Application to use an Alternative Requirement (In accordance with the Railway Group Standards Code and Standards Manual)

Transcription

1 Application to use an Alternative Requirement (In accordance with the Railway Group Standards Code and Standards Manual) Some guidance is provided here to help with the completion of this application form All images and tables should be clearly referenced in the text and sent as attachments to RSSB with your application. Reference Number: (RSSB to complete) 1. Problem statement: New build steam locomotive Tornado was built with 90 mph running in mind in order to take full advantage of it being a new build locomotive, taking into account the increasing density of traffic and operating speeds on today's GB mainline railway. However, the largest steam locomotives have traditionally been limited to a maximum speed of 75 mph, as stated in the current standard (GORT3440 Issue 2 / RIS TOM Issue 1). By anticipating the new processes proposed for the revised heritage standards under projects and , some of which A1SLT has contributed to through the provision of fully instrumented test data during the locomotive's original approval in 2008/9, it is intended to demonstrate that the speed limit for this locomotive can be increased to 90 mph without compromising safe operation. 2. Title of deviation application: 90mph testing of new build Al Steam Locomotive Tornado (TOPS 98863) 3. What is the requirement you can t comply with? ( Requirement number Document number RIS-3440-TOM Issue number One Issue date 03/12/2016 Title of document Steam Locomotive Operation The infrastructure manager shall time steam locomotive movements to take account of restrictions on maximum permissible speed according to driving wheel diameters, as shown in Table A. Other documents referenced in the text: For ease of reference, please provide the requirement, document number, issue number, issue date and title of any other documents or requirements being referenced within your application. Requirement number Document number Issue number Issue date Title of document Insert the text of the requirement as set out in the document. 4. Why can t you comply with the existing requirement? [See deviation guidance: section 2, A.1.] Explain why it is not reasonable, to comply with the existing requirement on either a temporary or a permanent basis. Explain the consequences for you (for example cost and service performance) of complying with the requirement. It should allow the reader to understand why these consequences make it unreasonable to comply with the requirement. In contrast to all other Steam Locomotives registered for operation on UK mainlines, 'Tornado' Page 1 of 13 PP257_F1 Issue 5: December 2016

2 (TOPS 98863) is a replica locomotive of all new construction. Hence, it is free from typical age-related considerations and has now operated for nine years on Network Rail infrastructure with no issues to report. It has covered almost 90,000 miles which gives confidence in the locomotive's abilities and reliability. The original A1 locomotives were designed as express passenger locomotives to operate at the prevailing operating speeds of the time. In common with other 'pacific' locomotives on the East Coast Mainline, service speeds of up to 90 mph were common, with occasional 100 mph maxima being recorded. A maximum of 105 mph is documented for the last member of the class, in somewhat run down condition, at the end of steam on the former British Rail (BR) Eastern Region. As normal services increase their speed and density, to maintain the ability to run credible heritage services on the East Coast Main Line (ECML), it is imperative to run the locomotive at speeds above 75 mph. Initial work alongside Virgin Trains East Coast, who are supportive of this proposal, suggests that the incremental change to 90 mph would enable better pathing and permit steam to continue to operate on the ECML. The Office of Rail Regulation has also been consulted on this proposal and has signalled its support for this locomotive to be tested with a view to operation at 90 mph in due course. This application is for a temporary deviation to allow testing of the new locomotive to proceed at speeds of up to 90 mph plus 10% overspeed. Dependent on the outcome of this testing, the A1 Trust intends to submit a further application for derogation for the maximum authorised operational speed of the locomotive to be increased up to 90 mph for passenger services over prescribed infrastructure. This assumes that the current redrafting and issuing of GMRT2003 is not complete by that time; otherwise, the replacement standard has a proposed mechanism by which such increases would be approved without the need for a derogation. 5. Where can t you comply with the requirement? [See deviation guidance: section 2, B.2.] As specifically as possible provide details of the area where you cannot comply with the requirement. For example, geographical limits, limits on type, pieces of ranges of equipment, identification numbers, signal numbers, specific assets or operations. The locomotive for which this application is submitted has a driving wheel diameter of 2032 mm (6feet-8ins) and is therefore limited by the RGS criteria to 75 mph. This temporary deviation is to allow the speed limit of 75 mph to be exceeded for testing to be undertaken with a view to allowing semi-regular operations up to a maximum speed of 90 mph, on specified stretches of the ECML only. The proposed testing would involve a return run over the ECML between Doncaster and Newcastle. Speed would be increased in 5mph stages on a leg-by-leg basis. Each further speed increase will be subject to satisfactory conclusion of the previous leg. A 10% overspeed test for circa 5-7 miles would be carried out as part of these tests. It is therefore requested that this temporary deviation allows testing up to 100 mph. The following details the sections of route proposed for higher speed testing: ECM1-3 - Arksey to Colton Jn. l58m0ch - l83m0ch - Down Fast - 80 mph; ECM5 - Skelton Jn to Sessay - lm23ch - l8m0ch - Down Fast - 85 mph; ECM5 - Sessay to Darlington - l8m0ch - 44m0ch - Down Fast - 90mph; ECM5 - Durham to Low Fell Jn. - 67m0ch - 77m0ch - Down Fast - 90 mph (including brake test); ECM5 - Aycliffe to Skelton Jn. - 49m0ch - lm23ch - Up Fast -90 mph (including 100 mph section); ECM3 - Colton Jn. to Arksey - 183m0ch - l58m0ch - Up fast - 90 mph. Page 2 of 13

3 6. What are you proposing to do instead of the existing requirement? [See deviation guidance: section 2, B.3.] A submission to the Standards Committee, for derogation against the relevant range of Railway Group Standards was made on behalf of the A1 Trust in March 2006, for line speed operation up to 75 mph. That submission was accepted and a certificate ( DGN) was issued. It is not intended that this application for a temporary non-compliance should nullify, or in any way affect this previously issued certificate of derogation. Similarly, an application was made in 2008 for testing up to 90 mph with this locomotive and was authorised by RSSB and a certificate issued in August (Ref TNC). The requirement to examine all structure families to mitigate risk on such structures designed after the use of steam traction mean that the temporary deviation lapsed before it could be used. Positively, and at signficant expense by the charity that owns the locomotive, a revised set of guidelines is now available to cover all structures on Network Rail infrastructure so that suitable assessments can be made in the same way that operation of steam locomotives at 75 mph is undertaken. A copy of this report is available to RSSB if required. The risk mitigations quoted within the previous application for derogation remain the same for the majority of the RGS referenced in the original submission. That is to say the increase in the maximum speed from 75 mph to 90 mph for testing purposes is not seen to increase risk so far as these RGS are concerned, or does not compromise the existing derogation mitigations. These RGSs are listed at the end of this section. A detailed hazard identification process has been undertaken and each risk has been considered and mitigated where necessary. For example, specific traincrew restrictions apply such as no use of route conductors. The fitness to run examination of the locomotive also has specific elements added for the higher speed operation having been developed from Tornado's multiple operations on the Royal Train and the 2013 high speed operations with A4 locomotive 4464 Bittern (TOPS 98819). A copy of the DB Cargo risk assessment (RA) is included with this submission. An area of risk that has entered folklore from 1938 is the inside big end bearings on some locomotives. On 03/07/1938, whilst descending Stoke Bank on the East Coast Main Line (ECML), A4 Mallard set a 126 mph world speed record for steam traction that still stands today. In doing so, it overheated the middle big end and had to be removed from its test train at Peterborough, not the planned Kings Cross. The A4s had a 'stink-bomb' fitted inside a tube in the big end to warn of failure and the distinctive smell was detected not long after speed was shut off on the record descent. It is viewed that the bearing failed when steam was shut off, the forces being much higher at that point that when under power. Tornado has an improved big end arrangement compared to the pre-war A4 design. However, in place of a 'stink-bomb', Tornado is being fitted with a digital temperature sensor on the middle big end which will provide a display into the driving cab to warn of any likely failure. This will remain on the locomotive post-testing. Additionally, being an all roller bearing engine is an advantage, and temperature sensing stickers to alert to potential failure are fitted to the locomotive. These will be changed ahead of the testing and monitored frequently. The risk is seen to increase so far as the following RGS are concerned and additional mitigation(s) to control this increase is outlined against each accordingly: a) GMRT2045, Issue 4, March 2016, Compatibility Requirements for Braking Systems of Rail Vehicles (formerly GMRT2042): The replica locomotive is fitted with air operated brakes. The braking system has been designed to achieve the requirements of a previous version of this standard and this was further demonstrated with a significant series of tests where the loco proved itself capable of meeting the requirements for stopping distances mandated in Clause 5.1.2a for lines signalled in accordance with GKRT0034 Appendix B. The locomotive, hauling a prototypical train length, stopped in 897 metres against the 1144 metres required by the standard. It is proposed that the maximum speeds of the acceptance tests will be incrementally increased from 75 mph in steps of 5 mph. A full test to zero will be conducted from 90 mph; the stopping distance will be measured to ensure continued compliance with this RGS. All tests will be conducted on infrastructure agreed for the tests with Network Rail (planned to be ECML Page 3 of 13

4 between Doncaster and Newcastle). So far as the requirements for the parking brake are concerned, as these regulations apply only to a stationary locomotive, no changes are seen as necessary from the previously agreed derogation. b) GMRT2130, Issue 4, December 2013, Vehicle Fire, Safety and Evacuation (formerly GMRT2120): Nature of Non-compliance (as submitted for the Derogation dated March 2006): - As with other steam locomotives, the source of power is a coal fire. Emissions could lead to line side fires. -The Class A1 Steam Locomotive uses coal as its fuel, which will be stored in an open tender. - The cab floor is to be constructed of wood, a flammable material. - No fire detection system is to be fitted. Current Mitigations: - [Coal fire] The A1 class locomotive is fitted with spark arrestor screens to control cinder and ash emissions from both the chimney and the ash-pan. These are subject to specific acceptance through the Engineering Acceptance procedures and will also be the subject of special checks before the test running. - [Coat Fire] Discharge and disposal of ashes from the ashpan is only permitted at designated points at maintenance depots. - [Coal tender] The ignition of tender coal has not proved to be a significant hazard on any steam locomotive operating in this country. The A1 is not different in this respect to any other heritage locomotive. One of the duties of the fireman is to slake the coal with water to reduce dust to a minimum and improve its burning efficiency. This additionally reduces such fire risk. - [Cab floor] It is of great importance that the cab floor should be non-slip, to enable the fireman to work safely. Wood has been traditionally used on steam locomotives and has not proved to be a significant fire hazard, but has given the stability required for non-slip operation. The A1 will be no different in this respect to any other heritage locomotive. - [Fire Detection] An automatic or semi-automatic fire detection system would be impractical in the open environment of the cab, subject to the smoke and heat emissions from the fire-hole door. There is invariably at least one person in attendance in the cab. - [General] The maintenance of the cab environment with particular attention to the cleaning of oil spills and general cleanliness is regarded as being of specific importance. - [General] Use of locomotive restricted as a 'heritage' vehicle. Additional Mitigations for 90 mph Testing: -The effectiveness of the spark arresting equipment (as required by GMRT2003) will be closely monitored during the tests and has shown itself to be very efficient up to 75 mph in regular use and during slightly higher test speeds. If deficiencies are found these will be corrected before undertaking further tests. -There will be a continuous monitoring of the spark arresting equipment during the tests. The testing will be undertaken late evening / night time which will accentuate the visibility of any excessive spark emissions. -Each of the successive runs of the tests will be conducted over the same stretch of railway, which will enable continuous monitoring for any line-side fires that may arise. Page 4 of 13

5 -The increase of risk between 75 and 90 mph is seen to be minimal (the locomotive will work for longer at the same power setting, rather than any harder, in order to achieve the increase in speed). -The locomotive is fitted with an ashpan sprinkler, which is available for use to reduce the risk of emission of hot cinders from this source. Conclusion: With these additions, the risk is maintained as low as reasonably practicable (ALARP). c) GMRT2173, Issue 1, December 2015, Requirements for the Size of Vehicles and Position of Equipment (formerly GMRT2149): Nature of Non-compliance (as submitted for the Derogation dated March 2006): Because of the semi-rigid driving wheelbase, assessment of swept envelopes using modern analytical techniques is considered inappropriate. Current Mitigations: - There would be practical difficulties and very high costs involved with the verification process(es) outlined in the RGS. - The locomotive is subject to the Gauging Acceptance process by the Infrastructure Manager for all routes on which it is operated. The principal dimensions and weights of the replica A1 steam locomotives are shown in Appendix 4 of this document and are those declared to Network Rail Acceptance Body (NRAB) for consideration for Route Acceptance. - The original class A1 locomotive was built to the L2 gauge, and was 13-1" (3988 mm) in height but, following early representation from [the then] RSAB, the overall height of the replica locomotive has been reduced to 13-0" (3962 mm). This has resulted in a reduction of height to the chimney, cab, boiler steam dome and safety valves. - Gauging issues similar to other steam locomotives in regular heritage operation having similar suspensions. The operation of the A4 class locomotive Bittern in 2013 at speeds up to 94 mph did not cause any issues as pertains to this standard. - All operational movements are subject to clearance by the Infrastructure Manager. - Use of locomotive restricted as a 'heritage' vehicle. Additional Mitigations for 90mph test running: - Throughout the testing, regular examinations of the locomotive will be undertaken; this includes inspection of suspension components to check for any unusual wear patterns. - All 90 mph running will be done on lines where linespeed is higher (up to 125 mph), so the locomotive will not be seeing high cant deficiencies at speed. - Reduced overall height (see above) means that 'bounce' should not be a critical mode of movement and experience of the locomotive confirms that such behaviour does not occur at speeds up to 75 mph even on poor track. - The locomotive is fitted with roller bearings throughout, hence more robust bearing arrangement for speed and less lateral 'slop' to affect dynamic performance. Conclusion: With these additions, the risk is maintained as ALARP. d) GMRT2160, Issue 4, December 2010, Environment Inside Railway Vehicles (Audibility of Detonators) Page 5 of 13

6 (previously Issue 2) GMRT2161, Issue 1, August 1995, Requirements of Driving Cabs: (These two RGS are considered together). Nature of non-compliances relevant to speed increase (as submitted for the derogation dated March 2006): - Little cognisance was taken of the vibration and noise environment in the locomotive cab when this class of locomotive was designed in the 1940s. No measurements, calculations or data exist to verify compliance. - As for other steam locomotives, forward sighting of signals below buffer level is restricted because of the bulk and location of the boiler. Similarly, the tender restricts reverse sighting. - As for other steam locomotives, windscreen wipers, washers, heaters and de-icers will not be fitted. Current Mitigations: - To check compliance with the RGS type tests would have to be undertaken on the locomotive at considerable cost. Vibration measurements were taken during test running in 2008 and it was found that for a shift of less than four hours the locomotive is below the action limit but for eight hour shifts the locomotive would be outside these limits. This is managed through shift length and also the fact that the locomotive operates for around 25 days a year. - Footplate crew are subject to specific training in the handling of a steam locomotive. - There are always at least two persons on the footplate whilst the locomotive is in motion. - Infrequency of any individual driver being rostered to work the locomotive. - At difficult locations drivers stand and lean out of the side windows to enhance their view, or may be assisted by the fireman and Traction Inspector. - The open cab environment does not generally give rise to the misting of windscreens. In the event of poor visibility, a driver is able to stand and lean out of the side window to enhance his view, or may be assisted by the fireman. - Footplate crew are subject to specific training in the cab environment and the handling of a steam locomotive with additional measures for operation above 75 mph as developed for the 2013 Bittern operations and including learning from that experience. - Use of locomotive restricted as a 'heritage' vehicle. Additional Mitigations: - For the duration of these proposed 90 mph tests there will be a minimum of 4 persons on the footplate, at least 3 of whom are competent both in handling the locomotive and in operating regulations, with particular reference to signal sighting. - A signal sighting survey has been undertaken to ensure the required minimum viewing time* for each signal on the proposed test route. (*8 seconds unless where authorised). - A cab video (of a mainline steam locomotive run) has been made and an assessment of the cab environment has been undertaken in support of the proposed 90 mph running. The aim of this is to demonstrate that the cab environment, whilst markedly different from a modern diesel/electric locomotive, is not demonstrably worse at the higher speed. Page 6 of 13

7 - DB Cargo have undertaken a thorough Hazid process and suitable mitigations are in place. Conclusion: With these additions, the risk is maintained as ALARP. e) GMRT2131, Issue 1, December 2015, Visibility and Audibility of Trains Visibility considerations (previously GMRT2483): Nature of non-compliance (as submitted for the Derogation dated March 2006): - Heritage steam locomotives are not fitted with headlights and the front of the locomotive does not display a painted yellow panel. Current Mitigations: - The locomotive will be fitted with marker lights. - A fixed headlight is mounted on the front of the locomotive when in operation unlike all other locomotives which rely on battery operated portable headlamps. These were developed for the A1 and were loaned to the owners of the A4 Bittern for use during the 2013 operations. - Of specific note, is the generally lower operating speed, and the presence of the smoke and steam emissions from the locomotive chimney, which are an aid to visibility. The locomotive is also fitted with a loud chime whistle at the front to aid audible warnings. - Use of locomotive restricted as a 'heritage' vehicle. Additional Mitigations for 90 mph Testing: - The 90 mph tests will be conducted at late evening / night time. - The electric lighting system fitted to the locomotive has been developed to achieve the intent of the RGS and the locomotive will display the correct light 'triangle' of marker lights / headlight configuration on its front end during the test runs. NOTE: The existing derogation for the yellow panel is unchanged. Conclusion: With these additions, the risk is maintained as ALARP. f) GMRT2131, Issue 1, December 2015, Visibility and Audibility of Trains Audibility considerations (formerly GMRT2484): Nature of Non-compliance (as submitted for the Derogation dated March 2006): - No measurements, calculations or data are available to verify compliance. Current Mitigations: - As for other heritage steam locomotives, the Class A1 Steam locomotive whistle is distinctive, but not Two-Tone. The whistle can be manipulated to give loud and soft tones, but this is in the skill of the driver. - Of specific note, is the generally lower operating speed, and the noise of operation of the locomotive, with its loud exhaust beats, giving a clear indication of approach, which are an aid to audibility. - Use of locomotive restricted as a 'heritage' vehicle. - Tests on the locomotive whistle will be undertaken to ensure compliance with the sound pressure Page 7 of 13

8 minimum criteria paragraph The locomotive is fitted with a 'chime' whistle as further aid to audibility in addition to the existing single pitch, high tone type referred to above. The 'chime' whistle is considered suitably distinctive* so as not to be confused with 'road transport, factory or other common warning devices', which is the intent of the RGS (ref clause ). *A 'chime' type whistle was fitted to the high-speed streamlined A4 locomotives in the 1930s to address audibility concerns and is as fitted to locomotive Bittern. No issues were raised with audibility following the mph operations with this locomotive. Conclusion: With these additions, equivalent compliance with the RGS in considered to have been demonstrated. g) GMTT0088, Issue 1, October 1993, Permissible Track Forces for Railway Vehicles: Nature of Non-compliance (as submitted for the Derogation dated March 2006): - No measurements, calculations or data are available to verify compliance. Current Mitigations: - Because of the high cost, it is not possible to undertake specific tests to establish vertical dynamic forces or to establish longitudinal and lateral forces. - Steam locomotives have relatively low un-sprung mass and Q/D ratio, when compared with Diesel locomotives fitted with axle hung traction motors, but give rise to "Hammer-blow" effects from the attempts to reduce yaw movements caused by unbalanced reciprocating masses by adding extra rotational balance masses beyond those required for perfect balance of the out of balance rotating parts. - On the A1 locomotive, hammer blow is significantly reduced on account of it being a three cylinder locomotive*, with its three crankpins set at 120 degrees to each other, similar to the other London and North Eastern Railway (LNER) locomotives. (* The 1928 Bridge Stress Committee Report measured hammer blow with three-cylinder engines as being typically 25% of that shown by two-cylinder locomotives). - Hammer blow has been further reduced on locomotive Tornado by careful examination of the specific requirements and the use of a high speed balancing machine more normally utilised for jet engines and large turbines. Problems with variable ride quality at initial service introduction in 1949 are known about and the replica A1 locomotive is fitted with the modified level of bogie side control springing and enhanced springing on the engine to tender drawbar to ensure that it does not suffer with this problem. This enhancement means that the cyclical hunting experienced on the initial 1948/49 series locomotives is not evident on Tornado throughout the speed range. - The quality of ride will continue to be monitored subjectively during these tests to ensure that it remains similar to, or better than, other steam locomotives. - Use of locomotive restricted as a 'heritage' vehicle. Additional Mitigations for 90 mph Testing: - The locomotive has already been subject to a programme of wheel balancing (supported by theoretical calculations) in order to minimise hammer-blow forces caused by the reciprocating motion. The locomotive emits the same level of hammer blow at 90 mph as similar Pacific types, such as Class A4, exhibit at 75 mph. - Some basic instrumented testing was carried out whilst at the Great Central Railway at speeds of up to 60 Page 8 of 13

9 mph to measure lateral track forces and vehicle ride characteristics, in comparison with another mainline registered steam locomotive. On Network Rail, infrastructure testing was carried out with the locomotive more fully instrumented, although by positioning the accelerometers at the far end of the locomotive, it likely produced a more pessimistic result than if the measurements were taken from within the more normal position akin to bogie pivot points. These tests mean that the locomotive is unique in having measured data for a brief distance at 90 mph and for a more sustained distance between 83 and 85 mph. The testing showed that the changes made to the locomotive's balancing and springing have given rise to excellent riding characteristics and that Tornado is producing similar forces around 90 mph that other locomotives, compliant with GORT3440 and GMRT2003, produce at or below 75 mph. This report ES is appended to this submission (the report is also in the RSSB archive) and it demonstrates that the locomotive is compliant with Appendix D of GMRT2141 for the full run as a whole and for a 20 mile section when the locomotive was running between 75 and 80 mph. For an 8 mile stretch, when the locomotive was operating above 80 mph, the locomotive also passed the same assessment; however, the momentary passing of Darlington South Junction (linespeed 90 mph in a 125 mph section) would need to be disregarded as a momentary and isolated feature. - The results of these tests were extrapolated to establish compliance with the RGS GMTT0088 requirements at 90 mph. This provides reassurance as to the behaviour of the locomotive in this important area and the overall data has been incorporated into the VAMPIRE model that has been developed for the locomotive - something that is unique. Being able to calibrate the model with real data has enabled a number of assessment runs to be taken, and is also informing the build of another new locomotive. - Wheelchex measurements have been taken from the Sessay (Northallerton) site and compared with readings from other mainline registered steam locomotives to provide data for vertical track forces and the A1 is clearly demonstrating positive performance in this area. Of note is that it produces less vertical forces from hammer-blow than Class 67 locomotives or Mkl / Mk2 coaching stock with wheel flats that would not lead to being stopped or even issued with an advisory notice. Furthermore, the owners of the locomotive have engaged specialist consultants (recognised by Network Rail) to provide a process to complement those existing which enables assessment of bridges for the higher speed running. This testing proposal utilises the same authorised sections for higher speed runs as was used in the 2013 operations to minimise work for Network Rail and to utilise known infrastructure characteristics. Attached to this document is a copy of a trace of the Wheelchex data demonstrating the information detailed above and Network Rail have indicated that they do not foresee any concerns that cannot be appropriately mitigated when considering the testing proposed under this temporary deviation. Following the 90 mph operation of the locomotive Bittern in 2013, no issues were reported as a result of track forces or hammer blow. Conclusion: With the completion of the measurements taken during the initial locomotive testing in 2008, and with the locomotive having operated successfully for nearly 90,000 miles, it can be demonstrated that the track forces exerted by the locomotive at 90 mph are no worse than other existing steam locomotives at 75 mph and are below higher speed diesel and electric traction operating regularly over these routes. * Full compliance with the RGS would not be possible as the P2 force calculations would not give a meaningful result (not appropriate for large diameter wheel). Instead, the physical testing of dynamic loads from loco has provided the equivalent demonstration. The following RGSs are listed as unaffected by the speed increase, with a rationale given for each: GMRT2045, Issue 4, March 2016, Compatibility Requirements for Braking Systems of Rail Vehicles. (relevant issues other that stopping distances). a) Rationale: Mitigations covering non-compliance with the specific requirements of Appendix F (formerly clause 7.2.5) (Brake applications to interrupt traction power) considered equally as valid. The derogation already highlights that the proportion of brake force to tractive effort on the locomotive is notably greater than with diesel or electric traction units, hence the effect of traction power remaining (briefly) applied when a sudden brake demand is activated is considered negligible in terms of overall stopping distance and can be validated on test in any case. b) GMRT2100, Issue 5, June 2012, Requirements for Railway Vehicle Structures Rationale: Inability to comply with this standard (lack of data to support crash-worthiness) is the same irrespective of speed. Page 9 of 13

10 Obviously, energy to be dissipated at 90 mph is greater than 75 mph but the existing mitigations are adjudged to be equally valid. c) GMRT2141, Issue 3, June 2009, Resistance of Railway Vehicles to Derailment and Rollover Rationale: Inability to comply with this standard (lack of data to support derailmenurollover calculations) is the same irrespective of speed. Acknowledged that lateral force increases round a curve with speed, but mitigations as stated remain the same and, at 90 mph, the locomotive will still be considerably below the linespeed of the planned test route (see comments in GMRT2173). Additionally, with the incremental nature of each run, the opportunity exists to examine the track force data (see GMTT0088) to confirm satisfactory ride prior to a subsequent run. GMRT2142, Issue 2 October 2000, Resistance of Railway Vehicles to Rollover in Gales. d) Rationale: Overall non-compliance with this standard unaffected by speed change (side forces imparted on loco unaffected by longitudinal speed). e) GMRT2162, Issue 3, June 2011, Traincrew Access to and Egress from Railway Vehicles Rationale: Inability to comply with this standard (use of simple hinged plates as a 'door) is the same irrespective of speed. f) GMRT2176, Issue 1, December 1995, Air Quality and Lighting Environment for Traincrew Inside Railway Vehicles. Rationale: Inability to comply with this standard (open cab draughty, and its air unfiltered) is the same irrespective of speed. This issue is partly addressed in any case in the comments against GMRT2160 / GMRT2161 above. GMRT2185, Issue 2, December 2001, Train Safety Systems. g) Rationale: Inability to comply with this standard (non-fitment of Tripcocks, DSD, Driver-Guard communication) is the same irrespective of speed. h) GMRT2100, Issue 5, June 2012, Requirements for Railway Vehicle Structures. Issues regarding couplings (formerly GMRT2190). Rationale: Inability to comply with this standard (unknown proof loadings of the locomotive dragboxes) is the same irrespective of speed. i) GMRT2100, Issue 5, June 2002, Requirements for Railway Vehicle Structures Issues regarding windscreens (formerly GMRT2456). Rationale: Limited relevance of this standard (Locomotive not fitted with full, forward-facing windscreen) is the same irrespective of speed. j) GMRT2453, Issue 2, September 2011, Registration, Identification and Data to be Displayed on Rail Vehicles (formerly GMRT2459). Rationale: Non-fitment of Data Panels and Lifting and Jacking Points is not an issue relating to speed of operation. k) GMRT2466, Issue 3, February 2010, Railway Wheelsets. Rationale: Inability to comply with this standard (does not cover the large diameter, spoked wheelsets used on heritage steam locomotives) is the same irrespective of speed. 7. How long would you like the deviation to last and is there anything that would affect the length of the deviation? Page 10 of 13

11 [This question may not be applicable if seeking to deviate from a requirement in a RIS] [See deviation guidance: section 2, B.4.] If applicable, please specify the dates you wish your deviation certificate to start and end. Start: 07/04/2017 End: 31/12/2017 If the deviation is time limited, state how your company / organisation plans to become compliant with the requirement. Please also indicate if this deviation is requested: - While conducting a trial. - To allow time to comply with the requirement at a future date. - For the remaining lifetime of an asset or piece of equipment, to allow it to be phased out. It is the intention that satisfactory completion of tests will lead to submission of results (presented in industry - recognised report with conclusions / recommendations) which will provide objective evidence in line with the proposed new methodology in the new heritage standards (replacement for current GORT3440 and GMRT2003) to permit higher operating speed for a new-build locomotive of this type. 8. Demonstrate that what you are proposing to do instead is reasonable: [See deviation guidance: section 2, C.6.] Demonstrate what you are proposing to do is reasonable. Explain the effects of implementing what you are proposing to do on: - The safety of the railway system. - The compatibility of the railway system now and in the future. - Costs and service performance, including reliability and availability. - If relevant, other essential requirements such as environmental protection and health. Clearly set out the risk assessment approach that was followed. Any assessment should consider both the activities of your company / organisation and those of affected parties. This explanation should be supported by any relevant documents such as: - Company / organisation procedures, processes and instructions. - Risk assessments undertaken. - Specific explanatory drawings, illustrations and diagrams. In order to test the locomotive's suitability for semi-regular operations at 90 mph a temporary deviation against the current 75 mph maximum stated in RIS-3440-TOM is required. In terms of the other RGSs listed above, the additional mitigations listed are considered to adequately address any incremental change in risk as a result of testing for 90 mph operations. It is not considered otherwise practical to comply with the requirements of the RGSs listed; in many cases, due to their wide diversity of design from modern traction units and the general scarcity of technical information now available to prove their compliance or otherwise, demonstration of compliance is not possible in any case. Steam locomotives are in a minority group, and subject to the restrictions in GMRT2000 for 'Heritage Vehicles'. 9. Demonstrate consultation with all affected parties has been carried out and their agreed support: [See deviation guidance: section 2, C.5.] [Note for further guidance on consulting with affected parties and providing evidence of support, please visit the deviations page of the RSSB website] Provide the results of your consultation with affected parties including copies of any responses to consultation. Provide a summary of any key issues together with how you have responded or intend to respond to those issues. N/A 10. What alternative options have been rejected and the rationale? Page 11 of 13

12 None. 11. What supporting documents / information are you providing? Please list any supporting documents / information you have to support your application. If you are not content for the supporting documentation to be published, please tick this box. 12. Is the application for a project requiring authorisation for placing in service? [This question may not be applicable if seeking to deviate from a requirement in a RIS] Please indicate whether the application is for a project requiring authorisation for placing in service under the Railways (Interoperability) Regulations 2011? The DfT Interoperability help note on 'Dispensations from Notified National Technical Rules' sets out how an industry process can be used by projects to obtain deviations from a national rule. The process for obtaining deviations from requirements in accordance with the RGS Code is recognised as an established industry process in this context. 13. Applicant details and status: Please provide your name, position (job title), the company / organisation you work for, your full address, contact details, and reference number (if applicable). Please make use of the additional contact details if there is more than one applicant. For seven or more applicants, please attach their contact details within the and we will ensure they are added to the certificate. Applicant details: Name: NAME Job title: Operational Standards Manager Company / Organisation: DB Cargo Ltd Address Lakeside Business Park, Carolina Way, Doncaster DN4 5PN Phone: TELEPHONE Additional contact #2: Name: Job title: Company / Organisation: Address Phone: Additional contact #4: Name: Job title: Company / Organisation: Address Phone: Additional contact #1: Name: Job title: Company / Organisation: Address Phone: Additional contact #3: Name: Job title: Company / Organisation: Address Phone: Additional contact #5: Name: Job title: Company / Organisation: Address Phone: Page 12 of 13

13 Please indicate whether you are applying as: The party who must currently comply, or may reasonably be expected to have to comply in future, with the requirement. A third party acting on behalf of, and with the support of, any party who must currently comply, or may reasonably be expected to have to comply in future, with the requirement. Please provide their details and attach evidence of their support for this application. Regardless of which party submitted the application, a deviation from a requirement shall be granted only to one or more specified parties who must currently comply, or may reasonably be expected to have to comply in future, with the requirement. Your reference number: Please provide your company / organisation reference number for this application, if applicable. N/A Applicant s signature: Date: Operational Standards Manager 17/01/2017 Use of alternative requirements in Rail Industry Standards (RIS) You do not require approval from the Lead Standards Committees to use an alternative requirement to that provided in a RIS. If you wish to adopt an alternative requirement than what is in a RIS, you would be using this form to seek observations and comments from the relevant Committee. Although a deviation certificate will be issued, it only documents the Committee s observations and comments regarding your intended approach, which will be highlighted on the certificate and other referenced documents such as relevant Committees minutes. In case of a RIS the Committee s approval and RSSB s authorisation are associated with the observation text provided by the Committee as opposed to approval and authorisation of the alternative requirements or the deviation application content. It is important to note that when deviating from requirements, ultimately assuring yourself of the applicability and suitability of any alternative requirements to address your legal and other obligations as well as any changes which you decide to make as a result of the Committee s observations, remain your responsibility. Rail Safety and Standards Board Limited will use the information you provide on this form (including any supporting documents) for the purpose of processing your deviation application. We will share the information with appropriate Standards Committees and may publish the information with the Deviation Certificate on the RSSB website. Page 13 of 13