Washington, DC 20590. Communications
received within 45 days of the date of this notice will be considered
by FRA before final action is taken. Comments received after that date
will be considered as far as practicable. All written communications
concerning these proceedings are available for examination during
regular

[[Page 67737]]

business hours (9 a.m.-5 p.m.) at the above facility. All documents in
the public docket are also available for inspection and copying on the
Internet at the docket facility's Web site at http://dms.dot.gov.
Anyone is able to search the electronic form of all comments
received into our dockets by the name of the individual submitting the
comment (or signing the comment, if submitted on behalf of an
association, business, labor union, etc.). You may review DOT's Privacy
Act Statement in the Federal Register published on April 11, 2000
(Volume 65, Number 70; Pages 19477-78). The Statement may also be found
at http://dms.dot.gov.

Re M-7 waiver request:

I think the LIRR is just looking for a clarification or ruling on how many dead trucks, if any, will be allowed in an M-7 consist. Since each truck has its own propulsion module on an M-7, instead of having only one propulsion system per car like the M-1 and M-3, will they allow one dead truck in a ten car consist. Maybe two dead trucks in a ten or twelve car consist, as long as they are not in the same car?
The disk brake stuff is thrown in to convince the regulators that we will not be overheating wheels with TBU friction brake in the event of no dynamic.


As a side note, we get M-1 cars in the shop for PIs all the time that are not setting up for dynamic brake. I've personally seen about 5 cars in the past 2-3 weeks.
A standing power test on M-1/M-3 will not show a dynamic brake problem, save for an open braking grid or other problem (dirty / open KM 3 switch, etc. ) in the DGC circuit (Dynamic Grid Check). Your power test will show only one point of power in this condition.
The only people that will see a dynamic brake problem (other than DGC problem) on this equipment are train crews, Babylon Dynamic Test Train, or shop personnel when they "run up" the propulsion groups.
In short, we already do have cars out there with no dynamic brake.
Some of them will run around like that until the next PI or shop repair visit.

Tom

Actually, I have to make one correction to my above post.
You CAN detect certain other potential problems in the dynamic brake circuitry in a standing power test.
If you test for power in both directions, and the car is dead in one direction only, you dump the train. Then you power test that car again. If it is alive in the previously dead direction, but dead in the previously alive direction, that generally indicates that the car did not run through the dynamic brake sequence properly.

Tom

I wish people would learn how the equipment works in the first place!
I do know that on some freight railroads, dynamic brakes need to be cut out on certain units to comply with axle braking requirements. To many axles in dynamic operation could cause a train to "blow out" in the middle and thus making a huge mess along the right of way.
I am not sure if previous series MU cars on LI. had dynamic breaking. I also don't see this as being a safety issue in the first place. There is only so much cohesion between a steel wheel and steel rail in the first place. With shoe on tread and disk braking alone will be enough to pinch a train down in a hurry and smoothly as well, and even too hard where it activates the Decelostat. All the dynamic brakes will do is save on tread and disk rotor wear, and thus save tax payer dollars in maintenance costs how ever, if the dynamics are more costly to trouble shoot then there is not any savings at all.
Brake on tread has been around almost as long as the railroads and has worked very well since the inseption and adoption of the automatic air brake.

Paul the M series cars techinicaly don't have Dynamic brake (its just called that by crews) LIRR and MNCR equipment runs in Blended brake. a combination of airbrakes and dynamic brakes guided by a micro processor (A-23 unit) that senses for speed - weight - brake feedback etc.

Current FRA regulation restricts a train to 60 mph if one or more cars are not having the Dynamic brake feature (untill tagged with proper defect tag and crew notified) the car can then run at normal speeds till next calender day inspection but must be cut out for repair.
I disagree about not being able to check the Dynamics without power. an open circuit can be detected, but the sequencing of the camgroup would tell you if there are contactor or interlocking sequence failure.
ps don't forget to put the test button in M3's back I hate those cars that do P1 only with no Dynamic brakes.

Dutch,

You are actually agreeing with me about interlocks and whatnot. That's what I mean by "running up" the groups in the shops. That's when we detect these problems. Let's say, for example, on group sequencing, call for "Coast", your cam is at position 1, your BK, BB, BM contactors are energized, but BCR does not energize account dirty/open BM interlock.)
When you go to brake and lose trainline 5, the cam is not going anywhere.
(This ties in with why you can dump the train, and check for power the other way. The reverser is interlocked to throw only from KM positions 24 -2. When you dump the train, it enables the KM controller to return to the neutral position of #24)
It's easy to troubleshoot this type of situation in the shop...not so easy outside. You more or less need two people, one on the handle, and one has to go under the train to look at the status of the contactors, relays, and KM position. Or, one could use a group sequencer outside, but he must make sure he is retracted, and properly configure knife switches on the pair he is working on.

You are correct about brake blending. But the dynamic brake is very real.
"Blending" keeps the friction brake to a lessened amount if there is sufficient dynamic brake amperage feedback to the A-23 unit. As dynamic fades out at lower speeds, the friction component increases. If there is no dynamic brake feedback, that car relies only on TBU friction brake.
Composite brake shoes lessen the friction heat aspect as compared to older all-metallic brake shoes, but wheel heating is still a concern.
(LIRR being a high speed operation with stations spaced a couple of miles apart, with heavy passenger loading.)
That's why the FRA wants dynamic brake to operate.

Tom

Dutch,

Re P1 only:
I guess you're talking about the STBS1 switch (in the M-3 cars only).
Yes, that is a problem. The main group cover has pads that are supposed to push the STBS buttons back in when you close the group cover, but they are worn and don't work very well. People forget to make sure they're pushed in and latched before they close the cover.
Result is 1 point of power only (No CCR energization).
That can be confused with a DGC problem or CLR problem.
The good news is it's a three second "repair" for a "1 and 0" complaint.

"P1 only" is technically a misnomer for this condition, but everyone knows what is meant by it.
True "P1 only" is full series, no transition to parallel. (Controller in P2 or higher.)

Tom

Ahhhhh...

Now I know what the "Obey CT-290 Rule" sticker between the M-1/3 cars refers to.

From skimming these, it seems LIRR is just asking to include the new equipment in previous waivers, instead of skipping a safety procedure.

the CT-290 rules are the Electrical safety rules. the reference sticker is so someone does not pull a jumper between cars if one car is still on live rail or the bug in the shop. if you did that and heat is on or the MA a flash would hurt the person pulling a 700 volt bus jumper.

I am very aware of blended braking and dynamic braking. As delivered, Metrolink F-59 PH locomotives were blended brake equiped. In the case of Metrolink F59s, this was contolled by the reduction from the 30CDW brake contol valve. This was later changed to a traditional stile of independant dynamic braking where the contoller was modified for the dynamic brake control as on freight locomotives, and blended brake functioned the same as before with an automatic brake pipe reduction. Antrak F-40 series locomotives that do not have MPC have blended brake as well as manualy operated dynamic braking.