August 2019 AGM

The C2 Project 2019 Annual General Meeting was held on Saturday 3rd August. We don't normally report this on the website as the formal business isn't likely to be of great interest to many people, and reporting the planning of technical work would just spoil your enjoyment of reading about it as it happens at each working party. However, this year much of the meeting was taken up with discussion about the boiler, which has far reaching implications for the project. So here's the tale of where we are, how we got here, and where we're going.

To save you trawling back through the website archives, we'll remind you that we imported the locomotive from China in 2007. That date is important. Also important to remember is that China is not in the European Union (EU).W

Now comes the boring bit about regulations. In 2002 the EU introduced the Pressure Equipment Directive (PED), which is mandated in every EU country by law. The PED is intended to ensure that all pressure vessels are safe to operate; a very noble objective. The way it goes about this, when applied to boilers like ours, is to require that the factory that made the steel works to the appropriate standards, and the chap who welded it together has the appropriate qualifications. All good stuff.

The way it is written, the PED is clearly intended for mass produced items. If we were importing 10,000 compressed air reservoirs, getting all the paperwork in place would be the obvious way of satisfying the PED. You wouldn't want to carry out comprehensive testing on every one of 10,000 items to prove each is good, and so the PED makes no provision for that. But that is a problem for us. We have one boiler and no paperwork. It would be quite practical for us to test the boiler to prove it is good, but the PED doesn't give us the option. We can provide evidence of material properties by using an accredited test organisation to test samples of our boiler plate (we have done this, and the mechanical and chemical properties are acceptable), but we can never provide the quality paperwork from whichever Chinese steelworks made the plate for our boiler more than 30 years ago.

Now we come to the second problem. The PED applies equally in all 28 EU countries; the wording (allowing for translation) is identical in all of them. 27 of those countries use Napoleonic law, which allows a little bit of flexibility. In that case, carrying out tests to prove that the boiler is good might be accepted, because you are working to the "spirit of the law". However, the UK uses Common law. In that case, the "letter of the law" applies, and there is no option to do anything but what the law says.

Having bored you with all the background about regulations and legal issues, we'll now return to C2 matters.

Paul has been busy working behind the scenes for the past year or two, trying to understand the PED in detail, and how it applies to the C2 boiler. He has also carried out design calculations for the C2 boiler, comparing it to British and German boiler standards as well as the PED requirements. We have had some initial discussions with the current Ffestiniog and Welsh Highland Railway's boiler inspectors (and 'Notified Body' design approval organisation), British Engineering, to understand their view on it too. Paul has also spoken to all the other 'Notified Bodies' which can approve pressure vessels for UK operation, and a couple of firms in mainland Europe too. Unfortunately they all have the same view that the precise wording of the PED is inflexible.

The key issue is that the PED applies to all pressure vessels built in or imported to EU countries after 2002. Because we imported the C2 from China in 2007, the PED applies to us. Now you can see the relevance of the date and country of manufacture mentioned at the beginning. Many other old steam locos imported from around the world were either imported before 2002, or had been built many decades ago in a country now part of the EU. They are all exempt from the PED requirements.

Of course the United Kingdom may not be a member of the EU for much longer. Maybe this will result in the regulations changing, but the PED is also enshrined in UK law. Knowing how long it takes to get legal documents changed (Dave 1 and Paul have worked on EU committees for many years), we consider it most likely that the existing PED requirements will remain in place for at least the next decade, and so waiting for a change that may or may not help us is unwise. Most changes to safety standards tend to make them more demanding! We need to work within the existing legal framework to move things forwards.

After much hard work, Paul presented the following four options to the other C2 Project members:

Option 1 is to get the boiler approved to the PED requirements. This requires us to have the original manufacturing paperwork. We have no paperwork.

Option 2 is to get the boiler approved, but not using the PED requirements. This relies on us proving the boiler is safe by calculation and testing, and a wide range of organisations, all the way from the Festiniog Railway Company through to the Office of Rail Regulation, agreeing that the boiler is safe to use.

Option 3 is to buy an old boiler from another EU country. This sounds crazy, but if the boiler was in use in an EU country before 2002, the PED requirements do not apply. We would still have to prove the boiler is safe to use.

Option 4 is to build a new boiler. This would come with paperwork, and so would be compliant with the PED requirements.

Clearly, option 1 is a non-starter.

Paul has been in discussion with many of the organisations which we would need support from if we were to proceed with Option 2. We consider it to be a very high risk strategy, as at any time any of the organisations could change their mind. We could spend a lot of money testing and repairing the existing boiler and still be unable to use it. The Office of Rail Regulation have told us that they don't even consider it to be within their remit to offer a derogation against the PED requirements, so this illustrates the level of uncertainty in taking this approach.

Option 4 guarantees success, but costs money. Potentially a lot of money.

All of the above was discussed in great detail at the meeting. It wasn't difficult to see, though, that only Option 4 guarantees that we will end up with a boiler and a certificate to operate it. And it fits with the C2 project mantra of working to the highest standards. All of the C2 Project members were in agreement with this, and so the motion to proceed with Option 4 was passed.

So, we're going to buy a new boiler. Next steps are to decide exactly what we need, write a specification, and to get quotes for it. There are likely to be options here too. If we carry out some work ourselves it may be a little cheaper, but will take more of our time which would be better spent on working on other parts of the locomotive. On the other hand, we can't afford a new boiler at present, so it will take a few years to save up for one. Obtaining the quotes should help us to decide which approach works best for us.

Hopefully the next update will return to the more usual themes, and will be illustrated with pictures of us machining chunks of metal and enjoying some Welsh sunshine.