Let me start with a short anecdote.
Early in my career I was appointed lead engineer on a project for a chemical plant in Texas. The project was to take a small unit operation consisting of a distillation column, two heat exchangers and a pump and to adapt it for a new service. Here are the parameters:
- The equipment had been built and installed in the 1940s.
- Since then it had operated safely and efficiently with no incidents.
- The equipment did not comply with the latest pressure vessel and heat exchanger code.
- The new service for this equipment was less stringent, i.e., pressures and temperatures were lower than before and the new chemicals being processed were no more hazardous than the old ones.
- Nevertheless we had to cancel the project because a fundamental change in service meant that the “grandfather clauses” that had allowed us to keep operating were no longer usable and we could not justify the cost of a major upgrade to the equipment.
Now fast forward to Ashland’s railroad.
In the posts to do with the proposed “High Speed Rail” project we have repeatedly pointed out that the Third Rail option is a code violation. Let us summarize the logic.
- The existing tracks were laid down in the years 1843 and 1903, long before the introduction of codes to do with track beds.
- The existing tracks are in violation of modern code in two regards. First the spacing between the tracks is too narrow. Second, there is insufficient space between the edge of the tracks and the public highway (see DRPT Basis of Design).
- Current operation of the tracks is permitted under the concept of a “grandfather clause”.
- Adding a third rail means that all the tracks, not just the new one, have to be upgraded to modern code.
- The fact that there has been only one major derailment in the Ashland area in recent years is immaterial. The codes’ requirements have to be followed.
- Based on the maps published by DRPT the proposed expansion is in violation of code.
- Hence the Third Rail option does not meet the requirements of Federal law.
- Hence the Third Rail option cannot go forward.
Let us apply the same logic to the 3-2-3 option.
- The project has two justifications. The first is to provide High Speed Passenger train capability. The second is to allow for a 95% increase in freight traffic and a 71% increase in the number of tank cars carrying Highly Hazardous Chemicals following the expansion of the east coast ports.
- Both of these rationales constitute a fundamental change in the operation of the tracks. This is analogous to the engineering analogy which started this post.
- Hence the grandfather clauses that apply to the existing tracks no longer hold.
- Hence the 3-2-3 option does not meet the requirements of Federal law.
- Hence the 3-2-3 option cannot go forward.
Two final thoughts.
- It is possible for the project team to ask for a variance from a safety code. But few regulators or engineers will ever do so for what should be self-evident reasons. That option was never on the table as we decided what to do with regard to our little engineering project.
- The project may be able to meet code by destroying and existing homes and businesses. But doing so is not part of the published option. If the project team changes the scope of work then there are many more new options to be considered.
To close out the anecdote that started this post; when I presented the results of the engineering analysis to the project manager I was not exactly the most popular person in the room because it resulted in cancellation of the project. But never at any time was there any question that we had made the right decision.