I
                                   EPA-550/9-76-005
               BACKGROUND DOCUMENT
                        FOR
              RAILROAD NOISE EMISSION
                     STANDARDS
                   DECEMBER 1975
           U.S. Environmental Protection Agency
           Office of Noise Abatement and Control
                 Washington, D.C. 20460

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA SSO/Q-7 6-004
4. TITLE AND SUBTITLE
Background Document for Railroad Noise
Emission Standards
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Noise Abatement and Control
Environmental Protection Agency
Washington, D.C. 20460
12. SPONSORING AGENCY NAME AND ADDRESS
15. SUPPLEMENTARY NOTES
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
December 1975
6. PERFORMING ORGANIZATION
EPA. ONAC
8. PERFORMING ORGANIZATION
CODE
REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Fi nal
14. SPONSORING AGENCY CODE

16. ABSTRACT
This document contains the technical, economic, health and
welfare analyses and other pertinent data and information utilized
by the Environmental Protection Agency in the development of the
final Interstate Rail Carrier Noise Emission Regulation.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.lDENTIFI
Economic cost, effects; Federal
regulations; locomotives; noise
emission; population exposure; rail-
cars; standards
18. DISTRIBUTION STATEMENT 19. SECURI
Release unlimited 20. SECURI
EPS/OPEN ENDED TERMS C. COSATI Field/Group

TY CLASS (ThisReport) 21. NO. OF PAGES
618
TY CLASS (This page) 22. PRICE

EPA Form 2220-1 (9-73)

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                        EPA 550/9-76-005
 BACKGROUND DOCUMENT
           FOR
RAILROAD NOISE EMISSIONS
        STANDARDS
       DECEMBER 1975
U.S. Environmental Protection Agency
Office of Notae Abatement and Control
     Washington, D.C. 20460
  TINS
         It dow not oonMliuto • ttsnoMv,

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                                     PREFACE
     On December 31,1975, the Environmental Protection Agency issued a regulation
governing noise emissions from interstate rail carriers. That regulation was issued under
Section 17 of the Noise Control Act of 1972.

     This document presents and discusses the background data used by the Agency in
setting the standards contained in the regulation. Presented here is a comprehensive
exposition on the most up-to-date available information on the environmental,
technological, and economic aspects of railroad noise.

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                           TABLE OF CONTENTS
Section                                                              Page

  1       PROLOGUE                                                1-1
             STATUTORY BASIS FOR ACTION                           1-1
             INTERNAL EPA PROCEDURE                              1-3
             PREEMPTION                                           1-4
                 Noise Emission Standards on Railroad Equipment              1-4
                 Noise Emission Standards on Railroad Facilities               1-5
                 Design or Equipment Standards                           1-5
                 Use, Operation, or Movement Controls                      1-6
                 Receiving Land Use Standards                            1-6

  2      SUMMARY OF WHAT THE REGULATION REQUIRES               2-1
             APPLICATION OF BEST AVAILABLE TECHNOLOGY TAKING
               INTO ACCOUNT THE COST OF COMPLIANCE                2-1
             LEVELS OF TRAIN NOISE CONTROL                        2-2
                 Locomotive Noise—Vehicle at Rest                        2-2
                 Locomotive Noise—Vehicle in Motion                      2-3
                 Railcar Noise—Vehicles in Motion on Line                   2-3
                 Railcar Noise-Vehicles in Motion in Yards                   2-3
             REVISION OF THE PROPOSED REGULATION PRIOR TO
               PROMULGATION                                      2-4
             NOISE EMISSION STANDARDS INTERSTATE RAIL CARRIER
               NOISE REGULATION                                   2-6

  3      DATA BASE FOR THE REGULATION                            3-1

  4      THE RAILROAD  INDUSTRY                                   4-1
             ECONOMIC STATUS                                      4-1
             EMPLOYMENT                                          4-3
             HEALTH AND GROWTH OF THE INDUSTRY                  4-5
                 Health of the Industry                                  4-5
                 Growth  of the Industry                                4'7

  5       RAILROAD NOISE SOURCES                                   5-1
             OVERVIEW  OF THE PROBLEM                              5-1
             CONSIDERATION OF RAILROAD NOISE SOURCES FOR
               FEDERAL REGULATIONS                              .  5-2
                 Office Buildings                                       5-2
                 Repair and Maintenance Shops                            5-3
                                   iii

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                         TABLE OF CONTENTS (Cont'd)


Section

  5              Terminals, Marshalling Yards, Humping Yards, and
                   Specifically Railroad Retarders                              5-3
                 Horns, Whistles, Bells, and Other Warning Devices                5-5
                 Special Purpose Equipment                                  5-6
                 Track and Right-of-Way Design                               5-7
                 Trains                                                    5-9
             CHARACTER OF RAILROAD NOISE SOURCES AND
               ABATEMENT TECHNOLOGY                                 5-9
                 Locomotives                                               5-9
                 Diesel-Electric Locomotives                                  5-9
                 Locomotive at Rest                                         5-11
                 Locomotive in Motion                                      5-11
                 Locomotive Noise Abatement                                 5-2 1
                      Abatement By Equipment Modifications                   5-21
                      Noise Abatement By Operational Procedures                5-26
                 Electric/Gas Turbine Locomotives                            5-27
                 Wheel/Rail Noise                                           5-27
                 Wheel/Rail Noise Abatement                                 5-29
                 Retarder Noise                                            5-33
                 Retarder Noise Abatement                                  5-34
                      Benefits                                              5-34
                      Costs                                                5-35
                 Car-Car Impact Noise                                       5.35
                 Warning Devices                                            5-36
                 Public Address Systems                                      5.39
                 Maintenance and Repair Shops                                5.39
                 Refrigerator Cars                                           5.39
                 Auxiliary Diesel Engines                                     5-39

    6     GENERAL PROCEDURE TO MEASURE RAILROAD NOISE             6-1
              INTRODUCTION                                              6-1
              SUBPARTC-MEASUREMENT CRITERIA                         6-2
                  20 1 .20 Applicability and Purpose                             6-2
                  20 1 .2 1 Quantities Measured                                  6-2
                  20 1.22 Measurement Instrumentation                          6-2
                  201.23 Acoustical Environment, Weather Conditions and
                    Background Noise                                        5.3
                  201 .24 Procedures for the Measurement of Locomotive and
                    Rail Car Noise                                            .
                                       iv

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                          TABLE OF CONTENTS (Cont'd)
Section                                                                    Page

  7       ECONOMIC EFFECTS OF A RETROFIT PROGRAM                    7-1
              INITIAL ECONOMIC ANALYSIS                                7-2
                  The Impact on the Railroad Industry                          7-2
                       General Impact                                       7-2
                       The Impact on Marginal Railroads                        7-15
                       The Impact on Bankrupt Railroads                       7-18
                  The Impact on Users of Rail Transportation                    7-18
                       The Effect on Railway Freight Rates                      7-18
                       The Effect on Quality of Service                         7-24
                  Summary and Conclusions Concerning Initial Economic Analysis   7-25
                       Impact on the Railroad Industry                         7-25
                  Impact on Users of Rail Services                              7-26
              SUBSEQUENT ECONOMIC COST AND IMPACT ANALYSES         7-26
                  The Cost of Retrofitting Mufflers on Locomotives               7-26
                       Initial Direct Costs                                    7-27
                       Initial Indirect Costs                                   7-33
                       Continuing Costs                                      7-37
                       Summary of Locomotive Retrofit Costs                   7-38
                  Economic Impact of Muffler Retrofit                         7-38
                       Labor Supply                                         7-40
                       Impact on Railroad Revenue and Profits                   7-44
                       Financial Impact                                      7-45
                       Freight Diversion as a Result of Differential Impacts
                         of Fuel Costs                                      7-47
                       Impacts on Consumers                                 7-52

  8       ENVIRONMENTAL EFFECTS OF THE FINAL REGULATION            8-1
              INITIAL ANALYSIS OF IMPACT RELATED TO ACOUSTICAL
                ENVIRONMENT                                           8-1
                  Case Studies of Railroad Lines                                8-1
                  Analysis of Train Noise Impact                               8-1
              REFINEMENTS ON INITIAL ANALYSIS OF IMPACT
                RELATED TO ACOUSTICAL ENVIRONMENT                   8-11
                  Miles of Railroad Track                                    8-11
                  Population Densities                                       8-12
                  Traffic Volume in Urban Areas                               8-12
                  People Exposed                                           8-15

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                        TABLE OF CONTENTS (Cont'd)
   Section
 Appendix A


 Appendix B


 Appendix C


 Appendix D

 Appendix E


 Appendix F



Appendix G

Appendix H
                                                      Page

        Impact Related to Land                              g. \ 9
        Impact Related to Water                              8-19
        Impact Related to Air                               8-19
    DAY NIGHT EQUIVALENT NOISE LEVEL (Ldn)               8-2 1
    EXCESS ATTENUATION OF RAILROAD NOISE               8-2 1

 ECONOMIC EFFECTS OF THE FINAL REGULATION               9- 1
    EQUIVALENT ANNUAL INCREASED LOCOMOTIVE
      MANUFACTURING COSTS ATTRIBUTABLE TO
      MUFFLER INTRODUCTION                            9-1
    EQUIVALENT ANNUAL INCREASED FUEL COSTS
      ATTRIBUTABLE TO MUFFLER INTRODUCTION ON
      NEWLY MANUFACTURED LOCOMOTIVES (OVER AN
      ESTIMATED 25-YEAR FLEET REPLACEMENT PERIOD)        9-2
    MUFFLER REPLACEMENT COSTS                         9-2
    SUMMATION OF THE MAJOR COSTS INCURRED THROUGH
      THE ADDITION OF MUFFLERS TO NEWLY
      MANUFACTURED LOCOMOTIVES                       9-3

 MAJOR TYPES OF DIESEL-ELECTRIC LOCOMOTIVES IN
  CURRENT U.S. SERVICE (1 JANUARY 1973)                  A-l

 REVIEW OF THE AUDIBLE TRAIN-MOUNTED WARNING DEVICES
  AT PROTECTED RAILROAD HIGHWAY  CROSSINGS             B-l

 OPERATING RAILROAD RETARDER YARDS IN THE
  UNITED STATES                                        C-l

 SUMMARY OF YARD NOISE IMPACT STUDY
GENERAL MOTORS CORPORATION LOCOMOTIVE EXHAUST
  MUFFLER RETROFIT COST STUDY REPORTS                  E-l

GENERAL MOTORS CORPORATION ADDITIONAL COMMENTS ON
  THE ENVIRONMENTAL PROTECTION AGENCY PROPOSED
  RAILROAD NOISE EMISSION STANDARDS                     F-l

MUFFLER DESIGN FOR LOCOMOTIVES                        G- 1

DETAILED MUFFLER DESIGNS AND PERFORMANCE ESTIMATES     H- 1
                                  VI

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                       TABLE OF CONTENTS (Cont'd)



  Section

Appendix I   SPACE AVAILABILITY FOR MUFFLERS INSIDE LOCOMOTIVES          A-I

Appendix J   LOCOMOTIVE NOISE MEASUREMENTS TAKEN IN CONJUNCTION
            WITH HARCO MANUFACTURING COMPANY AND
            ADDITIONAL MEASUREMENTS                                A-J

Appendix K   EXHAUST NOISE MEASUREMENTS FOR THE GP-9 LOCOMOTIVE         A-K

Appendix L   TRIP TO MONTREAL LOCOMOTIVE WORKS AND
            MEASUREMENTS OF M-420 LOCOMOTIVE                        A-L

Appendix M   THE USE OF MUFFLERS ON LARGE DIESEL ENGINES IN
            NONRAILROAD APPLICATIONS: RESULTS OF A BBN SURVEY         A-M

Appendix N   AMTRAK EXPERIENCE WITH MUFFLED LOCOMOTIVES               A-N

Appendix O   REFRIGERATOR CARS                                        A-O

Appendix P   APPLICABILITY OF TRACK AND SAFETY STANDARDS TO NOISE         A-P

Appendix Q   RAIL CAR NOISE LEVEL DATA                                  A-Q

Appendix R   ANALYSIS OF PUBLIC COMMENTS ON THE ENVIRONMENTAL
            PROTECTION AGENCY PROPOSED RAILROAD NOISE
            EMISSION STANDARDS                                      A-R
                                 vu

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                              LIST OF ILLUSTRATIONS
Figure                                                                            Page

 5-1        Effect of Fan Noise on the A-Weighted Spectrum of EMD GP40-2
             Locomotive Noise at 55 ft (Engine Access Doors Open)                    5-16
 5-2        Diesel-Electric Locomotive Passbys                                       5-17
 5-3        Peak Locomotive Noise Level vs. Speed                                   5-19
 5-4        Relationship Between Maximum Noise Level and Number of Coupled
             Locomotives                                                         5-20
 5-5        Wheel/Rail Noise Measured on Level Ground and on a 1% Grade              5-30
 5-6        Measured Wheel/Rail Noise                                              5-30
 5-7        Average, and Minimum Rail-Wheel Sound Level vs. Speed for
             Typical Railroad Cars on Welded and Bolted Rail                         5-31
 5-8       Retarder Squeal Amplitude Distribution                                   5-33
 5-9       Car-Car Impact Noise Time Histories                                      5-37
 6-1        Test Site Clearance Requirement for Locomotive Stationary,
             Locomotive Pass-by, and Rail Car Pass-by. Tests                          6-4
 7-1        Cost of Retrofit Program -as a Function of Compliance Period                7-14
 7-2        Distribution of Railroads by  Retrofit Cost as a Percent of Net Operating
             Revenue for 2- and 5-year Compliance Periods                           7-16
 7-3        Patterns in Maintenance of Railroad Equipment and Stores                   7-41
 7-4       Effect of Fuel Prices on Distribution of Freight                            7-51
 8-1        L(jn vs Distance From the Track for the Dorchester Branch of Penn Central    8-5
 8-2       L,jn vs Distance From Track for National Average Train Traffic              8-6
 8-3       Distance From Track at Which Various L(jn Occurs Around the
             Dorchester Branch of the Penn Central                                  8-7
 8-4       Thousands of People Exposed to Various L
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                                   LIST OF TABLES
Table                                                                             Page

 4-1       National Income Originating in the Transportation and Rail Sectors           4-2
 4-2       Intercity Freight                                                        4-2
 4-3       Percent of National Income Originating in the Transportation Sector
              and the Rail Sector as a Percent of Transportation                        4-3
 4-4       Employment in the Rail Industry Relative to the National Economy          4-4
 4-5       Index of Output per Man Hour and Wages                                  4-4
 4-6       Percent of Gross Revenue Carried Through to Net Operating Income
              Before Federal Income Taxes                                           4-6

 5-1       Effect of Throttle Position on Engine Power and Noise Levels                5-10
 5-2       Stationary Noise Emission Data for General Motors and
              General Electric Locomotives                                           5-12
 5-3       Source Contributions to Locomotive Noise Levels                           5-16
 5-4       Locomotive Passby Noise Emission Levels Measured at 100 Feet              5-18
 5-5       Locomotive Noise Levels Expected from Exhaust Muffling, Throttle 8         5-23
 5-6       Switcher Locomotives in Service                                          5-25
 5-7       Noise Levels from Electric and Gas-turbine Trains                           5-28

 7-1       Muffler Costs per Locomotive                                            7-2
 7-2       Distribution of Locomotives by Manufacturer, Type, and Region             7-4
 7-3       Total Direct Cost of Retrofit Program                                     7-4
 7-4       Annual Direct Cost of 2- and 5-Year Retrofit Programs                      7-6
 7-5       Average Maintenance Interval by District                                   7-7
 7-6       Days Lost Due to Retrofit                                                7-7
 7-7       Equation for Total Lost Time per District                                  7-8
 7-8       Lost Locomotive Days by Region and Compliance Period                    7-9
 7-9       Regional Annual Revenue per Locomotive Day                             7-10
 7-10      Estimated Lost Revenue Due to Retrofit                                   7-10
 7-11      Annual Net Cost of Retrofit                                             7-12
 7-12      Total Net Cost of Retrofit Program                                       7-13
 7-13      Annual Retrofit Cost as a Percentage of 1971 Total Operating Revenue        7-13
 7-14      Annual Retrofit Cost as a Percentage of 1971 Net Operating Revenue         7-15
 7-15      Number of Railroads in Unfavorable Financial Position Relative to
              Eight Indicators                                                      7-19
 7-16      Number of Railroads Designated as Being in Financial Difficulty by
              One or More Financial Indicators                                       7-20
 7-17      Net Cost of Muffler Retrofit Program for the Seven Bankrupt
              Class I Railroads                                                     7-20
                                          1x

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                               LIST OF TABLES (Cont'd)
Table                                                                            Page

 7-18      Rate Increase That Would Enable Railroads to Recover Retrofit Expenses     7-22
 7-19      Annual Locomotive Days Taken Up by Retrofit Program                    7-24
 7-20      Hardware Modifications and Material Costs for Turbocharged Road
              Locomotives                                                        7-28
 7-21      Average 1973 Hourly Wage Rate for Skilled and Other Workers              7-29
 7-22      1973 Weighted Average Hourly Labor Cost Deviation                       7-30
 7-23      Labor Man-Hours and Total Labor Cost for Muffler Retrofit Program         7-31
 7-24      Initial Direct Costs of Retrofitting Exhaust Mufflers to Locomotives          7-33
 7-25      Days Lost Due to Retrofit                                               7-35
 7-26      Number of Locomotives by Type                                         7-37
 7-27      Summary of Initial Locomotive Retrofit Costs for a  2-Year Program          7-39
 7-28      Summary of Annual Costs of Locomotive Retrofit for a 2-Year Program      7-39
 7-29      Levels of Employment and Average Hours Worked in 1970 and 1972
              Compared to 1973                                                   7-43
 7-30      Man-Hours Required for Locomotive Retrofit                              7-44
 7-31      Ratio 1-Current Assets/Total Assets                                      7-47
 7-32      Ratio 2-Operating Expenses/Operating Revenue                           7-48
 7-33      Ratio 3-Total Liabilities Less Stockholder Equity/Total Assets              7-48
 7-34      Ratio 4-Income After Fixed Charges/Total Assets                          7-49
 7-35      Ratio 5-Retained Earings/Total Assets                                   7-49
 7-36      Ratio 6-Net Income/Total Assets                                        7-50
 7-37      Ratio 7-Net Income/Operating Revenue                                  7-50
 7-38      Effect of a 1-Percent Rail Freight Rate Increase on Commodity Prices         7-53
 7-39      Freight Rate Necessary to Offset Increased Costs Due to Retrofit             7-54

 8-1        Land Use Near Railroad Lines                                            8-2
 8-2        Train Traffic and Community Characteristics Near Typical Railroad Lines     8-3
 8-3        Distribution of Urban Grade Crossings by Volume of Train Traffic            8-13
 8-4        Computation of National Average Direct-Powered Train Traffic              8-13
 8-5        Average Train Characteristics                                             8-14
 8-6        Present Distribution of People by L<}n Interval                             8-18
 8-7        Present and Projected Populations Exposed to Various Levels of L(jn          8-18
 8-8        Distribution of People by L(jn Interval  Assuming Muffler Retrofit            8-19
 8-9        Equivalent Noise Impact for Present and Quieted Locomotive Populations     8-20

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                                        Section 1

                                       PROLOGUE
STATUTORY BASIS FOR ACTION
     In Section 2 of the Noise Control Act, Congress expressed its judgment "that while primary
responsibility for control of noise rests with state and local governments, Federal action is essen-
tial to deal with major noise sources in commerce, control of which require national uniformity
of treatment."  Congress also declared within Section 2 of the Act "that it is the policy of the
United States to promote an environment for all Americans free from noise that jeopardizes
their health or welfare."
     As a part of this essential Federal action, Section 17 requires the Administrator to publish
proposed noise emission regulations that "shall include noise emission standards, setting such limits
on noise  emission resulting from operation of the equipment and facilities of surface carriers
engaged in interstate commerce by railroad which reflect the degree of noise reduction achievable
through the application of the best available technology, taking into account the cost of compliance.'
After the effective date of such a regulation, no state or political subdivision thereof may adopt or
enforce any standard applicable to noise emissions resulting from the operation of the same equip-
ment or facility of such carrier unless such standard is identical to a standard applicable to noise
emissions resulting from such operations as prescribed by these regulations.  The Administrator,
after consultation with the Secretary of Transportation may, however, determine that the state or
local standard, control, license, regulation, or restriction is necessitated  by special local conditions
and is not in conflict with regulations promulgated under Section 17. Procedures for state and
local governments to apply for an exemption under Section 17(c) (2) of the Act will be published
by this Agency shortly after promulgation of this regulation.
     These sections of the Noise Control Act reflect the desire of Congress to protect both the
environment and commerce through the establishment of uniform national noise emission regula-
tions for  the operation of interstate railroad equipment and facilities. Such equipment and facilities
require national uniformity of treatment to facilitate interstate commerce because certain types of
interstate railroad equipment and facilities operations would be unduly burdened by conflicting
state and local noise controls. Preemption under Section 17 occurs only for state or local noise
regulations on equipment and facilities on which Federal regulations are in effect.  When national
uniformity of treatment is not  needed, Congress recognized the primary responsibility of state and
local governments to protect the  environment from noise. State  and local regulations on noise
emissions resulting from the operation of equipment and facilities of surface carriers engaged in
interstate commerce by railroad that are not preempted by applicable Federal regulations under
Section 17 are subject to the Commerce Clause of the U.S. Constitution.  Under that Clause, any
state or local regulations that constitute an undue burden on interstate  commerce cannot stand.
                                            1-1

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     The Act directs that Federal regulations on interstate railroad equipment and facilities under
 Section 17 are to include noise emission standards setting limits on noise emissions resulting from
 their operation that reflect the degree of noise reduction achievable through the application of the
 best available technology, taking into account the cost of compliance. Based upon the strict
 language of the Noise Control Act, its legislative history, and other relevent data, these require-
 ments are further clarified:

     •   "Best available technology"is that noise abatement technology available for application to
          to  equipment and facilities of surface carriers engaged in interstate commerce by railroad
          that produces meaningful reduction in the noise produced by such equipment and facili-
          ties.  "Available technology" is further defined to include:
          •   Technology that has been demonstrated and  is currently known to be feasible.
          •   Technology for which there will be a production capacity to produce the estimated
              number of parts required in reasonable time to allow for distribution and installation
              prior to the effective date of the regulation.
          •   Technology that is compatible with all safety regulations and takes into account
              operational  considerations including maintenance and other pollution control
              equipment.

     •   "Cost of compliance" is the cost of identifying what action must be taken to meet the
          specified noise emission level, the cost of taking that action, and any additional cost of
          operation and maintenance caused by that action.

     In preparing the final regulation the Administrator has given full consideration to cost of com-
 pliance and available technology and has consulted with the  Secretary of Transportation to assure
 appropriate consideration for safety and for availability of technology.
     Further, recognizing that the Noise Control Act was enacted to protect the public from adverse
 health and welfare effects due to noise, EPA has also considered the impact of railroad noise taking
 into account  the levels of environmental noise requisite to protect the public health and welfare with
 an adequate margin of safety, as published by EPA in March 1974 in accordance with Section 5(a)
 (2) of the Act.
     Accordingly, EPA has  developed and is now implementing an interstate rail carrier noise control
 strategy based on Section 17 of the Act that should prove to be effective in reducing environmental
 noise from railroads in many areas to the levels identified as  protective of public health and welfare.
 The strategy calls for the reduction of the noise from railroad locomotives and rail cars to the lowest
 noise levels consistent with  the noise abatement technology available, taking into account the cost
 of compliance.
     Compliance regulations are to be developed and promulgated under separate rule making by
the Department of Transportation, as called for in Section 17(b) of the Act.
    The legal basis supporting promulgation of the regulation was set forth in substantial detail in
the notice of proposed rule making published in the Federal  Register on July 3,1974 (39 FR 24580).
In the same publication, notice was given of the availability of the "Background Document and
                                            1-2

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Environmental Explanation for the Proposed Interstate Rail Carrier Noise Emission Regulations,"
which provided the factual basis for the standards proposed, applicable measurement methodology,
costs of compliance with the proposed standards, and the public health and welfare benefits
expected. Public comment was solicited, with the comment period extending from July 3, 1974,
to August 17,1974.
    To ensure that all issues involved in the proposed regulation and Background Document were
fully addressed prior to promulgation of the final regulation, a special consultation meeting was
announced in the Federal Register of August 6,1974 (39 FR28316) and was consequently held
on August 14,1974, in Des Plaines, Illinois. The principal issues reviewed at this meeting related
to the adequacy of the available technology to meet requirements in the proposed standards and
the impact of Federal preemption on state and local noise regulations. The transcript of the meet-
ing has been included as a portion of the total body of public comment received.
    Public comments received during the public comment period are maintained at the EPA Head-
quarters, 401  M Street, S.W., Washington, D.C. 20460 and are available for public inspection during
normal working hours.
    In the future, the Agency may propose further regulations concerning railroad noise, as the
need for the feasibility of such regulations are demonstrated. Such regulations may be proposed
as amendments to that part of the Code of Federal Regulations established by the regulatory action
currently taken by the agency under Section  17 or may be proposed pursuant to EPA authority to
set noise emission standards for new products specified in Section 6 of the Act.

INTERNAL EPA PROCEDURE
    The rulemaking process of EPA began with the publication of an Advanced Notice of Proposed
Rulemaking in the Federal Register. At that time, EPA informed the public of the requirement that
regulations be developed and requested that pertinent information be submitted to the Agency for
consideration. A task force composed of Federal, state, and local government officials, and consul-
tants was then formed to develop recommendations for these regulations.  The Office of Noise
Abatement and Control considered these recommendations together with the recommendations
of the EPA Working Group, composed of representatives from various offices of the Agency, in
formulating the proposed regulations. After the Deputy Assistant Administrator for Noise Control
Programs approved the proposed regulations, they were submitted  to the Assistant Administrator
for Air and Waste  Management Programs, who has responsibility for the Noise Control Program as
well as several other programs. Following the Assistant Administrator's approval, the proposed
regulations were submitted to the EPA Steering Committee, which is composed of the Deputy
Assistant Administrators of EPA.
    Upon the Steering Committee's approval, the proposed regulations were forwarded to the
Office of Management and Budget, and other interested Federal agencies, for review. After those
comments were analyzed and satisfactorily addressed, the proposed regulations were submitted
through the Assistant Administrator for Air and Waste Management Programs to the EPA Admini-
strator for final approval and ultimate publication in the Federal Register.  The resulting public
comments were analyzed, and a recommendation for the final regulation was prepared by the
Deputy Assistant Administrator for Noise Control Programs. The final regulations were then
                                          1-3

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 submitted to the Assistant Administrator for Air and Waste Management Programs and the review
 process followed in the .case of the proposed regulations was initiated again.  This process culminated
 in the promulgation of the regulation.

 PREEMPTION
      Though the Noise Control Act speaks of preemption in unequivocal terms, the various sources
 of railroad noise are subject to such complex interrelationships that it is impossible to identify all
 regulations a priori as either preempted or not preempted. It is necessary to examine the regula-
 tion in question, the sources it purports to control, the activities to which it relates, and the reason-
 ableness of the various alternative means of complying. As to those regulations subject to preemp-
 tion, the preemptive effect may be waived under Section  17(c) (2) if the Administrator determines
 that the regulation is necessitated by special local conditions and is not in conflict with EPA regu-
 lations.  It is anticipated that all such determinations as to not only special local conditions but
 also the preempt status of state and local regulations impacting railroads would be handled by EPA.
 The Agency is currently preparing guidelines that will specify procedures to be followed  by state
 and local governments when questions of the preemptive effect of Federal rail carrier noise regula-
 tions are at issue.
      In view of the many comments received in response to the proposed regulation, the following
 discussion of preemption is intended to clarify the Agency interpretation of the preemptive effect
 of the regulation.
      State and local governments can deal with railroad noise problems in several different ways.
 The first, the method  adopted by EPA in the regulation, is to set emission standards on railroad
. equipment to reduce the noise produced at the source. Second, they can set noise emission stan-
 dards on facilities where rail operations occur. A variation of this approach is the use of property
 line standards, for which measurements are taken at the railroad property boundaries. Third, they
 may impose affirmative requirements on railroad equipment or facilities ("design" or "equipment"
 standards), such as the installation of mufflers on locomotives, the elimination of wheel flats on
 rail cars, or the construction of noise barriers along rights of way.  A fourth possibility is to regu-
 late, license, control or restrict the use, operation or movement of any equipment or facility, for
 example prohibiting idling of locomotives on sidings within communities or prohibiting railroad
 yard operations between the hours of 10:00 p.m. and  6:00 a.m. Fifth, a state or community may
 set receiving land-use standards for property impacted by railroad noise, for example requiring that
 noise levels at the property line of residential property not exceed 55 dBA Ldn-  Each of these
 methods presents special problems that affect the determination of the preemptive relationship of
 the EPA railroad noise regulation.

 Noise Emission Standards on  Railroad Equipment
       The Noise Control  Act provides that after the effective date of the standards promulgated
 for locomotives and rafl cars,  no state or local subdivision may adopt or enforce any noise emission
 standard on locomotives or rail cars unless it is identical to the Federal standard. They may adopt
 and enforce noise emission standards on other pieces of equipment not covered by EPA regulations,
 such as retarders and railroad construction equipment. They may also adopt standards for locomo-
 tives and rail cars if such standards are identical to the EPA standards.

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     Determining the preemptive effect of a noise emission standard is, however, complicated by
the fact that a standard for total noise emissions from the operation of a piece of equipment may
not differentiate between the elements contributing to the noise. When this is the case, the Admini-
strator believes that when any given element of noise is either (1) generated by a source that is an
integral part of the federally regulated equipment or (2) is a component of the total noise generated
by the federally regulated equipment, the regulation of that element by state and local governments
is subject to preemption. Specifically, these elements include the noise from refrigerator units on
refrigerator cars, auxiliary power units on locomotives, and noise caused  by the condition of track.
The noise caused by retarders, however, is a separate source of noise that will not be present during
compliance measurement for the rail car standard and, as such, is not subject to preemption.

Noise Emission Standards on Railroad Facilities
     State and local governments may enact noise emission standards for facilities that EPA has
not regulated. However, in the judgment of EPA, the preemptive purpose of Section 17 of the
Noise Control Act requires that such regulations not be permitted to do indirectly what is specifi-
cally preempted.  That is, state and local governments may not control the noise emissions of
locomotives and rail cars by setting noise emission limits on yards where the noise limit is, in
effect, a limit on locomotive and rail car noise.  Noise emission standards may be adopted and
enforced on facilities where rail cars and locmotives do not  operate. Where federally regulated
equipment is a noise contributor in a facility on which a state or local government proposes to set
a noise emission standard, such as a marshalling yard, such a regulation may or may  not be
preempted.
     If compliance could reasonably be achieved by action that did not require modification of or
controlling the use of the operation of locomotives and rail cars, then it would be permisssible. If
the only way compliance could reasonably be achieved were to take actions preempted by Federal
regulations, then such a standard is preempted.  Questions such as the availability and  reasonable-
ness of alternative means of compliance will be  dealt with by EPA under procedures now being
developed to guide states and localities in dealing with railroad noise in light of Federal preemption.

Design or Equipment Standards
     The Noise Control Act does not deal explicitly with regulations that require the installation
of noise abatement devices or the application of specified maintenance or repair procedures. EPA
believes that this is another area in which the preemptive purpose of Section 17 requires that the
effect of state or local regulations on federally regulated equipment or facilities be analyzed. The
intended result of Section 17(c) is that, except in cases in which EPA has made a special determina-
tion, state noise regulations on locomotives or rail cars will not require that interstate rail carriers
modify these federally regulated pieces of equipment. Accordingly, EPA believes that design or
equipment standards on federally regulated equipment (locomotive and rail cars) are preempted.
Design or equipment standards on other pieces of equipment, such as retarders or cribbing  mach-
ines, are not preempted. Similarly, design standards on facilities not federally regulated are not
preempted, even though locmotives and rail cars may operate there, because they do not require
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the modification of locomotives or rail cars. An example of this type of regulation would be a local
ordinance requiring that noise barriers be installed along the rights of way running through that
community.

Use, Operation, or Movement Controls
     A reduction in community noise impact can be achieved if the manner, time, or frequency of
use of a noise source is controlled. Clearly, such controls may be adopted and enforced with respect
to equipment that EPA has not regulated. However, with respect to federally regulated equipment
(locomotives and rail cars), such controls may not be imposed unless the Administrator has deter-
mined that such state or local regulation is necessitated by special local conditions and that it is not
in conflict with EPA regulations. A use restriction on railroad facilities may be subject to such
determination also if, in order to comply, the railroad must control the use, operation, or movement
of federally regulated equipment within that facility. The determinations called for will be made by
EPA in accordance with procedures now being developed.

Receiving Land Use Standards
     Receiving land use standards are to be distinguished from property line standards on the basis
that property line standards focus on the identity of the noise source, such as railroad yards or rights
of way, whereas receiving land use standards focus on the identity of the property receiving the
sound, such as schools, hospitals or residential property.  Obviously, a community is not preempted
from enacting such standards simply because it has a railroad within its jurisdiction. However, it is
possible that a standard that  says, for example, that no  school may be exposed to exterior noise
levels in excess of 55 dBA may require modification of locomotives or rail cars in a community in
which schools are close to the right of way of a railroad. Whether, or to what extent, such regula-
tions are preempted, will be determined by EPA in accordance with procedures being developed.
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                                            Section!

                      SUMMARY OF WHAT THE REGULATION REQUIRES
APPLICATION OF BEST AVAILABLE TECHNOLOGY TAKING INTO ACCOUNT THE COST OF
COMPLIANCE
     Section 17 of the Noise Control Act requires that the regulation ...  "reflect the degree of noise
reduction achievable through the application of the best available technology, taking into account the
cost of compliance."  For this purpose, best available technology is defined as that noise abatement
technology available for application to railroads that produces meaningful reduction in the noise
produced by railroads. Available is further defined to include:

     •   Technology that has been demonstrated and that is currently known to be feasible.

     •   Technology for which there will be a production capacity to produce the estimated number
         of parts required in reasonable time to allow for distribution and installation prior to the
         effective date of the regulation.

     •   Technology that is compatible with all safety regulations and that takes into account opera-
         tional consideration, including maintenance, and other pollution control equipment.

     The cost of compliance, as used in the regulation, means the cost of identifying what action must
be taken to meet the  specified noise emission levels, the cost of taking that action, and any additional
cost of operations and maintenance caused by that action. The cost for future replacement parts was
also considered.
     As discussed in Section 5 of this report, the only source of railroad noise proposed to be regulated
by the Federal government at the present time is trains.  Therefore, the following pages will discuss
the noise abatement technology for trains, in consonance with  the statutory requirements and inter-
pretation just presented.
     Train noise is composed of locomotive noise and car noise. The latter is primarily the result of
wheel/rail interaction and wheel/retarder interaction. The locomotive noise is composed of noise from
the engine exhaust, casing, cooling fans, and wheel/rail interaction. The technology for treating casing,
fan, and wheel/rail noise is in the early development and research stages and thus not available for
application at this time.  However, the technology for exhaust  silencing has been found to be available.
Further, the locomotive noise is dominated by the engine exhaust noise and, therefore, the application
of exhaust muffler technology is the most effective initial step to require for locomotive noise abate-
ment. The consequences of establishing a standard that would require modification of engine casing,
cooling fans, and wheel/rail interaction have not been assessed  in detail. It is clear, however, that
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 without first reducing exhaust noise, treatment of these components would result in little or no per-
 ceptible noise reduction.

 LEVELS OF TRAIN NOISE CONTROL
     In this discussion, noise levels that can be reasonably attained with appropriate maintenance of
 existing equipment and by the application of the best available technology are discussed for locomotives
 both at rest and in motion and for railcars in motion.

 Locomotive Noise—Vehicle at Rest
     As discussed in  Section 5, locomotive noise is dominated by the exhaust of diesel engines, which
 operate at eight possible speed and power output levels. One way to attain environmental noise control
 would be to limit the noise at all of these throttle settings; however, this could lead to combersome
 enforcement practices.  For ease of enforcement, permissible noise could be specified at the throttle
 setting with the most noise-throttle 8. However, this approach may lead muffler manufacturers to
 design mufflers that are tuned to the engine speed corresponding to that throttle setting.  Such mufflers
 could be effective at  the design setting and ineffective at other settings. Obviously, this would defeat
 the purpose of a locomotive  regulation.
     A compromise solution is to control locomotive noise at two conditions: idle and full power.
 Idle and full power apply to  frequently used throttle settings. Specifying  two throttle settings will
 probably preclude the design of-specially tuned mufflers.  Rather, it is  anticipated that mufflers that
 will be uniformly effective at all throttle settings will result.
     Although it is unrealistic to assume that mufflers can be designed, fabricated, and installed on all
 new locomotives as soon as a regulation is promulgated, it is  not unreasonable to hold noise at the
 level of existing, well-maintained equipment. Data, for locomotives at throttle setting 8 indicate that
 almost no locomotives exceed 93 dBA at 100 ft. Likewise, data indicated that locomotives at idle
 can be expected not to emit more than 73 dBA at 100 ft.  Accordingly, the following levels have been
 identified as indicative of present noise emissions:

     •   Idle                  73
     •   Overall Maximum      93

     Section 5 indicates that mufflers capable of reducing exhaust noise by 10 dBA are feasible.
 Depending upon the relative  contribution of the exhaust noise to the dominant sources of locomotive
 noise, this reduction may produce a 4 to 8 dBA reduction in the total noise (see Table 5-5). It is
 believed that the noisier locomotives have a higher exhaust noise component and, therefore, may
 achieve greater overall reduction in total  noise by reducing exhaust noise.  Based on the considerations
 of available empirical data, at throttle settings other than idle, an overall noise reduction of 6  dBA for
 the noisier locomotives seems reasonable. However, the EPA received further data in response to the
 docket, which indicated that a number of locomotives would be incapable of compliance with the
proposed 67-dBA idle standard through the application of muffler technology alone, due to the  pres-
ence of excessively high levels of structurally radiated noise at idle. As the result of an analysis of all
pertinent data dealing with the noise levels and the availability of technology for compliance,  the
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permissible long term idle noise level has been raised 3 dBA. Accordingly, the application of an exhaust
muffler can be expected to permit all locomotives to achieve the following levels:

     •   Idle                 70 dBA
     •   Overall Maximum     87 dBA

     The exhaust noise is primarily a function of the diesel engine horsepower and the method of
engine aspiration.  Rootes-blown engines would have higher exhaust noise than an equal size turbo-
charged engine. Also, a larger engine has higher exhaust noise than a smaller engine if the aspiration is
the same.
     However, the larger engines are generally turbocharged, while the small engines are Rootes-blown.
This leads to a partial cancellation of the effect of power and aspiration on the exhaust noise. It may
be feasible in the future to establish separate standards for different types of locomotives, depending
upon power or method of aspiration. This is not possible with the present data, however.
     Section 5 also shows that muffler manufacturers could supply the needed hardware within the
4 years allotted for design, development, and testing.

Locomotive Noise—Vehicle in Motion
     In addition to the stationary locomotive standard a passby standard that relates directly to the
manner in which locomotives operate in the environment is also desirable. Such a standard also could
be a  useful tool for adoption and enforcement by local and state governments.
     Based on available train passby data (see Figure 5-3) 96 dBA measured at 100  feet is achievable
and represents the best maintenance practice level for current locomotive noise emissions. As just
discussed, a reduction in overall locomotive noise of 6 dBA for the noisier locomotive through proper
muffler application is considered reasonable. Therefore, using the same projected design, development,
and testing times mentioned above, a 90 dBA noise emission level measured at 100  feet for all newly
manufactured locomotives during a passby test would be required in 4 years.

Rail Car Noise—Vehicles in Motion on line
     Figure 5-8 shows that at a given speed, rail car noise ranges ± 5 dBA above or below a mean value.
At 45 mph, the mean is approximately 83 dBA.  At 60 mph, the mean is approximately 88 dBA. As
such, the following Best-Maintenance-Practice-Standard measured at a 100-ft distance for rail cars in
motion is considered appropriate:

                                Rail Car Speed (v)       Noise Level
                                      mps                  dBA

                                     V  < 45                 88
                                     V  > 45                 93

Rail Car Noise—Vehicles in Motion in Yards
     As discussed in Section  5, a rail car passage through a retarder causes the emission of noise levels
as high as 120 dBA. Further discussed, are five possible methods of retarder noise control that might
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conceivably be employed individually or in concert. With such information, it might be argued that a
status quo level of 120 dBA may be appropriate at this time and could be subsequently reduced to
approximately 80 dBA as the technology of retarder noise control advances over the next few years.
At this time, however, it is the Agency position that retarder noise is an element of fixed facility rail-
road yard noise that, as such, can best be controlled by measures that do not in themselves affect
the movement of trains and therefore do not require national uniformity of treatment. Such noise
control measures might include, for example, the erection of noise barriers.
     The Agency study of railroad yard noise indicates that concern for noise from railroad yards is
more local than national. This is due in large part to the location of the number of yards in non-urban
areas and the relatively small number of hump yards (130).  Accordingly, the establishment of a
uniform national standard could potentially incur significant costs to the railroads with only  limited
environmental impact resulting in terms of the population relieved from undesirable noise levels.

REVISION OF THE PROPOSED REGULATION PRIOR TO PROMULGATION
     The Interstate Rail Carrier Noise Emission Regulations, which are now being promulgated,
incorporate several changes from the proposed regulation published  on July 3, 1974. These changes are
based upon the public comments received and upon the continuing study of rail carrier noise by the
Agency.  In all but four instances, such changes were not substantial; they are only intended to further
clarify the intent of the regulations.
     The first substantive change is that the restricted coverage of the long term locomotive standard
for both stationary and moving conditions will now apply only to those locomotives newly manufactured,
effective 4 years after the promulgation of the final regulation. Accordingly, the retrofit provision as
originally proposed has been deleted from the final regulation.
     A number of factors influenced the EPA decision to delete the retrofit requirement.  Several
docket entries contained economic and technological data that conflict significantly with the EPA data
that appears in the Background Document. The principal areas of conflict involve disparities in deter-
mination of the best  available technology as it exists today and the resultant costs of its application.
There is a further complicating factor in that the available space configurations existant within many
locomotives have been altered over the years due to the addition and modification of various locomo-
tive components such as dynamic braking systems and spark arresters. As a result of this practice,
there are numerous and diverse locomotive configurations, each possessing its own specific peculiari-
ties that must be accounted for in a retrofit program. The implications of this diversity of locomotive
configurations and the accompanying disagreement concerning available technology and the cost of its
application (i.e., labor rates, capital costs of new facilities, etc.) have given rise to cost of compliance
figures ranging from the original EPA estimates of $80 to $ 100 million to industry estimates approximat-
ing $400 to $800 million.
     Although the generation of additional information concerning  the availability of technology may
allow the Agency to reconcile these widely varying retrofit cost estimates, the collection of such data
would be a costly and time consuming process that may produce a retrofit cost estimate remaining
substantially high relative to the public health and welfare benefits that would result. For these
reasons, the Agency has decided to remove the retrofit requirement  from the regulation being promul-
gated herein. Acknowledging the uncertainties that currently accompany the retrofit provision, the
Agency may continue to consider the retrofit issue and may promulgate a retrofit requirement if
further information indicates that the technology is available and that retrofit compliance costs are
reasonable relative to the health and welfare benefits to be accrued.

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     The second substantive change to the regulation involves modifying the proposed locomotive idle
standard by increasing allowable noise emissions from the proposed 67 dBA to 70 dBA at 100 ft. This
change was made to accommodate new data that demonstrated that certain locomotive models appear
to be incapable of compliance with a 67-dBA standard through the application of muffler technology
alone, due to the dominant influence of structurally radiated noise during idle operation.
     The third substantive change to the regulation is that the effective dates of the initial standards
have been changed from 270 days to 365 days from the date of promulgation in response to requests
by the  DOT.
     The final  substantive change to the regulation is the incorporation of additional measurement
criteria into the standards as a separate Subpart C of the regulation. The noise emission standards
specified in the Agency regulations must be fully and definitively specified so that there is no question
as to the EPA standard being promulgated. Accordingly, measurement criteria containing those con-
ditions and parameters necessary for the consistent and accurate measurement of the sound levels
specified have  been included in the final regulation.
     Those changes made to clarify the intent of the regulations and the reasons therefore, are:

     •    Section 201.1 Definitions
         The  definition of "sound level" was changed slightly to be consistent with the definition of
         that term  as used in the document, Information on Levels of Environmental Noise Requisite
         to Protect Public Health and Welfare with an Adequate Margin of Safety," issued by the
         Environmental Protection Agency in March 1974.
         "Fast meter response" has been expanded for clarity.
         "Interstate commerce" has been modified to ensure  that any questions as to its scope would
         be resolved by reference to Section 203(a) of the Interstate Commerce  Act, consistent with
         the reference to that Act in Section 17(b) of the Noise Control Act.
         "Person" has been deleted since the word is no longer used in subpart B of the regulation.
         "Sound pressure level" has been deleted since the words are no longer used in subpart B of
         the regulation.
         "Special track work" has been  added in order to clarify the meaning  of the term as used
         in the find regulation.
         "Locomotive" has been expanded to include self-propelled rail passenger vehicles.
         "Special Purpose Equipment" has been  added to clarify the meaning of the term  as used in
         the final regulation.
         "Retarder" has been deleted since the word is no longer used in  subpart B of the  regulation.
         "Self load" has been deleted since the term is no longer used in subpart B of the regulation.
         "Idle" has been expanded to clarify the meaning of  the term as used  in the regulation.
         "dBA" has been modified slightly to specify the reference pressure of 20 micropascals.

     •    Section 201.10 Applicability
         This section has been modified slightly to exclude the application of Section 201.11 (a)
         and  (b) to gas turbine powered locomotives and any locomotive type which cannot be con-
         nected by any standard method to a load cell, and to more clearly  specify  the exclusion of

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          intra-urban mass transit systems in terms consistent .with the definition of "carrier" cited
          in the Act. In addition, the wording in the section has been modified to more clearly in-
          clude the application of the standards to refrigeration and airconditioning units on loco-
          motives and rail cars. Finally, the express exclusion of the applicability of the standards to
          railroad yards, shops, rights-of-way, or any other railroad equipment or facility not
          specified in the regulation has been deleted as unnecessary.

     •    Section 201.11 and 201.12 Standards for Locomotive Operation
          Under Stationary and Moving Conditions, Respectively.
          In addition to the applicability and effective date changes previously described, the reference
          to measurement site surface has been deleted and replaced by language referencing the
          measurement criteria in Subpart C of the regulation. Also the phrase "or the equivalent
          thereof in reference to a load cell has been deleted.

     •    Section 201.12 Standard for Rail Car Operations
          Track curvature requirements for measurement sites identical to those specified in Section
          201.12 for locomotives were incorporated into this section in addition to identical language
          referencing the measurement criteria of Subpart C as used in Section 201.12 and 201.11
          for locomotive test sites.  Also, the language in the section was modified slightly so as to
         to restrict compliance measurements to track free of special track work or bridges or trestles.
         The change in the effective date previously described also applies to this section.

NOISE EMISSION STANDARDS INTERSTATE RAIL CARRIER NOISE REGULATION
    •     Rail Cars
          Best Maintenance Practice Standards; Effective, 365 Days:
         @ Speeds: < 45 mph:      88  dBA
         ©Speeds: > 45 mph:      93  dBA
    •    Locomotives
         a. Best Maintenance Practice Standards; Effective, 365 Days:
            (1)  Stationary:
                (a) Idle:          73 dBA
                (b) Other Throttle: 93 dBA
            (2) Moving:           96 dBA
         b. Four year Newly Manufactured Standards:
            (1) Stationary:
                (a) Idle:          70 dBA
                (b) Other Throttle: 87 dBA
            (2) Moving:           90 dBA
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                                        Sections

                         DATA BASE FOR THE REGULATION
    The program for compiling data on train noise began with a search for existing data. By  com-
piling the existing data, it was possible to avoid repeating the few measurements completed by
others, and the limitations of the existing data indicated what measurements needed to be made to
extend the data.  Technical journals were searched for reports of pertinent measurements. Published
accounts of measurements in Europe and Asia were considered along with the accounts of measure-
ments in the United States and Canada.
     Much of the needed data was obtained by the EPA Regional Offices and under contract by
acoustical consultants. Some unpublished accounts of measurements and proceedings of appropri-
ate seminars were obtained through informal communication with members of the acoustics com-
munity. Leaders in the engineering departments of the two remaining locomotive manufacturers
Electro-Motive Division of General Motors (EMD) and General Electric Corp. (GE)  were also inter-
viewed to  ascertain the extent of their data files, as well as to determine what problems may be
created by attempts to control locomotive noise.  At a meeting hosted by the Association of Ameri-
can Railroads, EMD, and GE engineers reported measurements of locomotive noise  and discussed
some possible effects of locomotive noise controls. Three leading muffler manufacturers (Donald-
son, Harco Engineering, and Universal Silencer) were contacted to evaluate the feasibility and the
impact of fitting locomotives with exhaust mufflers.
     Railroad company personnel who worked in various capacities at various levels were contacted
to determine the mix of equipment used by railroads, the configurations of properties and equipment,
the scheduling of operations, and the modes of operation. In particular, yard masters, yard superin-
tendents, or engineering personnel were contacted to obtain information about yard configuration,
layout, and equipment. Railroad personnel were asked for information related to schedules and
speeds of trains.  The railroad companies that participated are listed in the references for this report.
     To resolve questions raised in the docket comment to the Notice of Proposed  Rule Making, the
Agency engaged in  further study of railroad noise, focusing on the further definition of available
technology and attendant costs that would be incurred during the implementation of a locomotive
retrofit program. In addition to information received from the docket comments and from additional
contractor effort, the Agency was the recipient of a gratis study conducted by the General Motors
Corporation Electromotive Division that attempted to identify the costs involved in the  retrofit of
the major EMD locomotive models currently in operation. The results of this study have been in-
cluded as Appendices E and F to this document.
     The sources of all information and data cited in this document are listed in the Reference
Section at the end of this report.
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                                         Section 4

                               THE RAILROAD INDUSTRY


ECONOMIC STATUS
     There are currently 72 Class I railroads in the U.S.* These tend to break down into two groups:
large transportation companies such as the Union Pacific or the Penn Central and railroads owned
by large industrial firms such as U.S. Steel.  The latter roads primarily provide transportation services
to the parent company.  Since railroads are regulated by the Interstate Commerce Commission
(ICC), the degree of competition is also regulated. The size of the firms has in many cases been de-
termined by whether the ICC has allowed or disapproved mergers.  Most large roads have grown
through mergers. In addition, the favorable financial positions of some roads have resulted from their
non-transportation activities.
     The total tonnage of freight moved in the U.S. has been rising over time, but the transportation
sector of the economy has declined in relative importance. In 1950, 5.6 percent of national income
originated in the transportation sector. By 1968, this figure declined to 3.8 percent and has remained
at about that level. This trend reflects the higher relative growth rates in those industries that re-
quire a smaller transportation input.
     The rail industry has declined more rapidly than the transportation sector as a whole. In 1950,
the rail sector constituted 53 percent of the national income originating in the transportation sector.
By  1968 it had declined  to 25.8 percent of the-transportation sector and has remained relatively
stable since then.  Table  4-1 summarizes these statistics.**
     Accompanying the  decline in the rail sector's share hi national income originating in the trans-
portation sector, the proportion of total freight hauled by rail has declined. In 1940, the railroads
hauled 63.2 percent of all freight, dropping to 44.7 percent by 1960 and to 39.9 percent by 1970.
Motor carriers and oil pipelines have rapidly increased their share during this period. Air freight has
increased more rapidly than either motor carriers or pipelines, but it accounts for only 0.18  percent
of total freight. In spite of the decreasing proportion of shipments by rail, railroads still produce
more ton-miles of freight transportation than any other single mode, the total volume of freight
hauled by rail having increased from 411.8  billion ton-miles in 1940 to 594.9 in 1960, to 768.0 in
1970, and to an estimated 855 in 1974. Table 4-2 summarizes these trends.
*Class I railroads are those having annual revenues of $5 million or more. They account for 99 per-
cent of the national freight traffic.
**Unless otherwise stated, the data presented in Tables 4-1 through 4-6 were obtained from the
Statistical Abstract of the United States (1971) and (1972).
                                           4-1

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                                      TABLE 4-1
   NATIONAL INCOME ORIGINATING IN THE TRANSPORTATION AND RAIL SECTORS
                                     ($ In Billions)
Year
1950
1960
1965
1968
1969
1970
National
Income
$241.1
414.5
564.3
712.7
769.5
795.9
Transportation
$13.4
18.2
23.2
27.1
29.2
29.5
Transportation
as%of
National Income
5.6%
4.5
4.1
3.8
3.8
3.7
Rail
$7.1
6.7
7.0
7.0
7.4
7.2
Rail as % of
Transportation
53.0%
36.8
30.2
25.8
25.3
24.4
                                      TABLE 4-2
                     INTERCITY FREIGHT (In Billions of Ton-Miles)
Year
1940
1956
1960
1965
1968
1969
1970
Total Freight
Volume in
109 Ton-Miles
651.2
1376.3
1330.0
1651.0
1838.7
1898.0
1921.0
Rail Freight
inlO9
Ton-Miles
411.8
677.0
594.9
721.1
765.8
780.0
768
Rail
%
63.2
49.2
44.7
43.7
41.2
41.1
39.9
Motor
Vehicles
%
9.5
18.1
21.5
21.8
21.6
21.3
21.44
Oil
Pipelines
%
9.1
16.7
17.2
18.6
21.3
21.7
• 22.4
Air
%
.002
.04
.06
.12
.16
.17
.18
Inland
Water
%
18.1
16.0
16.6
15.9
15.9
15.8
15.98
     Rail passenger service declined from 6.4 percent of intercity travel in 1950 to less than 0.1 per-
cent in 1970.  The real impact of railroads on the national economy is in terms of freight rather
than passengers. The decline of the rail industry share of the transportation sector is less dramatic
when passenger service (air, local, suburban, and highway) is eliminated from calculations. Table
4-3 gives the transportation sector percentage contributions to national income, less the passenger
sectors just mentioned, and the rail industry's percentage of the transportation sector.
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                                      TABLE 4-3
                PERCENT OF NATIONAL INCOME ORIGINATING IN THE
               TRANSPORTATION SECTOR (LESS AIRLINE AND LOCAL
                 SUBURBAN AND HIGHWAY PASSENGERS) AND THE
                RAIL SECTOR AS A PERCENT OF TRANSPORTATION
Year
1950
1960
1965
1968
1969
1970
Transportation* (Adjusted)
as % of
National Income
4.8%
3.7
3.3
3.0
3.0
2.9
Railroads
as%of
Transportation
(Adjusted)
61.7%
44.1
37.6
33.0
32.3
Not
Available
              "Transportation minus air carriers and local suburban and highway passengers.
     From comparison of Table 4-1 and 4-3, it can be seen that the freight sector has declined more
rapidly than the total transportation sector.  It can also be seen that the railroads' decline is some-
what less dramatic in terms of freight alone than in terms of both freight and passenger service.

EMPLOYMENT
     The railroads' importance as a source of employment within the economy has decreased along
with their share of the nation's transportation output. In 1950, the railroads accounted for 2.7 per-
cent of all employees in nonagricultural establishments.  By 1970, this had fallen to less than  1.0
percent. Not only has the relative importance of railroads declined, the absolute level of employ-
ment from 1950 to 1970 decreased by over 50 percent as shown in Table 44.
     Wages in the rail sector have consistently been above the average of all manufacturing employees,
and this differential has increased over the years. In 1950, the average hourly compensation in the
rail sector was $1.60 which was 110 percent of the average hourly compensation in manufacturing.
In 1968 average compensation was $3.54, or 118 percent of that in manufacturing. By 1971, rail
compensation had increased to 126 percent of the average compensation in the manufacturing
sector.
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                                     TABLE44
                       EMPLOYMENT IN THE RAIL INDUSTRY
                      RELATIVE TO THE NATIONAL ECONOMY
Year
1950
1960
1965
1968
1969
1970
National Employees
in All
Nonagricultural
Establishments
(1000)
45,222
54,234
60,815
67,915
70,274
70,664
Railroad
Employment
(1000)
1220
780
640
591
578
566
Railroad
as%of
National
2.7%
1.4
1.1
.9
.8
.8
     Increases in wage rates in the rail sector have been greater than the increases in the wage rates
in the manufacturing sector. Using 1967 as the base (=100), the index of wage rates in manufacturing
in 1970 was 121.6, while the rail industry index was 125.6. Over the same period, the increase in
productivity in the rail industry has been less than productivity increases in manufacturing. In 1970,
the index of output for all railroad employees was 109.9*, while in manufacturing it was 111.6 (using
a 1967 base of 100).  Table 4-5 summarizes the wage and productivity data.

                                    TABLE 4-5
                  INDEX OF OUTPUT PER MAN HOUR AND WAGES
                                    (1967 = 100)
Year
1950
1960
1965
1968
1969
1970
Rail Wage
41.5
74.3
88.9
106.3
113.6
125.6
Manufacturing
Wage
44.7
76.6
91.2
107.1
113.9
121.6
Rail
Productivity
42.0
63.6
90.8
104.4
109.3
109.9
Manufacturing
Productivity
64.4
79.9
98.3
104.7
107.7
116.6
""Computed on the basis of revenue per man-hour.
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     The fact that productivity increases have not kept pace with wage rate increases indicates that
unit labor costs are rising.
     In the years since 1970, wages in the rail industry have, as in most industries, increased rapidly.
The index of wages in 1971 was 136.8; in 1972,136.8; and in 1973,165.4 (estimated).

HEALTH AND GROWTH OF THE INDUSTRY
Health of the Industry
     There are a number of measures one might use to judge the health or financial stability of the
rail industry. Two of these are the  rate of return on stockholder equity and the percent of revenue
carried through to net operating revenue. Shareholder equity is the excess of assets over liabilities,
which is equal to the book value of capital stock and surplus.
     In 1971, the rate of return on  stockholder equity for all manufacturing firms was 10.8 percent.
The rates of returns in some selected industries are as follows:

     • .   Instruments, photo goods, etc.          15.8%
     •    Glass Products                        11.1%
     •    Distilling                               9.9%
     •    Nonferrous metals                      5.2%

     The return for the total transportation sector was 3.1 percent. Railroads showed a 2.1 percent
on stockholder equity, slightly above the airlines' 2.0 percent.
     The rate of return on stockholder equity increased from 1.3 percent in 1971 to 3.0 percent in
1972.  The use of industry data, however, tends to give a  misleading impression of the industry.*
     The Eastern District had a negative rate of return for the three years from  1970 to 1972, while
both the Southern and Western Districts had positive and increasing rates of returns. The Southern
District showed an increase from 5.2 percent to 6.1 percent and the West from 3.7 to 5.1 percent.
The rates of returns in these districts are well above the 3.1 percent for total transportation and are
about equal to the textile and paper industries.
     These trends indicate that the problem in the rail industry is not with all districts but primarily
with roads in the Eastern District.  Using operating ratios** as the measure of financial stability, one
draws the same conclusions.
* Because the railroads use a nonstandard accounting procedure (the so-called betterment technique),
the rate of return is low relative to what it would be if they used a procedure comparable to those
used in the nonregulated sector.
**Operating ratio equals operation expenses divided by operating revenues.
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     The historical trends in the profitability of the industry can be measured by the percent of
gross revenue carried through to net operating income before Federal income taxes. This measure
is similar to the rate of return on sales before taxes. For the industry as a whole, the percent of
gross revenue carried through has been declining.  This is also true of each district, with the Eastern
being the worst.  Table 4-6 summarizes these trends.

                                       TABLE 4-6
                   PERCENT OF GROSS REVENUE CARRIED THROUGH
            TO NET OPERATING INCOME BEFORE FEDERAL INCOME TAXES
Year
1950
1960
1965
1968
1969'
1970
1971
All Class I
RR's
17.3%
8.3
11.0
6.9
6.6
4.2
4.0
Southern
District
20.1%
10.7
12.1
11.0
12.1
11.8
10.3
Eastern
District
12.0%
2.1
10.0
3.7
2.7
Nil
0.5
Western
District
19.8%
10.0
11.6
8.4
8.0
7.7
7.2
     The performances of the Southern and Western Districts are much better than the Eastern.  In
fact, one could conclude that compared with nonregulated industries such as steel, the Southern
and Western roads are reasonably good performers.  Compared with other regulated industries, such
as public utilities (10.5 percent return on stockholder equity) and telephone and telegraph companies
(9.5 percent return on stockholder equity), the railroad rate of return is low.  One point that should
be made is that railroads follow a betterment accounting procedure, which tends to overstate the
value of their assets. We have not attempted to adjust rate of return in the rail industry to reflect
this.
     The historical decline in the profitability of railroads came as a result of a decrease in the rela-
tive importance of high-weight, low-value cargo, which has traditionally been handled by rail. The
increased competition from motor carriers  and pipelines has further reduced the relative importance
of railroads. Federal and state funding of highways has improved the competitive position of trucks
and has led to the diversion of high-valued freight to motor carriers.
     In 1935, when motor carriers came under Interstate Commerce Commission regulation, the
value-of-service rate structure applied to railroads was also applied to motor carriers. (The value-
of-service rate-making policy was originally applied to railroads to favor agricultural products.
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Under value-of-service rates, low-valued products have a lower rate per ton-mile than do high-value
products.*)  This measure reduced intermodal price competition and, in fact, gave an advantage to
trucks in carrying high-valued freight when they could give faster service. Railroads were unable to
lower prices on this type of freight, which could have offset the faster service offered by trucks.
     The decline of some manufacturing industries in the East has led to a more intense financial
crisis among eastern roads. Also, the capital stock of these railroads tends to be older than that of
the other roads. They spend a larger portion of total cost on yard switching than do either Southern^
or Western roads, due to shorter hauls and a larger number of interchanges among roads. Since
shippers pay for movement from one point to another (i.e., rate per mile), the competitive position
of railroads tends to be diminished if these nonline-haul expenses rise. The greater yard-switching
results in having rail cars sit in switching yards waiting for a train to be made up, thus resulting in
longer time in transit and higher comparative costs.

Growth of the Industry
     In projecting growth rates in any industry, it is assumed that historical trends and relationships
will continue to hold in the future to some extent. If these relationships do continue, then rail
freight can be projected based on projection of other figures.  For example, rail freight service on
the basis  of population or gross national product can be projected.  If the population continues to
consume similar commodities, if these commodities move by the same modes of transporation, and
if increases in income are ignored, then projections based on accurate population projections will be
valid.
     The number of ton-miles of railroad freight per capita in the U.S. has remained stable over recent
years.  It was 3.73 in 1965, 3.77 in 1968, and 3,75 in  1970.  Given this stability, reasonable short-run
projections based on population growth may be made.  Based on the population projections for the
U.S., about a 1.0 percent annual increase over the next 5  years is estimated. This would project an
increase from 768 billion ton-miles in 1970 to about 822 billion ton-miles in 1975.  This projection
falls somewhat short of the estimated 855 billion [42] ton-miles of freight actually hauled in 1974.
This difference is largely attributable to a gradually increasing efficiency in the operation and utili-
zation of railroad equipments and facilities, as well as periods of increased coal and  grain traffic
during the past few years.  However, exclusive of any dramatic improvements in railroad technology
or operations, or substantial fluctuations in the types and amounts of commodities available for
transport, the 1.0 percent figure seems to provide a reasonable projection of short run growth.
     One other factor that may accelerate the growth of  demand for rail transporation services is
that rail movement uses less energy than other forms of freight movement. A ton-mile of freight
moved by rail requires 750 BTU, while pipelines require 1850, trucks 2400, and air freight 63,000.
The only mode of freight movement more efficient (in terms of energy) than rail is water, which
requires 500 BTU  [41].
*These points are examined in an article by R. H. Harbeson in the 1969 Journal of Law and
Economics, pp. 321-338.
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     The rail industry contribution to national income has remained relatively constant from 1968
to 1970 at about 1.0 percent. The long-run rate of growth in GNP has been about 3.5 percent.
Again, under the assumption that these historical relationships hold, the long-run growth should be
around 3.5 percent.
     Energy may come to be an important factor and may cause some short run traffic variations,
but it seems unlikely that rail freight will increase more rapidly than the growth in national income
in the long-run. The factor mitigating a more rapid increase  is that consumption patterns
have continued to move toward more services and fewer manufactured products.  This means a
smaller transportation input. In addition, rising interest rates and greater product differentiation
have caused shippers to be increasingly concerned with time in transit. The railroads' real advantage
is in rates, not speed. However, the advent of transporting entire truck trailers by rail has aided in
substantially reducing delivery time where this is practiced.
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                                             Section 5

                                  RAILROAD NOISE SOURCES
OVERVIEW OF THE PROBLEM
     Noise is generated by railroad operations in two basic locations: in yards and on lines.  In railroad
yards, trains are broken down and assembled and maintenance is performed. Line operations involve
the sustained motion of locomotives pulling a string of cars over tracks.
     The hump yard is an efficient system for disengaging cars from incoming trains and assembling
them into appropriate outgoing trains.  A locomotive pushes a string of cars up a small hill, known as a
hump, allowing each car to roll individually down the other side through a series of switches onto the
appropriate track, where a train is being assembled.  As each car rolls down the hump, it is first slowed
by the master retarder.
     The slowing, or retarding, is accomplished by metal beams that squeeze the wheel of the rail car.
After the cars leave the master retarder, they coast into a switching area that contains many  tracks.  As
each car is switched onto a particular track, it is slowed by a group retarder.  After a car moves out of a
«?roup retarder, it is switched onto one of many  (approximately 50) tracks in the classification area,
where the car collides with another car.
     The collision causes the cars to couple, forming a train. In some yards, the first car that moves
into the classification area along a particular track is stopped by an inert retarder, so called because the
retaining beam is spring-loaded and requires no external operation.  Inert retarders differ from the master
and group retarders, which are controlled continuously by an operator or automatically by a computer.
     All three  of the retarding processes just described produce noise. When the beam of a master or
group retarder rubs against the wheels, a loud squeal is often generated.  The most significant noise
generated by inert retarders occurs when a string of cars is pulled through. If the inert retarders are
short and exert small forces, they may generate  noise that is negligible compared with the noise genera-
ted by the group retarders.  Some yards are equipped with inert retarders that can be manually or
automatically released when a string of cars is pulled through them, thereby preventing retarder squeal.
There are no inert retarders in some yards, so  an individual brakeman must ride some cars and brake
them manually.
     Noise is also produced when cars couple  in the classification area of the yard.  The impact points,
and thus the origins of the noise, are scattered over the classification yard. The noise is impulsive,
and sometimes it is followed by a thunderlike rumble audible for several seconds after the impact.
     Locomotive engines generate noise as the locomotives move around or pass through yards. When
the locomotives are not in use, their engines are often allowed to idle continuously (even overnight),
which also results in significant noise. When the locomotives are in motion, their horns, whistles, and
bells may produce noise  for warning purposes.
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     Some noise originates in the yard shops, where locomotives and cars are repaired and maintained.
Power tools and ventilation fans represent such sources.  However, the most readily identifiable sources
of shop noise are the locomotives themselves when undergoing testing.
     Most yards are equipped with a number of loudspeakers used for conveying verbal instructions and
warning sounds to workers in the yard. The speakers are scattered about the yard, and a given speaker
issues sound on an unpredictable schedule.
     Line, or wayside noise-the noise in communities from passing trains-is produced by many high-
noise sources. The locomotive engine and its components, such as exhaust systems and cooling fans,
and the interaction of railroad car wheels with rails results in significant noise.
     Wheel/rail noise is caused principally by impact at rail joints, giving rise to the familiar clickety-
clack, and by small-scale wheel and rail roughness.  A severe form of wheel roughness that generates
high noise levels is caused by flat spots developed during hard  braking.  Also, wheels squeal on sharp
curves and generate noise by flange-rubbing on moderate curves.  The operation of such auxiliaries as
refrigeration equipment also contributes to the overall noise level. Horns or whistles are  sounded at
crossings and are significantly louder than the other wayside noises. In addition, some crossings are
equipped with stationary bells that sound before and during the passage of trains.
     The remainder of Section  5 treats each of the noise sources mentioned separately and in as much
detail as the state-of-the-art allows. Included in the discussion of each source is a description of abate-
ment techniques.

CONSIDERATION OF RAILROAD NOISE SOURCES FOR  FEDERAL REGULATIONS
     The EPA has studied the operations of rail carriers engaged in interstate commerce by rail and
recognizes that such operations are imbedded in every corner of the nation  at thousands of locations
and along hundreds of thousands of miles of right-of-way.  The nature and magnitude of the noises
produced by the many types of facilities and equipment utilized in these operations differ greatly, and
their impact on the environment varies widely depending on whether they occur, for example, in a
desert or adjacent to a residential area.
     The Agency concludes that the control of certain of these noise sources, such as fixed facilities,
or equipment used infrequently or primarily in one location, is best handled by the state and local
authorities, rather than by the Federal government. State and local authorities are believed in this
case to be better able to consider local circumstances in applying such measures as the  addition of noise
barriers or sound insulation to particular facilities or the positioning of noisy equipment  within these
facilities as far as possible from noise-sensitive areas. Further, and more importantly, the EPA did not
find during its analysis, and has not received from rail carriers, any information identifying situations
in which lack of uniform state and local laws regarding these facilities and equipment has imposed any
significant burden on interstate commerce.
     The Administrator has considered the following broad categories of railroad noise sources, to
identify those types of equipment and facilities requiring national uniformity of treatment through
Federal noise regulations to facilitate interstate commerce.

Office Buildings
     Many, if not all, surface carriers engaged in interstate commerce by railroad own and operate
office buildings. These buildings are technically facilities of the carriers.  Like all office buildings they
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may emit noise from their air conditioning and mechanical equipment. But since each building is
permanently located in only one jurisdiction and is potentially subject only to its regulations, it is not
affected in any significant way by the fact that different jurisdictions may impose different standards
on noise emissions from the air conditioning and mechanical equipment of other buildings. At this
time, there appears to be no need for national uniformity of treatment of these facilities, and they are
therefore not covered by this regulation.

Repair and Maintenance Shops
     Railroad repair and maintenance shops are similar in many ways to many nonrailroad industrial
facilities, such as machine shops, foundries, and forges. All such facilities can reduce their noise impact
on the surrounding community by a variety of measures including:

          Reducing noise emissions at the source
          Providing better sound insulation for their buildings
          Erecting noise barriers
          Buying more land to act as a noise buffer
          Scheduling noise operations at times when their impact will be least severe
          Moving noisy equipment to locations more remote from adjoining property.

     Such detailed and highly localized environmental considerations are best handled by local
authorities so long as they comply with the applicable restrictions concerning Federal preemption.
Like office buildings, shops are permanently located in only one jurisdiction and thus are not poten-
tially subject to differing or conflicting noise regulations of other jurisdictions. At this time, therefore,
there appears to be no need for national uniformity of treatment of these facilities, and they are not
covered by this regulation.
     At times, railroad maintenance shops may contain major noise sources that do require national
uniformity of treatment, such as locomotives.  But the fact that some such individual noise sources
within a shop may be subject to Federal noise emission regulations is irrelevant to the validity of state
or local noise emission regulations applied to the shop as a whole.  This is so as long as the state or local
regulation of the shop can be reasonably complied with without physically affecting the federally
regulated noise source within the shop (for example, by installing sound insulation in the shop building).
This will  be  discussed further in the section on preemption.

Terminals, Marshalling Yards, Humping Yards, and Specifically
Railroad Retarders
     Like office buildings and shops, railroad terminals and yards are permanent installations normally
subject to the environmental noise regulations of only one jurisdiction. The Agency has determined
that such fixed facility railroad yard and terminal noise is  best controlled at this time at the local level,
employing measures that do not in themselves affect the movement of trains and therefore do not
require national uniformity of treatment.
     Local jurisdictions are familiar with the particular complexities of their community/railroad
noise situation, and, as such, are in a position to exhibit greater sensitivity in prescribing practical and
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 cost effective solutions to the local noise problem.  Railroad yard facilities vary in size, shape, and
 special characteristics, and the noises produced there are diverse.
     The EPA recognizes that the communities neighboring these yards and terminals are equally
 diverse, varying in land zoning and population density and distribution. As such, Federal regulation
 successfully producing substantial population health and welfare benefit at one locality may produce
 little or no such benefit at another locality. For example, the regulation of a railroad yard facility
 enveloped by a residential community would not achieve similar population health and welfare benefit
 when equally applied to a similar railroad yard facility existing within a large industrial complex. This
 subject is discussed in more detail in Appendices C and D of this document.
     Additionally, the Agency study of railroad yard noise (inclusive of retarder noise) indicates that
 concern for noise from railroad yards, and retarders in particular, is apparently limited to certain
 localities and is not a national concern. This is due in large part to the location of a number of yards in
 non-urban areas and the relatively few existing retarder systems, approximately 120.
     This local nature of the retarder noise problem further  reduces the desirability of a Federally
 preemptive regulation.  For example, in a situation in which a retarder yard is bordered on one side by
 a residential area and on all  other sides by an unpopulated wooded area, a  barrier could be beneficial
 to public health and welfare only if erected on that side of the retarder facing the residential area.
 Under such circumstances a community would receive insufficient health and welfare benefits to justify
 the costs incurred by a Federally preemptive regulation that mandates the  installation of barrier walls
 on both sides of retarder mechanisms.
     At the currently estimated materials cost of $70 to $100 per linear foot for barriers, barrier
 costs would run from $75,000 to $150,000 per railroad yard and from $9.6 to $ 19.1 million for the
 entire railroad industry. Maintenance and replacement costs, yard down time, and  track modification
 costs have  not been fully identified.
     Expenditures should be assured of producing maximum benefits, and this may best be done through
 local regulation.  Available space for installation of barriers, and safety hazards that might accrue, have
 not been identified and are peculiar to the particular characteristics of the  individual railroad yards and,
 as such, may be best accounted for through local regulation.
     A  Federal regulation for conversion of inert retarders to retractable inert retarders would be
 subject  to considerations similar to those discussed for the erection of barriers around active retarders.
 However, probable yard down time and installation and materials costs would be considerably greater
 for conversion to inert retractable retarders than for the erection of barriers. The EPA estimates that
 conversion to retractable inert retarders would cost $7,500 for each retarder, not including labor, yard
 down time, or maintenance costs.  Applying a gross estimate of 20,000 such inert retarders nationally,
 estimated national conversion costs, exclusive of labor, down time, and operational costs, would be
 $150 million.
     Although the EPA does not currently propose to regulate retarder noise, it does recommend that
 local jurisdictions establish regulations requiring railroads to  utilize barrier  technology where needed
 and where  both practical and feasible.  Further consideration may be given by the EPA to possibly
providing future regulations requiring that new retarder installations be equipped with retractable inert
retarders, computer control systems, retarder beam lubrication systems, or other available technical
developments resulting in  significant noise reduction from retarders as the need for such regulations is
demonstrated relative to the costs involved and the availability of technology.
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     For reasons just outlined, the EPA does not presently propose to regulate railroad yard or retarder
noise.
     Like railroad maintenance shops, marshalling and humping yards contain some noise sources that
are covered by the proposed regulations. As is discussed in greater detail in the section on preemption,
a state or local noise regulation on a railroad terminal or yard is, in effect, a regulation on the federally
regulated noise sources within the terminal or yard when it can be met only by physically altering the
Federally regulated noise sources, or as otherwise specified in the preemption discussion.

Horns, Whistles, Bells, and Other Warning Devices
     These noises are different in nature from most other types of railroad noise since they are created
intentionally to convey information to the hearer instead of as unwanted byproducts of some other
activity. Railroad horns, whistles, bells, etc., are regulated at the Federal and state levels as safety
devices rather than as noise sources.
     Federal safety regulations are confined to the inspection of such devices on locomotives so as to
'ensure that, if present, they are suitably located and in good working order (Safety Appliance Act, 45
USCA; 49 Code of Federal Regulation,  121, 234, 236, 428,429). State regulations are oriented
toward specifying the conditions of use of these devices and, for the most part, do not specify any
maximum or minimum allowable noise level for them.  A recent survey of the 48 contiguous states
(See Appendix B) has revealed the following:

     •    At least 43 states require that trains must sound warning signals when approaching public
          crossings.

     •    Thirty-five of these states specify some minimum distance  from a public crossing at which a
          train approaching that crossing may sound a warning signal.

     •    Three states specify a maximum distance from a public crossing at which a train approaching
          that crossing may sound a warning signal.

     •    Thirty-five states specify that these warning signals must be sounded until the  train reaches
          the crossing.

     •    Three states specify that these warning signals must be sounded until the train completely
          clears the crossing.

     •    Sixteen states provide for exceptions to their regulations for trains operating in incorporated
          areas.

     •    At least two states provide for exceptions to their regulations for trains approaching public
          crossings that are equipped with satisfactory warning devices.

     The EPA does recognize that a noise problem exists as to the use and extent of railroad warning
devices and that regulatory action may be appropriate for controlling them.  However, the Agency
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 believes that the requisite regulation can best be considered and implemented by state and local authori-
 ties, who are better able to evaluate the particular local circumstances with respect to the nature and
 extent of the noise problem and the requisite safety considerations involved.  Any comprehensive
 Federal regulation in this area could be overly diverse and cumbersome. The EPA encourages in this
 regard the interaction between local and state governments and the railroads directly concerned in
 solving the particular local noise problems associated with the use of such warning devices.  However,
 if local authorities, after having first sought solutions with the railroads involved, have still not been
 able to resolve their problems, they are encouraged to then direct their concerns to the EPA for
 possible further Federal action.
     EPA has determined that the use of such warning devices in and around railroad yards is not out
 of place due to the often heavy  intermingling of workers and mobile equipment with locomotives and
 rail cars. Such use may, of course, be beyond the extent necessary to ensure safety, not only in railroad
 yards but wherever else railroad horns, bells, and whistles are used. The term overused, however, is
 relative to the particular circumstances surrounding such use:  whether, for example, a railroad yard or
 rail-highway intersection is situated in a residential as opposed to an industrialized area. These situations
 are instances  where the EPA recommendation for railroad and community interaction is at this time the
 most appropriate means of achieving effective warning device noise abatement.
     EPA encourages alternate solutions to the routine use of acoustic warning devices at rail and road
 crossings.  For example, the elimination of public grade level railroad crossings would do away with the
 source of the problem, the intersection of rail tracks and public thoroughfares. However, such a
national program of elevating or depressing either the railroad line or the public thoroughfare  at each
crossing, solely  for the purpose of the abatement of acoustic warning signal noise, is not considered
appropriate.  It should be seriously considered, though, in future public thoroughfare or railroad line
construction programs for both  safety and environmental noise reasons.
     Warning gates, too, as suggested, would appear to be an effective safety alternative to acoustic
 warning signals. Specifying their use on a national basis, however, would be prohibitively expensive
 considering that, costs range from $45,000 to $90,000 per unit.  And with the extensive use of grade
level crossings in the  United States, Illinois, for example, having approximately 15,000 crossings without
 drop gates, the cost would be $675 million or more in that state alone.
     Since acoustic warning devices do serve the interests of safety and can best be regulated at the
 local and state level for the reasons indicated, EPA does not propose to regulate railroad acoustic warn-
ing devices at this time.

 Special Purpose Equipment
     Examples of special purpose equipment that may be located on or operated from rail cars include:

         Ballast cribbing machines
         Ballast regulators
         Conditioners and scarifiers
         Bolt machines
         Brush cutters
         Compactors
         Concrete mixers
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         Cranes and derricks
         Earth boring machines
         Electric welding machines
         Grinders
         Grouters
         Pile drivers
         Rail heaters
         Rail layers
         Sandblasters
         Snow Plows
         Spike drivers
         Sprayers and numerous other types of maintenance-of-way equipment.

     The Agency realized that special purpose equipment such as that used for maintenance-of-way
activities is essentially construction equipment and as such, may emit loud intermittent noise.
Railroads may avoid noise problems by keeping routine maintenance activities to reasonable times.
Local jurisdictions may easily regulate operation times for such equipment as long as exceptions
are allowed for emergency use.  For example, a community may wish to regulate the hours allowed
for routine operation of spike driving equipment, but exception must be made for the operation
of such equipment in the aftermath of a derailment, so tht interstate commerce would not be
unduly impeded.
     The small numbers of such equipment, their infrequency of use, and the relative ease with
which viable local regulations may be instituted all tend to make a federally preemptive regulation
overly expensive relative to the benefits received.
     There has not been any indication that any cases currently exist in which non-uniform local
or state regulation of special purpose equipment has unduly burdened those railroads so regulated.
At this time the Agency does not believe that special purpose equipment requires national
uniformity of treatment. However, the rail cars on which such special purpose equipment is
located are included under the standards for rail  car operations. The Agency continues to solicit
notice of specific cases in which non-uniform local or state regulation of special purpose equipment
has created a burden on interstate commerce.  If, in the future, it appears that national uniformity
of treatment of such equipment is appropriate, noise emission standards may be proposed.

Track and Right-of-Way Design
     The standard promulgated  for rail cars applies to the total noise produced by the operation
of trains on track. As such, it is preemptive with respect to both rail cars and track. It reflects the
noise level  achievable by application of best maintenance standards to rail cars.  Further reductions
in noise levels are achievable' through various track repairs and modifications. However, EPA has
not fully identified the available technology or the applicable costs associated with such practices.
In the future, the EPA may propose standards that would require their application.
     However, some steps, such as the erection of noise barriers, can be taken to reduce noise
emissions from railroad rights-of-way that do not in any way affect the operation of trains on the
rights-of-way. State and local governments are better able than the Federal Government to
determine if some noise-sensitive areas need such protection; and the existence of differing require-
ments for such measures in different areas does not at this time appear to impose any significant

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 burden on interstate commerce. There is presently no need for national uniformity of treatment of
 such noise abatement techniques; and they are, therefore, not covered by the proposed regulations.
     The Federal railroad noise regulations do preempt any local regulations that set noise
 emission standards or require use restriction on rail cars equipped with auxiliary power units, more
 specifically, mechanically refrigerated freight cars, and various auxiliary powered passenger-related
 cars.
     The initial decision by the Agency was to regulate noise from all sources produced by rail cars
 while in motion only and to leave to state and local authorities the regulation of whatever
 noise is produced from rail cars while stationary.  This decision was made because these noises are
 a problem only when such cars are parked near noise-sensitive areas (such noises being indistinguish-
 able from other railroad car noises while the cars are in motion) and because it was felt that such
 localized problems could best be controlled by measures such as the relocation of those cars to less
 noise-sensitive areas.
     The Agency was and continues to be cognizant of the extent of the problem that can be
 caused in specific instances by the continuous operation of the diesel or gasoline engines operating
 on such cars. Noise levels as high as 75 dBA at 15 meters (50 feet) are possible from refrigerator
 cars parked with their cooling systems running in marshalling and humping yards. Noise levels from
 such refrigerator cars can be even greater because such cars are often parked coupled together in
 large numbers.  Additional data acquired by and supplied to the Agency has shown that the problem
 exists not only with refrigerator cars but also with various passenger-related cars such as dining cars,
 lounge cars, cafe-type cars, and others equipped with self-contained power units.  Also, the abatement
 of such noise appears possible and, in certain instances, is now being accomplished through the use
 of existing muffler designs.
     The Agency therefore may consider  the possible promulgation of a regulation dealing with
 the noise produced by mechanically refrigerated freight cars and passenger cars equipped with
 auxiliary power equipment so as to reduce the impact of such noise when these cars are parked near
 noise-sensitive areas.
     It should be noted that, in the regulation, the standard for rail car operations refers to
 the total noise generated and that the setting of emission standards on any element of that noise is
 preempted, whether the rail car is in motion or stationary. This Federal regulatory action does not,
 however, interfere with the ability of state and local governments to enact or enforce railroad yard
 noise emission regulations that require railroads to erect noise barriers. Nor does the regulation
 interfere with the ability of state and local governments to enact or enforce noise emission regulations
 that require the relocation of parked rail cars generating noise so long as that regulation is reviewed
 and approved by EPA pursuant to Section 17(c)(2) of the Act.
     The Agency has not intended and does not intend that intra-urban mass transit systems be
 covered  by the regulation being  promulgated.  It is the  Agency judgment  that such  systems
 are specifically excluded from regulation under Section 17 of the Noise Control Act of 1972 by the
 definition of "carrier" cited in the Act, which excludes "... street, suburban, and interurban
electric railways unless operated as a part of a general railroad system of transportation." In addition,
 such systems operate principally within one jurisdiction or in some cases throughout a small number
of contiguous metropolitan jurisdictions under the purview of a single transit authority and, as such,
do not appear to require uniform Federal regulation to facilitate interstate commerce. However, the
                                             5-8

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  exclusion of such systems does not also exclude the operations and equipment associated with
  commuter rail services provided by a number of interstate rail carriers.

  Trains

      Unlike the categories of railroad equipment and facilities just discussed, train noise is
  potentially subject to the noise regulations of more than one jurisdiction.  Trains are constantly
  moving from one jurisdiction to another, and it is not feasible to have them stopped at policital
  boundaries and adapted to meet a different noise standard.  Moreover, they constitute a major
  source of noise to people close to railroad rights-of-way. The various sources of train noise (other
  than warning devices) are therefore covered by the regulation to facilitate interstate commerce
  through uniform national treatment of their control.

  CHARACTER OF RAILROAD NOISE SOURCES AND ABATEMENT TECHNOLOGY

  Locomotives
      Railroad locomotives are generally categorized as

      •   Steam
      •   Diesel-electric
      •   Electric
      •   Gas turbine.

     The few remaining steam locomotives in the United States are preserved primarily as historical
 curiosities and are, therefore, not covered by the proposed regulations. In this subsection, noise
 associated with diesel-electric and electric/gas turbine locomotives are presented.
     All measurements discussed in this section are A-weighted levels obtained by means of
 microphones places alongside a locomotive, and refer to a measurement distance of 100 feet,
 unless otherwise noted. Details of the measurements are given in Section 6.

 Diesel-Electric Locomotives
     Three types of engines are currently in use:

     1.   Two-stroke Rootes blown
     2.   Two-stroke turbocharged
     3.   Four-stroke turbocharged.

     A turbocharged engine produces about 50 percent more power than does a Rootes-blown
engine.  The number of cylinders on a diesel engine may be 8, 12, 16, or 20, with each cylinder
having a displacement of 640 cu in. Each cylinder produces 125 hp when Rootes blown and 187.5
to 225 hp when turbocharged. These engines are employed on-the two basic types of locomotive:

     1.   The switcher, which is used primarily to shunt cars around the railroad yard and is
         powered by engines of 1500 hp or more.
                                           5-9

-------
     2.   The road locomotive, which is used primarily for long hauls, and is powered by engines
         of 15 00 hp or more.

     A diesel locomotive engine drives an electric alternator that produces electricity to run the
electric traction motors attached to each axle of the locomotive. The rated power of the engine
is the maximum electrical power delivered continuously by the alternator. The engine has eight
possible throttle settings. As can be seen in Table 5-1, engine power and noise levels increase with
throttle position.  The data in this table are taken from a presentation given at an Associated of
American Railroads (AAR) meeting in August 1973, by the Electro-Motive Division (EMD) of
General Motors Corporation and were developed from a study of local cell information for a
number of U.S. railroads. Of the approximately 27,000 locomotives in service on major railroads
(see Appendix  A), about 20,000 were built by EMD. The percent of horsepower and percent of
time given for each throttle position are typical of all locomotives.  The dBA levels vary, of course,
from engine to engine.  The example here is for a 2000 hp, EMD GP40-2 locomotive.
                                       TABLE 5-1
                         EFFECT OF THROTTLE POSITION ON
                         ENGINE POWER AND NOISE LEVELS
Throttle
Position*
Idle
1
2
3
4
5
6
7
8
% of Rated
hp for
Diesel Engines
0.75t
5
12
23
35
51
66
86
100
% of .Time at
Throttle Position
Road Loco
41
3
3
3
3
3
3
3
30
Switcher
77
7
8
4
2
1
—
—
1
dBA at
100 Ft for
2000 hp Engine
69.5
72.0
74.0
77.0
80.0
84.5
86.0
87.5
89.0*
        Three cooling fans were operating during measurement for throttle position 8, only one
        fan for other measurements.
       f Locomotive auxiliary hp only—no traction.
                                           5-10

-------
Locomotive at Rest
       During the course of this study, sound level measurements were made on individual loco-
motives at different power settings during load-cell or self-load testing. The results of these tests
are shown in Table 5-2.
       For those locomotives listed in Table 5-2, the average overall noise level for the EMD
locomotives at 100 ft is 90 dBA ±4 dBA, where the variance includes allowances for all possible
measurement and locomotive differences; for example, different observers and  different test sites.
The GE measurement for its 3000-hp locomotive is 86 dBA ±3 dBA, again allowing for all possible
measurement variations, which is slightly lower than those measured by EMD.  The reason for this
difference may be that on GE locomotives, the exhaust stacks rise about 6 in. above the hood,
while on EMD locomotives the stacks are flush with the hood and radiate sound more efficiently.
       In addition to exhaust and casing noise, the noise from cooling fans may be significant.
Figure  5-1 shows that the noise from an EMD GP-40-2 3000-hp locomotive with its engine access
doors open measured 9 dBA higher with three cooling fans running than with no fans running.
Since it was necessary to open the engine access doors during the measurements, the recorded levels
are somewhat higher than would be generated under normal operating conditions. However, there
is little doubt that cooling fan operation can significantly contribute to overall levels.  The fans on
GE engines run continuously, thus contributing to total noise levels under all operating conditions.
Fans on EMD locomotives are thermostatically controlled.
       In summary, the major components of locomotive noise are, in order of significance,
engine  exhaust noise, casing-radiated noise, cooling fan noise, and wheel/rail noise. Table 5-3
shows average levels in dBA at 100 ft for each of these sources.  Other sources, such as engine air
intake, traction motor blowers, and the traction motors themsleves have noise levels too far below
the other sources to be identified. Also, Rootes-blown engines have an unpleasant "bark", which
does not show up in any generally used method of measurement.

Locomotive in Motion
       Another method of characterizing locomotive noise is doing so as a locomotive passes by a
fixed point during normal operation. Levels recorded in this manner contain all sources of loco-
motive noise discussed previously.  Measurements of this nature are meaningful, since this is the
noise that is emitted into the community.  Unfortunately, the specific parameters that affect  the
level of noise produced are not easily controlled. These include horsepower, velocity, throttle
setting, and number of locomotive units coupled together.  However, by recording the sound  levels
of a large number of passby events, typical levels may be established.
       Figure 5-2 and Table 5-4 display the results of approximately  105 passby events. As indi-
cated, locomotive passbys range from 74 dBA to 98 dBA when measured at 100 feet.
       Figure 5-3 shows, for the same events, the maximum sound level as a function of the ve-
locity.  There does not appear to be a definitive relationship between speed and maximum locomo-
tive noise.
       Figure 5-4 relates, again for the same events, the maximum sound levels as a function  of
velocity and number of locomotives. There does not appear to be a definitive relationship between
the number of coupled locomotives and the noise emitted.
       The measurement of locomotive passby events is explained in Section 7.
                                           5-11

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                  TABLE 5-2
        STATIONARY NOISE EMISSION DATA FOR
GENERAL MOTORS AND GENERAL ELECTRIC LOCOMOTIVES
Locomotive
Identification
EMD-SW1500
EMD-F7A
EMD-SW1500
EMD-SW1500
EMD SD 9
SD 4328
EMD 25014
SD9
EMD-GP/SD38
EMD 5077
GP 38-2
EMD
GP 38-2 535
EMD
GP 38-2 535
EMD 41 15
72635-1
GP 38-2
EMD 41 11
72735-12
GP 38-2
EMD 4053
5806-4
GP 38-2
EMD 4050
5806-1
GP 38-2
EMD 4508
SD24
SD 35 1921
EMD 29355
SD35
EMD 1952
29340
SDP35
EMD FP/SD-40
Horsepower
1500
1500
1500
1500

1750

1750
2000

2000

2000

2000


2000


2000


2000


2000

2400
2500

2500


2500
3000
Loading
Conditions
T
T
T
T

T

—
T

S

S

T


S


S


S


S

T
T

T


S
T
Aspiration
—
—
—
—

RB

RB
—

RB



—


TC


RB


RB


RB

TC
—

TC


TC
—
Throttle Setting
0
—
66*
69*
—

68

70
—

65

67

66.5


66*


63*


62*


61*

68
69

68


70
72
8
84.5**
86
92*
93

89

—
91.5

91

88.5

88.5


91


90


88


89

86.5
86

88


88
89.5
Reference
3
1
1
3

11

10
3

7

7

7


8


8


8


8

9
7

8


8
3
                     5-12

-------
                TABLE 5-2 (Cont'd)
        STATIONARY NOISE EMISSION DATA FOR
GENERAL MOTORS AND GENERAL ELECTRIC LOCOMOTIVES
Locomotive
Identification
EMD
GP 40 3049
EMD
GP 40 301 8
EMD
GP 40 3182
EMD
GP 40 3195
EMD
GP 40 3156
EMD 15 59
32623
GP40
EMD 15 62
32960
GP40
EMD-GP40-2
EMD 31 15
SD45
EMD 3124
SD45
EMD
SD 45-T2
SP9212
EMD
SD45
GEU25
GE 38573
4300
GE 1472
38417
U30C
GE1581
37970
U30C
Horsepower

3000

3000

3000

3000

3000


3000


3000
3000

3200

3200


3600

3600
2500

3000


3000


3000
Loading
Conditions

T

T

T

T

T


T


T
T

S

S


S

T
T

—


S


S
Aspiration

—

—

—

—

—


TC


TC
—

TC

TC


TC

—
—

TC


TC


TC
Throttle Setting
0

64.5

69.5

67

68.5

67


69


68
70*

68

70


72

—
—

72


66*


65*
8

88

88.5

85.5

88

88


92


87
88*

90

90


94

90.5
86*

—


89


87
Reference

7

7

7

7

7


8


8
7

8

8


11

3
5

10


8


8
                      5-13

-------
                TABLE 5-2 (Cont'd)
       STATIONARY NOISE EMISSION DATA FOR
GENERAL MOTORS AND GENERAL ELECTRIC LOCOMOTIVES
Locomotive
Identification
GE 1473
38418
U30C
GEU30
GE3811
U33C
GE8717
U36C
38879
GE U36B
1759
GE U36B
1825
GEU36B
1780
GE U36B
1855
GE U36B
1832
GE U36B
1815
GE 1767
37430
U36B
GE 1796
37792
U36B
GE 1766
37429
U36B
GE 1771
37434
U36B
GE 1764
37427
U36B
Horsepower


3000
3000

3300


3600

3600

3600

3600

3600

3600

3600


3600


3600


3600


3600


3600
Loading
Conditions


S
T

S


S

S

S

S

S

S

S


S


S


S


S


S
Aspiration


TC
—

TC


TC

—

—

—

—

—

—


TC


TC


TC


TC


TC
Throttle Setting
0


67*
—

68


72

68

67

66

66

65

64.5


66


67


67


67


67
8


87
86*

90


91.5

91

93

90.5

85.5

89.5

90


87


91


93


91


94
Reference


8
4

8


9



7

7

7

7

7


3


8


8


8


8
                     5-14

-------
                                 TABLE 5-2 (Cont'd)

                      STATIONARY NOISE EMISSION DATA FOR
             GENERAL MOTORS AND GENERAL ELECTRIC LOCOMOTIVES
Locomotive
Identification
GE1526
38048
U36B
GE1800
37796
U36B
GE U36B

Horsepower


3600


3600
3600
Loading
Conditions


T


S
s
Sample Size
Aspiration


TC


TC
—

Throttle Setting
0


66


68
64.5
47
8


90


92
90
51
Reference


8


8
7

      S   -  Self Load        *Data taken at 50 ft.;
      T   -  Load Cell  '         6 dBA added
      TC -  Turbo Charged  **Pre-1960 muffler
      RB -  Rootes Blown

REFERENCES TO TABLE 5-2
           Idle
Range   61-73 dBA
Mean    67.3  dBA
Standard
Deviation  2.45 dBA
 Throttle 8
84.5-94 dBA
89.3   dBA

 3.36  dBA
 1.    R. A. Ely, "Measurement and Evaluation of the Impact of Railroad Noise Upon Communi-
      ties," BBN Report No. 2623, August 1973.

 2.    E. K. Bender and R. A. Ely, "Noise Measurements In and Around the Missouric Pacific
      Centennial Yard, Fort Worth, Texas," BBN Report No. 2648, October 1973.

 3.    Electromotive Division of General Motors, presentation to American Association of Rail-
      roads, August 8, 1973.

 4.    General Electric, presentation to American Association of Railroads, August 8, 1973.

 5.    J. W. Awing and D. B. Pies, "Assessment of Noise Environments Around Railroad Opera-
      tions," Wyle Laboratories Report WCR-73-5, July 1973.

 6.    E. J. Rickley, Department of Transportation, Transportation Systems Center, unpublished
      data.

 7.    M. Alakel, C. Malme, M. Rudd, Bojt Beranek and Newman Inc., unpublished data.

 8.    EPA Region IV study of locomotive noise, unpublished data.

 9.    EPA Region VII study of locomotive noise, unpublished data.

10.    EPA Region VIII study of locomotive noise, unpublished data.

11.    EPA Region IX study of locomotive noise, unpublished data.
                                        5-15

-------
Figure 5-1.  Effect of Fan Noise on the A-Weighted Spectrum of EMD
          GP40-2 Locomotive Noise at 55 ft (Engine Access Doors
          Open)
                       TABLE 5-3
 SOURCE CONTRIBUTIONS TO LOCOMOTIVE NOISE LEVELS
          (Based on Prediction Techniques of Ref. 4)
Source
Exhaust
Casing
Cooling Fans
Wheel/Rail I
at 40 mph J


Locomotive only
Total train
dBAatlOOFt
(Throttle 8)
86-93
80-85.5
80-84
78
81
                          5-16

-------
                         DIESEL-ELECTRIC LOCOMOTIVES
100
9CF

80
70
UJ
LU
g 60
0
UI
UJ
VE PASS-BYS EX
Ln
O
i
§ 40
u.
O
2
U
(E
S 30
20
10
n
— x—














105 MEASUf


X
xx













CEMENTS




X
X
X
X


















xx

X
X
J


















X

X
X

X


















xx
X
70
           75
                       80          86           90
                           PEAK dB(A) AT 100 FT.
95
            100
              Figure 5-2. Diesel-Electric Locomotive Passbys
                                5-17

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                              TABLE 5-4
   LOCOMOTIVE PASSBY NOISE EMISSION LEVELS MEASURED AT 100 FEET
                            (sec Figure 5-3)
dBA
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96 •
97
98
Road Noise Studies
I
1




1
2

2
4
3
3

1
2
1
2
4
2
3
4
3
1

1
II
1




1



1
1
1

2


3

1


1



III





2



1


1
3

2
2

4
2
3
2

2
1
IV


2

1
1

2
2
2
3
4

2
3
1

2

1

1

1

TOTAL
2

2

1
5
2
2
4
8
7
8
1
8
5
4
7
6
7
6
7
7
1
3
2
 I.  Department of Transportation - Office, of Noise Abatement
 II.  Department of Commerce — National Bureau of Standards
III,  Wyle Laboratories
IV.  Environmental Protection Agency - Office of Noise Abatement and Control
                                5-18

-------
120
no
100
 90
 80
 70
 60
\ DIESEL
  \
   \
                  /  XN
                          V   \!
                     ELECTRIC
                         V           __
                            ""
                                                                               TURBOTfiAIN
                                                                                Ts^A/
                                                                 METROLINER
              CONVENTIONAL PASSENGER AND FREIGHT
                                                                          HIGH SPEED PASSENGER
                                           _L
                                                 _L
_L
  10
            20
                       30
                                 40
                                           50         60        70
                                                  SPEED (mph)
                                                                          80
                                                                                    90
                                                                                              100
                                                                                                       110
                           Figure 5-3.  Peak Locomotive Noise Level vs. Speed

-------
        110
        100
on
K)
o
      8
LLt

UJ
        80
     *v4P
                	FIVE & SIX
                	THREE
                	FOUR
                	TWO
                	ONE
        70
        60
          10
             20
30
40
50
60
70
80
90
                                             SPEED (mph)
            Rgure 5-4. Relationship Between Maximum Noise Level and Number of Coupled Locomotives

-------
Locomotive Noise Abatement
       Locomotive noise abatement may be grouped into two broad categories:

       1.    Abatement by equipment modification
       2.    Abatement by operational procedures.

Abatement By Equipment Modifications
       Mufflers. Since locomotives contribute most of the noise of railroad operations and since
exhaust noise dominates locomotive noise, the first step in reducing locomotive sound levels is to
require that locomotives be fitted with an effective muffler. This section contains muffler manu-
facturer estimates of various factors affecting the feasibility of supplying both new and in-service
locomotives with mufflers. (Please refer to Appendices G, I, M, and  N for discussions of muffler
design, space availability, nonrailroad muffler applications, and AMTRAK experience with muffled
locomotives.)
       One such factor is the amount of back pressure a muffler creates.  Back pressures on the
engine may affect its performance and life to a small extent. The engine must pump against the
back pressure, thereby reducing the power that can be distributed to propel the train. Normally,
this degradation in performance is about 1.0 percent when back pressures are held within manufac-
turer limits. Back pressure may shorten engine life because when gases with increased temperature
and density exhaust into a region of high pressure, they raise the temperature of exhaust valves and
turbochargers. The following information on back pressure and its effects was determined by
muffler manufacturers.

Engine Type                Back Pressure                      Effect

Rootes Blown          47.5 in. H2 O measured
                       at engine exhaust port

Turbocharged          5 in. H2 O measured at          10° rise in turbocharger
                       exhaust stack                  temperature
                                                     20-hp loss on 3000 hp engine
                                                     0.6% increase in fuel consumption

       Mufflers have no appreciable effect on exhaust emissions; muffler-equipped locomotives
give off insignificant incremental amounts of NOX, CO, and smoke (EMD (1973)).
       Three manufacturers with experience in fabricating mufflers for locomotives have indicated
that their products will materially assist the railroads in complying with the proposed regulations:
Donaldson of Minneapolis, Minn.; Harco Engineering of Portland, Ore.; and Universal Silencer of
libertyville, 111. The following are these manufacturer's estimates of the attenuation that could be
achieved with their mufflers alone, without any allowance installation, and the amount of back
pressure they create.
                                          5-21

-------
       Donaldson has had experience with the Chicago and Northwestern Railroad in equipping a
locomotive with an off-highway truck type of muffler. The results were:

       •    Muffler Cost*       -     approximately $800 for two mufflers
       •    Back Pressure       —     further testing necessary

       Harco Engineering has achieved the following results for a switcher locomotive. The muf-
ler is fitted to a Harco spark arrester [20].

       •    Attenuation        -     approximately 5 dBA**
       •    Muffler Cost        -     $75

       The results for road locomotives are:

       •    Rootes Blown

                Attenuation    —     approximately 10 dBA**
                Muffler Cost   -     $750

       •    Turbocharged:

                Attenuation    -     approximately 10 DBA**
                Muffler Cost   -     $1000
                Back Pressure  —     13-20 in. H2 O (EMD claims that the back pressure is too
                                     high)

       Universal Silencer has built mufflers for EMD locomotives (3 DRG and 40 AMTRAK).
According to EMD (presentation at AAR meeting, 1973) these mufflers achieved:

       •    Attenuation        —     9-10 dBA at full power
       •    Muffler Cost        -     approximately $1200
       •    Back Pressure       —     3 in. H2 O

       The estimated overall noise that would result from equipping various locomotives with
mufflers that give 5 and  10 dBA attenuation in throttle 8 is indicated in Table 5-5.
 *Muffler cost figures are given in 1973 dollars.
**This measurement was performed by the manufacturer.


                                          5-22

-------
                                     TABLE 5-5
   LOCOMOTIVE NOISE LEVELS EXPECTED FROM EXHAUST MUFFLING, THROTTLE 8
Locomotive Type
EMD 1000-hp Rootes Blown
Switcher
EMD 1500-hp Rootes Blown
Switcher
EMD 2000-hp Rootes Blown
Road Locomotive
EMD 3000-hp Turbocharged
Road Locomotive
GE (or Alco) 3000-hp
Turbocharged Road
Locomotive
EMD 3600-hp Turbocharged
Road Locomotive
GE (or Alco) 3600-hp
Turbocharged Road
Locomotive
5 dBA Exhaust Muffling
Total Noise
Level
(dBA)
86.0
88.0
89.0
86.5
87.5
87.5
88.5
Total
Attenuation
(dBA)
4.0
4.0
4.0
3.5
3.0
3.5
3.0
10 dBA Exhaust Muffling
Total Noise
Level
(dBA)
82.0
84.0
85.0
84.5
86.5
85.5
87.5
Total
Attenuation
(dBA)
8.0
8.0
8.0
5.5
4.0
5.5
4.0
*Because of problems integrating with spark arrester.

        Muffler manufacturers have said that they could supply fully developed and tested muffler
 systems for all locomotives by the following dates within the 4-year period allotted for design,
 development, and installation:
        HARCO
            Switchers
            Road
        DONALDSON
            All types
        UNIVERSAL SILENCER
            Turbocharged Locos
            Rootes Blown
            Switchers
1 January 1974
1 January 1976
1 January 1976
1 January 1976
1 January 1977
1 January 1978
                                        5-23

-------
 EMD and GE have said that they could fit mufflers on new locomotives by the following dates.

       EMD
            Turbocharged                               1 January 1976
                            Road
            Rootes Blown                               1 January 1977
            Switchers                                   1 January 1978*
       GE
            Turbocharged                               1 January 1976

       EM and GE agree that mufflers can be incorporated in new locomotives. The cost of instal-
 ling mufflers on locomotives must be compared with a total cost of $300,000 to $400,000 per
 locomotive (GE and EMD presentations to AAR meeting, 1973).  The following methods would be
 used by each locomotive manufacturer in fitting mufflers on new engines.

       •    New GE Road Locomotives.  Mufflers would be installed above the engine, and the
            hood roof would be raised 8 in. A locomotive would still clear the required 15-ft,
            7-in. gauge. Cost * = $1500 per locomotive.

       •    New EMD Road Locomotives. Turbocharged - The muffler would be installed over
            the turbocharger.  Mountings would have to be changed, as would the roof structure,
            brake cabling, and extended range dynamic brakes.  Cost = $2500 per locomotive.

            Rootes Blown - The muffler would be integrated with the spark arrester. There
            would be changes to the dynamic brake contactors, roof structure, and coolant piping.
            Cost = $3000 per locomotive.

       •    New EMD Switchers. The muffler would be integrated with the spark arrester, but
            EMD is not quite sure how.  Cost = $200-$500 (estimate based on Harco figures).

       •    Retrofitting Older Locomotives.  Retrofitting mufflers on locomotives involves finding
            out how many of each type of locomotive are still in service and adopting muffler
            installation procedure to the peculiarities of each model.

       Table 5-6 illustrates the distribution of switchers in service, categorized by manufacturer.
*Cost estimates cited here for fitting new locomotives with mufflers are based on 1973 quotations
as given by EMD and GE and are expressed here in 1973 dollars.  For a complete discussion of new
locomotive muffling costs please refer to Section 9.
                                          5-24

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                                       TABLE 5-6
                         SWITCHER LOCOMOTIVES IN SERVICE
Manufacturer
EMD

ALCO
GE
Baldwin, Lima Hamilton
Fairbanks Morse
Year Built
1940-59
1960-present
1940-61
1940-58
1946-56
1944-58

No. in Service
3200
1100
950
116
415
220.
TOTAL 6000
       Few new switchers are being built, only about 120 per year, since switchers appear to run
indefinitely. Furthermore, old road locomotives can be downgraded for switching use.
       Most switching locomotives built before 1960 were equipped with mufflers, but after 1960,
railroads generally fitted spark arresters instead.
       In general, there does not seem to be any difficulty in fitting a muffler to the exhaust stack
above the hood of a switcher. This has already been done in many cases with spark arresters, result-
ing in some loss in visibility for the driver. Harco has designed and tested a muffler that integrates
with its spark arrester. The Harco muffler costs $75. However, this unit may have inadequate
muffling for the regulation or too high a back pressure. Keeping this in mind, EPA estimates the
cost of other spark arresters to be $200 to $500 plus 1 man-day of labor for installation.
       The 8758 EMD Rootes-blown road locomotives built before 1 January 1972 have less space
for mufflers than the new model GP/SD 38-2. Care must be given to the siting of mufflers, but
installation is considered to be possible. The dynamic brake grids will have to be re si ted, and the
roof structure will have to be modified. Railroads might have changed exhaust systems on rebuild-
ing. Discussions with a representative from Penn Central have led to the following cost estimates
for fitting each of these older models with a muffler. Please refer to Section 6 for a comprehensive
discussion of retrofit costs.

       Muffler  =   $1500
       Labor   =   25 man-days ($/man-day=$46.40)
       Parts     =   $200-$500

Labor covers the resiting of dynamic-brake grids, plumbing  and cabling, modifying the roof struc-
ture, and installing the muffler.
       Mufflers that produce 5 to  10 dBA of exhaust muffling are currently feasible. It is important
that a muffler be designed to give as good muffling at idle as at full power, since locomotives idle
much of the time.  Unless other noise sources on the locomotives are also treated, the net locomotive
quieting will be only about 6 dBA due to contributions from these sources (see Table 54).
       Mufflers could be developed and ready for production by January 1976.  The manufacturers
have sufficient capacity to produce the mufflers required.
                                           5-25

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        Cooling Fan Modification.  The next contributor to locomotive noise that may be treated
 is the cooling fan. Cooling fan noise is essentially aerodynamic noise resulting from the air move-
 ment created by the fan. Methods of treatment include increasing the diameter of the fan, adjusting
 clearances between blade and shroud, and varying the pitch of the blade.  Although fan modifica-
 tions are feasible, the application of fan retrofitting has not been developed for locomotives. Fur-
 ther, the impact of such a requirement could not be assessed with regard to cost and the effect on
 the total noise.

        Engine Shileding.  The vibration of the engine casing is a significant component of the total
 locomotive noise.  On a limited basis, work has been done to reduce the noise from this source by
 adding acoustic panels to the engine, stiffening the engine casing, and using sound-absorbing mate-
 rials. This technique has not been developed to the extent that it could be applied to locomotives
 at this time.  Due to new data that demonstrates the dominant effects of casing-radiated noise at
 idle, the regulation as proposed has-been amended to raise allowable long term idle emissions from
 67 to 70 dBA.  Please refer to Appendix F.

 Noise Abatement By Operational Procedures
       Parking Idling Locomotives Away from Residences.  One of the most frequent complaints
 about railroad noise is that locomotives are left idling overnight.  Railroads are reluctant to shut
 down locomotives, except during their monthly inspection, because:

       •    Shutting down and starting locomotives require a special crew.

       •    Engines do not contain any antifreeze in  their cooling systems and would have to be
            heated in cold weather.

       •    Locomotive engines are likely to leak cooling fluid into the cylinders, which could
            damage an engine on starting if precautions were not taken to drain it.

        Railroads are sometimes rather careless about where idling locomotives are left. Frequently
 they are parked on the edge of a rail yard close to residences. With a little effort,  locomotives
 could be parked near the center of a rail yard, where they would be less troublesome to neighboring
homes.

       Speed Reduction.  The power needed to pull a train increases almost  directly with speed,
but the noise of a given locomotive increases rapidly with speed.  Thus,  one could achieve some
reduction  by lowering the speed limit for trains passing through residential areas.  For example,
the throttle settings of the locomotives of passing trains would  generally be lower, and, thus, the
locomotive noise would be reduced. Further, other noise sources, such  as wheel/rail noise, would
also be reduced.
       This  noise reduction method may not be generally practical, except perhaps in special urban
areas, since the net effect would be to slow the movement of train traffic. The cost to the railroads
of lower speeds  has not been calculated.


                                            5-26

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       Ban on Night Operations. Many freight trains, particularly in the eastern United States,
operate at night. Their noise is most disturbing at this time, since the background noise is lowest
and people can be awakened from sleep.  Thus, a significant impact on the annoyance resulting
from the train noise can be made by banning night operations. However, such a ban on night oper-
ations would frequently be impractical, since trains are scheduled for markets that open in the
morning and the trains are loaded during the previous day. The resulting burden on the flow of
interstate commerce could be extensive.

       Use of More or Larger Locomotives for a Given Train. One paradox emerged from the
model of locomotive noise presented earlier. A large locomotive in a low throttle position devel-
ops less noise than a small locomotive in a high throttle position, even when the two develop the
same horsepower. For example, a 3600-hp locomotive in throttle 4 generates 15 dBA less noise
than a 2000-hp locomotive in throttle 8.  Thus, a considerable noise reduction is achieved by using
a 3600-hp engine to haul  a train requiring only 2000-hp.  Similarly, a 9-dBA reduction  could be
obtained by using four 3600-hp locomotives with lower throttle settings to pull a train that nor-
mally requires two 3600-hp locomotives, but which operate at high throttle settings.
       This noise reduction technique is considered to be impractical in general, since  the extra
hauling power required is large.  However, this method could be used in some situations, such as
switching operations. Locomotive engineers could use low throttle positions rather than gunning
the engine in throttle 8.

Electric/Gas Turbine Locomotives
       There are other means of train propulsion, apart from diesel-electric, currently  in use on
American railroads. All-electric and gas turbine locomotives are becoming more popular, particu-
larly in the Northeast corridor.  Rickley, Quinn, and Sussan have measured the wayside noise
levels of the Metroliner, Turbotrain, and electric passenger and freight trains. The levels at 100 ft
are given in  Table 5-7.  In general, levels do  not exceed 88 dBA. For those trains, namely two
Metroliner trains and one standard passenger train, exceeding 88 dBA, it is felt that the cause was
the wheel/rail interaction phenomena as  opposed to locomotive engine-generated noise, per se, since
these vehicles travelled at rates of speed at which rail noise is likely to predominate. (See discus-
sion which follows.)
       Thus, in passby situations, non-diesel-electric locomotive noise is well below that of diesel-
electric locomotives, and the former are likely to comply with any regulation written for the latter.
However, in the case of gas turbine locomotives, the Agency could not obtain data on  stationary
noise levels  and, as such, has exempted them from compliance with the stationary standards.
Stationary standards for gas turbine locomotives may be promulgated in the future.

Wheel/Rail Noise
       Rail car noise includes all sources of train noise other than that produced by the locomo-
tive. These sources are

       •   wheel/rail interaction
        •   structural vibration and rattle
        •   refrigerator car cooling system noise.

                                             5-27

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                                         TABLE 5-7
              NOISE LEVELS FROM ELECTRIC AND GAS-TURBINE TRAINS
Train
Metroliner





Electric Pass
Electric Freight
(2 Locos)
Turbo train
-


No. of
Cars
4
4
4
6
4
6
6
3
5
5
3
3
Direction
South
South
North
North
North
North
South
South
East
West
East
West
Speed
(mph)
106
110
106
110
80
84
84
49
97
91
89
104
SPL(dBA 100ft)
89
89
84
84
78
80
90 (wheel/rail)
88
85
85
84
88
       Of these sources, the interaction of the wheel and rail is the major component. As discussed
in Reference 43, this source is generated by four mechanisms:

       •    Roar
       •    Impact
       •    Flange rubbing
       •    Squeal.

       Roar describes the noise that predominates on welded tangent track. It is believed that
roar is due to roughness on the wheels and rails.
       Impact noise refers to the noise produced by wheel and rail discontinuities such as wheel
flats, rail joints, frogs and signal junctions. This noise is characterized by a clickety-clack sound
and may cause significant increase in wayside noise.
       Flange rubbing describes the sound made when the flange contacts the rail and squeal does
not occur. This noise is characterized by a low-frequency grinding sound. It could be caused by a
stick-slip phenomenon or by roughness on the flange and rail head.
       Squeal is a high pitched noise produced when a train negotiates a tight curve.  Three possi-
ble ways in which squeal can occur are:

       1.    Differential slip between inner and outer wheels on a solid axle.
                                          5-28

-------
       2.   Rubbing of the wheel flanges against the rails.
       3.   Crabbing, or lateral motion of the wheel across the top of the rail.

       Structural vibration and rattle emanate from the car bodies and couplings. Noise from
these sources may be distinguishable in a slowly moving train.  Normally, however, this noise com-
bines with the other sources of car noise and is not readily distinguishable.
       Refrigerator cars are railroad cars used to transport perishable freight requiring refrigera-
tion. It is necessary for the cooling equipment to operate continuously when the car is loaded, and
also when the car is empty but a load is anticipated.  This cooling equipment usually contains a
diesel engine, sometimes with muffler (of undetermined adequacy), to drive a compressor.  These
engines are similar in size and performance to engines used in other applications in a muffled con-
figuration.
       It is believed that the muffler industry could supply the additional muffler requirement for
rail refrigerator cars.  However, application consideration would also have to include space availa-
bility and installation and replacement costs. The maximum noise level from this source is approxi-
mately 75 dBA at 50 ft [40]. When a train is moving, the noise levels emitted from a refrigerator  .
car cannot  be distinguished from overall train noise; however, if the train stops or if the cars are
held over, the continuous operation of the compressor engine may be a source of undesirable
noise.
       Refrigerator cars parked with then- cooling systems running, as they often are in marshal-
ling and humping hards, may cause noise problems, but only in places where refrigerator cars are
parked near noise-sensitive areas. At this time, such localized problems can best be controlled as
a part of railroad yard noise control, through measures such as parking refrigerator cars away from
noise-sensitive areas or installing noise barriers, rather than by requiring modifications to the entire
refrigerator car fleet. For an expanded discussion of reefer car noise please refer to Appendix O.
       Typical measured levels of rail car noise are illustrated in Figures 5-5, 5-6, and 5-7.  Figure
5-8 indicates that the A-weighted wheel/rail noise level varies as 30 log  V, where V is the train ve-
locity. This relationship primarily describes the roar component of the noise. The higher levels
present are most probably indicative of impact, flange rubbing and squeal noise.

Wheel/Rail Noise Abatement
       A number of techniques have been suggested to reduce noise from railroad  cars operating
on open track. In most cases, testing has been limited and, thus, the results regarding effectiveness
are inconclusive.
       Grinding of train wheels and rail would reduce roar noise by reducing the amplitude of the
excitation.  Bender and Heckl [44] report differences of approximately 6 dBA  between noise
levels for ground and unground rails on the Munich Subway.  The  important parameter to control
during grinding is irregularities having wavelengths on the order of 0.5 inch to 1.0 foot, rather than
the micro-surface finish. Such wheel irregularities (wheel flats) can be  controlled by spinning the
wheel during grinding. For rail, it is more difficult because running a vehicle with a grinding wheel
attached slowly over the rails causes the grinder to move vertically in response to the vertical
motion of  the vehicle wheels.
                                             5-29

-------
        95

     m  90


     Si  85
     O
     m
     5  80


     UI75


     fro
     V)
     O 60
   • ZERO GRADE
-  O ZERO GRADE, EMPTY CARS
   A UP 1 % GRADE
   A DOWN 1% GRADE
               SPL [dBA] AT 50FT«75 + 30LOG[V(MPH)/20] -
                                           1   I  I
         10       15     20   25  30  35  40   50  60  70 80 901OO
                               SPEED(MPH)(V)

 Figure 5-5. Wheel/Rail Noise Measured on Level Ground and on a 1% Grade
too
                            I       I	1	1	1	1   I   I   I  I   I
                                    MKENGER,
                                    EQUIP.
                                             • B8N
                                             § EMBLETON AND THIESSEN
                                             A WYLE
                                             O TSC
SO
         IS
                 >3     SO    93   40
                     SPEED (MPH)  (V)
                                                45   80  65  60 65 TO 75 M
                 Figure 5-6. Measured Wheel/Rail Noise
                               5-30

-------
    110
   100
    90
§
5
<
CD
TJ
Ul
Ul
O
Z
I
O
Ul
O
3   70
    -
    60
                                                                        PEAK	
                                                                         AVG ••• — BOLTED RAIL
                                                                         MIN	
                                                                        PEAK
                                                                         AVG
                                                                         MIN
                                                                                    • WELDED RAIL
             CONVENTIONAL FREIGHT & PASSENGER
                                                            I
                                                                                            HIGH SPEED PASSENGER
      10.
                20
30
40
SO
   60

SPEED (mph)
                                                                      70
                                                      80
                                                                                           90
                                                                100
                                                                                                               110
  Figure 5-7. Average, and Minimum Rail-Wheel Sound Level vs. Speed for Typical Railroad Cars on Welded and Bolted Rail

-------
        The use of resilient wheels has undergone considerable development since they were in-
 vented in. 1889.  There are now four different designs available:

        1.   Penn Cushion wheels, available in the U.S. from Penn Machine Co., Johnstown, Pa.

        2.   Acousta Flex wheels, marketed by the Standard Steel Division of Baldwin-Lima-
            Hamilton Corporation, Burnham, Pa.

        3.   SAB resilient wheels, marketed in the U.S. by American SAB Company, Inc.,
            Chicago, Illinois.

        4.   P.C.C. wheels, made by Penn Machine Co., Johnstown,  Pa.

        The Penn Cushion and Acousta Flex wheels are similar in principle.  Both utilize an elasto-
 meric ring between the rim and the hub of the wheel. The SAB and  PCC wheels also are similar to
 each other in principle.  In these wheels, the rim is part of a steel disc, and the hub assembly con-
 sists of one or more parallel steel discs. The rim disc is connected to the hub assembly via rubber
 elements that deform as the wheel is loaded radially. The experimentation and data for resilient
 wheels on rapid transit cars indicate that such wheels would be of negligible benefit for reducing
 railroad freight car noise. Freight cars operate principally on tangent track, where resilient wheels
 are least effective.
        Another technique explored is wheel damping. B. F. Goodrich Company constructed a
 wheel with a layer of viscoelastic damping material bonded to the inside of the wheel rim and
 covered with a bonded steel constraining layer. This treatment is said to have eliminated screech,
 reduced far field noise obtained on tangent track by up to 2 dBA at high speeds, and attenuated
 rail vibration.  Some limited experiments by B. F. Goodrich showed  that use of an unconstrained
 viscoelasf c layer resulted in no significant noise reduction. However, the Toronto Transit Com-
 mission found a  12  to IS dBA squeal noise reduction when applying unconstrained damping layers.
 Use of a four-layer damping configuration on a BART prototype car had no significant effect on
 interior and wayside noise on tangent track, but eliminated some screeching on curved track.
 Reductions of 20 dBA in screeching noise and 4 dBA for nonscreeching noise were realized for
 curved track.
       Rail  welding is a method that can be used to reduce the noise caused by the discontinuities
 at rail joints. On the average, it can be expected  to reduce wayside noise by  as much as 3.5 dBA.
 However, maximum levels are as high on welded  rail as on bolted rail (see Figure 5-8). Other
 advantages of welded rail are the potential for less maintenance and a decrease in average rolling
 resistance. Both are due to the absence of rail joints.
       Rail damping is a technique that has undergone only limited testing.  A damping compound
 is applied to the nonrunning surfaces of the rails, which should shorten the length of rail that
vibrates when a wheel passes over it.  At this time, experimentation is so limited that no conclu-
 sions can be  reached as to the effectiveness of this technique.
       In  summary, although there are some new techniques and systems that show a degree of
promise, the only available methods today for reducing moving rail car noise emissions is through
the maintenance  practices of car wheel and rail grinding, in addition to the use of welded rail.  For
                                           5-32

-------
a discussion of the applicability of track and rail safety standards to noise, please refer to Appen-
dix P.

Retarder Noise
       Within rail car classification yards, several thousands of cars are moved in each 24-hr period,
as trains are assembled/disassembled. Two general methods are used for car movement:

       1.    Small switcher locomotives are used to maneuver (one or more cars) and to create
            rail car vehicle velocity prior to release for self-movement to pre-selected tracks.

       2.    Heavy duty pusher locomotives push rail cars up an incline and over a hump,
            where the cars are released to travel on their own to predetermined yard
            locations.

       As a result of the technique used in hump yards,  a single rail car or several rail cars coupled
together may be traveling at 10 to 15 mph and accelerating while moving down the hump.
       To manage  the rail car(s), retarders are used to reduce car(s) speed or to stop them. In the
process of slowing or stopping the car(s) intense noise, characterized as a squeal, is often generated.
Figure 5-8 shows the amplitude distribution of noise associated with railcar movement through
retarders.  Noise levels as high as 120 dBA at 50 feet have been observed.
*o
EVENTS
w
O
0 20
0
|
10

0
.
-

-


—


0








1 1 1 1 1









| 	 [






VMM^^M
1 1 1 1 1
90 100 110
1 1
-

••
_T— I


1




120 M

Ul
Ul
"I
fc
10 H
Ul
£
3 °"
8
                               SOUND LEVEL AT 50FEET [dBA]

                     Figure 5-8. Retarder Squeal Amplitude Distribution
                                           5-33

-------
        Although studies [36, 24] have been conducted to determine the mechanism of wheel/
 retarder noise generation, a thorough understanding of the phenomenon is not yet at hand. It is
 thought that the intense wheel squeal is the result of excitation of the rail car wheel at its resonant
 frequencies.  Apparently, the noise levels emitted by the car wheels are influenced by car type, car
 weight and loading, type of wheels, structure and composition of the retarder, and the decelerating
 force that the retarder applies to moving cars.
        According to the Federal Railroad Administration, there are approximately 130 hump yards
 in this country. A listing of the current in-use hump yards by location, railroad, and number of
 classification tracks is shown in Appendix C.

 Retarder Noise Abatement
        Though the mechanisms of wheel/retarder noise are not fully understood, several methods
 to control the noise are thought feasible. One method, namely, the use of barriers, would control
 the noise once it is generated. In other words, it would minimize the noise propagation efficiency,
 while four methods  would control noise at the source; i.e., minimize noise generation efficiency.

        1.   Retarder lubrication
        2.   Use of ductile iron wheel shoes
        3.   Use of releasable inert retarders
        4.   Retarder control by computers.

        While the  five methods cited are thought to be possible alternatives for retarder noise con-
 trol, much further study is required to assess the benefits and costs associated with each method.
 To date, known benefit and cost information associated with the aforementioned methods are
 summarized as follows.

 Benefits
        The only completed study that models the impact on people of retarder noise reduction was
 of the Cicero Yard outside of Chicago. (See Appendix D.) The results of that study showed
 that the reduction of retarder noise levels by 20 dBA allowed about 200 more people to be ex-
 posed to less than an Ljn of 65 dBA. The maximum reduction that would be experienced by any
 of the 200 people would be a 2 dBA change in Ldn.  If retarders were completely silenced, the
 noise reduction would benefit only 200 more people (total of 400) as per the preceding criteria,
 according to the study.
       Although it is not altogether  accurate to project a study of a single yard to a national im-
pact, if the assumption  was made that Cicero Yard is typical of all rail yards, approximately 26,000
more people would be exposed to less than an L^n of 65 dBA.
       By reducing locomotive exhaust noise by 10 dBA in the Cicero Yard, approximately twice
the benefit was realized (400 people less than 65 L(jn) than with the 20-dBA reduction in retarder
noise, according to the study.
                                           5-34

-------
Costs*
       •    Barriers (material costs of initial installation only)

            1.   $70 to $ 100 per linear foot.
            2.   $75,000 to $ 150,000 per yard.
            3.   $9.6 to $19.1 million for railroad industry.
            4.   Maintenance/replacement costs unknown.
            5.   Space and safety hazards unknown.
            6.   Down time and track modification costs are unknown.

       •    Source Control

            1.   Lubrication Systems (excludes maintenance/operation costs)

                a.   Specific costs unknown, estimated by industry to be $375,000 to
                     $750,000 per retarder system (master plus 4 to 8 group retarders) or
                     5 to 10 percent of total capital investment.

                b.   Estimated initial cost of new equipment on basis—$ 150 million
                     (assuming 200 retarder systems)

                c.   Maintenance and operational down time and mofification costs to
                     track system are unknown.

            2.   Ductile Iron Shoe

                a.   Initial cost ($37 per foot) is twice that of regular retarder shoes.

                b.   Ductile shoes wear 10 times faster than regular retarder shoes.

                c.   Estimated additional cost for using ductile iron shoes to replace
                     present shoes is $150,000 per retarder system.

                d.   Estimate of national cost impact to industry is $150 million
                     (assuming 200 retarder systems).

                e.   Yard down time is not included in this cost estimate.

            3.   Releasable Inert Retarders

                a.   Conversion of nonreleasable inert retarders to releasables cost $7,500
                     per retarder, not including labor, down time, or operation costs.
 "The cost of shutting down a yard or part of a yard during installation or maintenance of these
 systems could double or triple the estimated costs.

                                            5-35

-------
                 b.   The number of nonreleasable inert retarders in use is unknown. Gross
                      estimate is 20,000.

                 c.   Estimate of national cost to convert is $ 150 million.

             4.   Computer Control of Retarders

                 a.   Computer control of retarders seems practicable only at the newer
                      yards, where computer control systems were installed when the yard
                      was built.

                 b.   There are approximately 40 computer controlled yards.

                 c.    The cost, during new construction of a yard, for computer control of
                      a retarder system is $2.25 million.

                 d.    Cost of feasibility of retrofitting a yard with compuer control is
                      unknown.

                 e.    If hardware installation costs were assumed to triple the new installa-
                      tion cost, the national cost impact for retrofit of existing yards for
                      computer control would be $800 million, assuming 120 retarder
                      systems.

Car-Car Impact Noise
       The time histories of car-car impact noise illustrated in Figure 5-9 show some features of
the physical phenomena that accompany car-car'impact. The initial impact of the car couplers
causes a crack, as illustrated by the sharp rise in sound level in both parts of the figure.  The high-
frequency portion of the mechanical energy  fed into couplers often excites an entire car body. The
second time-trace in the figure shows how, as the resulting vibrational energy decays exponen-
tially, the radiated noise falls off proportionally.  The time-trace for a tank car hitting two loaded
flat bed cars shows the  noise  sometimes generated by secondary impacts as cars pull away from
each other and coupler slack is subsequently taken up. The  time-trace for the noise measured
eight cars away from a point of impact shows how the energy from an impact can propagate along
a chain of cars.

Warning Devices
       This source of noise includes bells, horns, and whistles, which are sounded to warn pedes-
trians and motorists that a train is approaching a grade crossing. The noise level at 50 ft due to
either a horn or a whistle is 105 dBA ±10 dBA. Of prime consideration in addressing these sources
of noise is the measure of safety that they provide.
       Methods of noise abatement for warning devices have not been fully evaluated.  Some
localities have required  that the devices not be sounded, while others have required the  opposite.
                                           5-36

-------
law
O
JO
AJ
(\J
0 120
O
0
o
CO 110
1 1
_J
UJ
UJ
J 100
o
z
o
90c
1 1 1 1 1


—







at 10 feet
Box Car into
String of Cars 	

1
|
1
1
H i i i i
> 2 4 6 8 1O 12
TIME (seconds)
IOW
o
(VI
0 120
O
0
4)
V.
m no
i
-j
UJ
UJ
"J 100
O
15
O
to
90c
1 1 1 I 1
at 10 feet
—

—





Piggyback into
Empty Freight 	



-

i i i i
) 2 4 6 8 10 12
                                                 TIME   (seconds)
Figure 5-9. Car-Car Impact Noise Time Histories (Sheet 1 of 2)

-------
             130
v
w
oo
          o
          .o
          
    90
                              I      I      I     I      I
                              at 10 feet
                              Tank Car into
                              Two Loaded Flat Bed Cars
                           ll   II   I
                                       ii
I
                                 6     8    10    12
                                 TIME  (seconds)
                                                                            no
                                                                CM
                                                                o 100
                                                                O
                                                                q
                                                                o
                       GO  9O
                       •o
                                                                         UJ
                                                                         >
                                                                         Ul
                                                                         o
                                                                         o
                                                                             80
                                              14
           16
                                                          18
                                                                             70
                                   I     I      I      I
                                   at 10 feet
                                   Eight Cars Away from
                                   Covered Hopper into Eight
                                   Covered  Hoppers Connect-
                                   ed to a String of Box Cars
246     8     10
TIME  (seconds)
                              Figure 5-9. Car-Car Impact Noise Time Histories (Sheet 2 of 2)

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Various alternatives for controlling their noise include requiring reduced levels, specifying direction-
ality, or limiting the times and areas in which the devices should be sounded.

Public Address Systems
       Although the frequency of occurrence of noise from loudspeakers in railroad yards is
sporadic and unpredictable, the level of the noise from speakers is comparable to the level of noise
from other sources in the yards.  Where abatement is desired or necessary, more speakers could be
strategically located so that less volume is necessary, or railroad yards could follow the recent trend
to two-way radio communication.

Maintenance and Repair Shops
       The noise from shops conies mainly from running the engines of stationary locomotives.
Other noises from maintenance and repair shops are overshadowed by the noise from retarders,
car impacts, and locomotives moving about the yard.  If controls are applied to noise from loco-
motives, car impacts, and retarders, that part of shop noise not due to locomotive engines may
then emerge as a significant part of the remaining noise.

Refrigerator Cars
       These cars are railroad cars used to transport freight that requires refrigeration.  It is neces-
sary for the cooling equipment to operate continuously when the car is loaded and when the car
is empty but a load is anticipated.  This  cooling equipment usually contains a diesel engine, some-
times with muffler (of undetermined adequacy), to drive a compressor. These engines are similar
in size and performance to engines used in other applications in a muffled configuration. It is
believed that the muffler industry could supply the additional muffler requirement for rail refriger-
ator cars.  However, application consideration would also have to include space availability and
installation and replacement costs,  (see additional discussion under Wheel/Rail Noise in this sec-
tion, as well as Appendix O.)

Auxiliary Diesel Engines
       Passenger locomotives and cars are frequently equipped with (1) diesel engines to drive an
alternator supplying electric power to the train, and (2) steam generators (on the locomotive) to
supply heat for the train. AMTRAK is purchasing new locomotives with auxiliary diesel engines on
board; some of their club cars already have them.
       Data on noise levels.from auxiliary engines were provided by the Illinois Railroad Associa-
tion (IRA) in its submission to Docket ONAC 7201002. The IRA cited noise levels of two auxi-
liary engines as measured by the Chicago and Northwestern Railway.  These engines were Cummins
V-block diesels running at 1800 rpm so as to generate 60-Hz electricity. Noise measurements were
taken with no load on the engines; they would have been higher if a load had been applied.  The
measured levels were 58 and 55 dBA at 100 ft from the locomotive.
                                            5-39

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                                       Section 6

               GENERAL PROCEDURE TO MEASURE RAILROAD NOISE
INTRODUCTION
     The EPA did not propose or publish a detailed measurement methodology as part of its
original rule making establishing railroad noise emission levels. The Agency did reference it in the
Notice of Proposed Rule Making (NPRM) and described it in detail in the Background Document
to the proposed railroad noise regulations.  The proposed regulation did not include a detailed
measurement methodology since it was contemplated that it would be included as part of the
compliance regulation to be issued by the Department of Transportation (DOT).
     Section 17 of the Noise Control Act of 1972 places the responsibility for promulgation of
compliance regulations with the Secretary of Transportation. The EPA develops and promulgates
standards that provide the basis from which DOT develops the requisite compliance regulations.
Such EPA standards must be sufficiently detailed as to the requisite  definition that there is no
question as to the standard promulgated. Proper definition of such standards is particularly critical
with respect to railroad noise because there is no generally accepted measurement scheme in use
throughout the affected industry, unlike the situation in other industries subject to Federal noise
regulation, such as the Motor Carrier industry.
     A measurement methodology, dealing with the enforcement aspects of railroad noise measure-
ment, will still be developed by the Department of Transportation.  The Agency, however, as a
result of its own further analysis and after consideration of the questions and suggestions received
during the public review process, has decided to incorporate additional measurement criteria into
the standards as an  added subpart of the final regulation being promulgated herein. Such measure-
ment criteria contain specifications for ambient noise, wind noise, test site conditions, test equip-
ment orientation, and other parameters necessary for the consistent and accurate measurement of
the sound levels specified in the regulation.
     The criteria were derived  from  the EPA methodology which was published in the Background
Document to the proposed regulation and commented on as a result of the public review process.
That methodology has since undergone thorough review by  concerned Agencies of the Federal
government, including the Department of Commerce/National Bureau of Standards, and the
Department of Transportation/Federal Railroad Administration, and been revised by the EPA in
response thereto.
     If issue is taken with the data supporting the railroad standards proposed by EPA, such data
submitted to the Agency in support of the respondent's position should be based on measurement
methods or procedures similar to those of the Agency. The equivalency of correlation between
different measurement practices must be clearly explained, to permit adequate comparisons with
the data and levels in regulation.
                                           6-1

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     It is recommended that technically competent personnel select the equipment to be used for
 the test measurements. Proper test instrumentation and experienced personnel are essential to
 obtain valid measurements. Operating manuals or other literature furnished by the instrument
 manufacturer should be referred to, for both recommended operation of the instruments anrf
 precautions to be observed. Following are the measurement criteria as they appear in the regulation.

 SUBPART c - MEASUREMENT CRITERIA
 201.20  Applicability and Purpose
     The following criteria are applicable to and contain the necessary  parameters and procedures
 for the measurement of the noise emission levels prescribed in the standards of Subpart B of this
 regulation. These criteria are specified in order to further clarify and define such standards.

 201.21   Quantities Measured
     The quantities to be measured, under the test conditions described below, are the A-weighted
 sound levels for fast meter response as defined in the American National Standard SI .4-1971.

 201.22  Measurement Instrumentation
     (a)  A sound level meter that meets, as a minimum, all the requirements of American National
         Standard SI .4-1971 for a Type II instrument shall be used with the "fast" meter response
         characteristic.

     (b)  In conducting the sound level measurements, the general requirements and procedures of
         American  National Standard SI .13-1971 shall be followed. This publication is available
         from the American National Standards Institute, Inc., 1430 Broadway, New York, New
         York  10018.

     (c)  A microphone wind-screen recommended by the manufacturer of the sound level meter or
         microphone of an alternate sound level measurement system shall be used.

201.23  Acoustical Environment, Weather Conditions and Background Noise
     (a)  The standard test site shall be such that the locomotive or train radiates sound into a free
         field over the ground plane.  This condition may be considered fulfilled if the test site
         consists of an open space free of large, sound reflecting objects, such as barriers, hills,
         sign-boards, parked vehicles, locomotives or rail cars on adjacent tracks, bridges or build-
         ings within the boundaries described by Figure 6-1, as well as conforms to the other
         requirements of Section 201.23.

     (b)  Within the complete test site, the top of at least one rail upon which the locomotive or
         train is located shall be visible (line of sight) from a position 4 feet above the ground at
         the microphone location, except as provided in Section 201.23(c).
                                           6-2

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                              100'
                                       MICROPHONE
                                       LOCATION
Figure 6-1. Test Site Clearance Requirement for Locomotive Stationary,
          Locomotive Passby, and Rail Car Passby Tests
                              6-3

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     (c)  Ground cover such as vegetation, fenceposts, small trees, telephone poles, etc., shall be
         limited within the area in the test site between the vehicle under test and the measuring
         microphone such at 80 percent of the top at least one rail along the entire test section
         of track be visible from a position 4 feet above the ground at the microphone location;
         except that no single obstruction shall account for more than 5 percent of the tot«d
         allowable obstruction.

     (d)  The ground elevation at the microphone location shall be within plus 5  feet or minus 10
         feet of the elevation of the top of the rail at the location in-line with the microphpne.

     (e)  Within the test site, the track shall exhibit less than a 2 degree curve or  a radius of
         curvature greater than 2,865 feet (873 meters). This paragraph shall not apply during
         a stationary test. The track shall be tie and ballast, free of special track work and bridges
         or trestles.

     (f)  Measurements shall not be made during precipitation.

     (g)  The maximum A-weighted fast response sound level observed at the test site immediately
         before and after the test shall be at least 10 dB(A) below the level measured during the
         test.  For the locomotive and rail car pass-by tests this requirement applies before and
         after the train containing the rolling stock to be tested has passed.  This background
         sound level measurement shall  include the contribution from the operation of the load
         cell, if any, including contribution during test.

     (h)  Noise measurements may only  be made if the measured wind velocity is 12 mph (19.3
         kph) or less.  Gust wind measurements of up to 20 mph (33.2 kph) are  allowed.

201.24  Procedures for the Measurement of Locomotive and Rail Car Noise
     (a)  Microphone Positions
         (1)  The microphone shall be located within the test site according to the specifications
              given in the test procedures of sections 201.24 (b), (c) and (d), and shall be posi-
              tioned 4 feet above the ground. It shall be oriented with respect to the  sources in
              accordance with the manufacturer's recommendations.

         (2) The observer shall not stand between the microphone and the source whose sound
             level is being measured.

     (b)  Locomotive Stationary Test (Load Cell Test)

         (1)  For stationary locomotive tests, the microphone shall be positioned on a line per-
              pendicular to the track at a point 100 feet from the track centerline at the longi-
              tudinal midpoint of the locomotive.
                                            6-4

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     (2)  The sound level meter shall be observed for thirty seconds after the test throttle
         setting is established to assure operating stability. The maximum sound level
         observed during that time shall be utilized for compliance purposes.

     (3)  Measurement of locomotive noise shall be made with all cooling fans operating.

(c)   Rail Car Pass-by Test

     (1)  For rail car pass-by tests, the microphone shall be positioned on a line perpendicular
         to the track 100 feet from the track centerline.

     (2)  Rail car noise measurements shall be made when the locomotives have passed a
         distance of 500 feet or 10 rail cars beyond the point at the intersection of the track
         and the line which extends perpendicularly from the track to the microphone loca-
         tion, providing any other locomotives are also at least 500 feet or 10 rail  car lengths
         away from the measuring point.  The maximum sound level observed in this manner
         which exceeds the noise levels specified in Section 201.13 shall be utilized for com-
         pliance purposes.

     (3)  Measurements shall be taken on reasonably well maintained tracks.

     (4)  Noise levels shall not be recorded if brake squeal is present during the test
         measurement.

(d)   Locomotive Pass-by Test

     (1)  For locomotive pass-by tests, the microphone shall be positioned on a line perpen-
         dicular to the track at a point 100 feet from the track center line.

     (2)  The noise level shall be measured as the locomotive approaches and passes by the
         microphone location.  The maximum noise level observed during this period shall
         be utilized for compliance purposes.

     (3)  Measurements shall be taken on reasonably well maintained tracks.
                                       6-5

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                                        Section 7

                    ECONOMIC EFFECTS OF A RETROFIT PROGRAM
       The imposition of a railroad locomotive muffler retrofit program, as proposed in the  '
Notice of Proposed Rule Making, elicited several public comment docket submissions that
contained technical and economic data that conflicted significantly with that appearing in the
original background document.  The principal areas of conflict involve disparities in determina-
tion of the best available technology as it exists today and the resultant costs of its application.
       There is a further complicating factor in that the  available space configurations within
many locomotives have been altered over the years due to the addition and modification of
various locomotive components such as dynamic braking systems and spark arresters. As a
result of this practice, there are numerous and diverse locomotive configurations, each possessing
specific peculiarities that must be accounted for in a retrofit program. The implications of this
diversity of locomotive configurations and the accompanying disagreement concerning available
technology and the cost of its application (i.e., labor rates, capital costs of new facilities, etc.)
have given rise to cost of compliance figures ranging from the original EPA estimates of $80 to
$100 million to industry estimates approximating $400 to $800 million.
       The purpose of this portion of the background document is to present the economic
analyses that the Agency has performed concerning a locomotive retrofit program:

       •   The analysis of the economic effects of retrofit as presented in the original back-
           ground document.

       •   Subsequent economic cost and impact analyses of retrofit that constitute refinements
           to the original analysis.

       These studies have been unable to reconcile the differences between Agency and the Rail-
road Industry positions on the economics of retrofit.  Although the generation of additional
information concerning the availability of technology might allow the Agency to reconcile such
widely varying retrofit cost estimates, the collection of such data would be a costly and time con-
suming process. Further that process may produce a retrofit cost estimate remaining substantially
high relative to the resultant public health and welfare benefits, especially since railroad noise has
not been identified as one of the major sources of noise in the environment.
       Such factors were the major reasons for the Agency decision to remove the retrofit require-
ment from the final regulation.
                                         7-1

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INITIAL ECONOMIC ANALYSIS
The Impact on the Railroad Industry
General Impact
       The engineering data gathered from discussions with various manufacturers and railroad
operating personnel were used to estimate the direct cost of muffler retrofit by locomotive type and
manufacturer. The differences in construction between switcher and road locomotives required
that these be treated separately. The three categories of direct cost are mufflers, additional hard-
ware, and labor.  Since each make of locomotive is unique, it was necessary to make separate
analyses of each type.  The cost are "Shown in Table 7-1. The retrofit costs associated with the
various types of locomotives are based on the designs of several common types, which make up
about 90 percent of the population. For some locomotives, retrofit costs, may be significantly
higher than the figures shown here.  This may be the case, for example, for several hundred units
that, although originally conforming to one qf the common designs, have been heavily modified
during service so that their configurations now present difficult hardware problems to a muffler
installer.  Also, there are some 1000 older road locomotives manufactured by Alco and Fairbanks-
Morse and owned by a total,of 22 railroads, the design of which may render muffler installation
difficult. The Agency has been advised that these units  are, in fact, in the process of being replaced.
Thus, this discussion assumes that such units will be retired from service during the compliance
period.
                                      TABLE 7-1
                         MUFFLER COSTS* PER LOCOMOTIVE
                    (Source: Manufacturers' and Operators' Estimates)
Time of Installation
New Production
Muffler Only
Additional Hardware
Labor @5.80/hr
Total
Locomotive Manufacturer and Type
GM
Road
$3000 (RB)
2500 (TC)
1500
200- 500
464-1163
$2164-3163
GM
Switcher
$200 - 500
200 - 500
46
$246 - 546
GE
Road
$1500
1500 -
1500-2500
187
$3187-4187
Other
Road

1500
1500-2500
187
$3187-4187
Other
Switcher

500 - 800
46
$546 - 846
 (RB)  = Rootes Blown
 (TC)  = Turbocharged
                                         7-2

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       The estimates of the direct cost of mufflers and additional materials were gathered from
locomotive and muffler manufacturers. The sources of the data on required labor input were loco-
motive manufacturers, muffler manufacturers, and management personnel of selected railroads.
       An hourly wage rate of $5.80 was arrived at by taking total compensation of maintenance
personnel as reported in annual Interstate Commerce Commission (ICC) summaries and dividing
by total hours worked.*  Although this wage rate probably includes some overtime compensation,
it may be an accurate reflection of the true labor cost, since some retrofitting may be done at the
overtime rate.  We assume that the current mix of straight time and overtime will be used in the
retrofit program.
       No capital costs for maintenance facilities were assigned to the retrofit program.  Annual
compensation statistics and discussions with the Association of American Railroads indicate that
the roads have been generally cutting back their maintenance staff over the last decade, while not
necessarily reducing the size of their plant.**  Frequently, therefore, excess physical capacity would
be available for a retrofit program. In an economic, although not necessarily an accounting sense,
such excess capacity can be utilized at zero cost.
       The next step was to determine how many of each type of locomotive are in service.  The
May 1973 issue of Railway Locomotives and Cars lists, by railroad, the make  and horsepower of
each locomotive in service. In most cases, the horsepower of the engine could be used to determine
whether it is a switcher or road locomotive.  General Motors (GM) produces both a 1500-hp switcher
and a 1500-hp road locomotive, but because road locomotives outnumber switchers by about seven to
one, we assumed all GM 1500-hp locomotives to be road locomotives. This biased the cost esti-
mates upward by a small amount. Table 7-2 shows the distribution of locomotives by type and
manufacturer, both nationally and for each  of the  three ICC regions.
       Total direct cost of the retrofit program was obtained by multiplying the cost per loco-:
motive by the number of locomotives and is given  in Table 7-3 in terms of minimum and maximum
costs for each region and for the entire nation. Normally, some locomotives would be retired
during the compliance period and, therefore, would not incur retrofit costs. (Their replacements
would presumably have been quieted at the factory.) This consideration has not been included here,
because it is difficult to forecast replacement rates in the light of an endemic shortage of motive
power such as presently exists.  If we assume, instead, that past retirement rates (about 2000
units per year from 1965 through 1969) are cut in half due to the shortage of locomotives, this
will result in 5000 fewer units needing muffler retrofit for a 5-year compliance period and 2000
fewer over a 2-year period. The total cost estimates projected would  then be high by about 20
percent and  8 percent for the two compliance periods, respectively.
* All railroad data presented in this section come from Interstate Commerce Commission,
Transportation Statistics in the U.S., (1971) [67]unless otherwise specified.
**Sources in the AAR state that this may not be the case for roads that have recently modernized
their plants and that may have divested themselves of some unneeded facilities. In these cases,
according to the AAR, the cost of installing or renting the needed plant and equipment may
significantly increase retrofit costs. Unfortunately, precise estimates of capital stock in main-
tenance facilities do not exist.
                                          7-3

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                               TABLE 7-2
DISTRIBUTION OF LOCOMOTIVES BY MANUFACTURER, TYPE, AND REGION
 (Source: "Railway Motive Power, 1973," Railway Locomotives and Cars, May 1973)
Manufacturer
and
Type
GM Road
GM Switcher
GE Road
Other Road-
Other Switcher
Region
Total
16,155
2,811
1,930
1,737
1,504
East
(29 Roads)*
7,006
1,462
878
1,052
734
South
(8 Roads)*
2,026
304
230
289
139
West
(22 Roads)*
7,123 ,
1,045
822
396
631
*Number of roads in each district obtained from ICC, op. cit. Other listings of roads may not tally with
 this one, due to varying methods of accounting for mergers, subsidiaries, etc.
                               TABLE 7-3
              TOTAL DIRECT COST OF RETROFIT PROGRAM
                           (Millions of Dollars)

Region

East
max.
min.
West
max.
min.
South
max.
min.
National
max.
pin.
Locomotive Manufacturer and Type
GM
Road

$22.160
15.161

22.530
15.414

6.411
4.386
GM
Switcher

$0.798
0.360

0.570
0.257

0.166
0.075
GE
Road

$3.676
2.798

3.442
2.620

0.963
0.733
Other
Road

$4.405
3.353

1.659
1.262

1.210
0.921
Other
Switcher

.$0.621
0.401

0.534
0.345

0.118
0.076


-

Total


$31.660
22.073

28.735
19.898

8.868
6.191

69.263
48.162
                                  7-4

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       The annual direct costs in Table 7-4 were derived from Table 7-3 by dividing total cost by
the number of years allowed to complete the retrofit program. In addition, the annual cost for
2- and 5-year compliance periods is shown as a percentage of the 1971 net operating revenue.
It should be noted that we are assuming 2 and 5 years beginning at the time the muffler becomes
available.  Generally, mufflers will not be available until 2 years after the regulation is promulgated,
so that the 2-year program will not be completed until 4 years after promulgation, and the 5-year
program until 7 years after promulgation.
       It appears that the direct cost of a retrofit program will not constitute a significant burden
on the railroads. Total direct cost is invariant with respect to compliance period, although annual
cost is not. Annual cost is, therefore, probably a more relevant measure of the financial impact on
the railroads.
       The direct cost of retrofitting mufflers is only part of the total cost, however. If retro-
fitting requires that locomotives be taken out of service, and if the railroads have no excess capac-
ity with respect to locomotives, then there will be some loss of revenue. At present, most railroads
are operating a full capacity. The number of locomotives has decreased slightly from 1965 to 1973
(from 27,988 to 27,041) although total horsepower did increase from 52 million in 1971 to 55
million in 1973. It appears, therefore, that capacity has remained about constant or has decreased
slightly  while demand has increased.  It seems unlikely that the present high volume of grain
shipments will continue beyond a year. Other factors, however, indicate that the current high
levels of capacity utilization will probably continue into the future.
       One of the developments that will tend to keep rail transportation at a high level of
capacity utilization is the "energy crisis." A general fuel shortage favors the railroads over other
modes of transportation. An increase in coal output,  which seems inevitable, would stimulate
rail freight volume.  Coal, because of its low value per ton, is hauled almost exclusively by rail.
       A further impact of a general fuel shortage would be to potentially degrade the quality and
cost of truck transport relative to rail service. Restricted speed limits could induce delays and
uncertainties in truck schedules.  Fuel price increases would have a greater adverse impact on
trucks than on rail, since trucks use 3.2 times as much diesel oil per ton-mile of freight. As a result
transportation demand would tend to shift from trucks to rail.  The net effect of these considera-
tions is to support the assumption that railroads will be operating at close to full capacity for the
next 5 or so years. This means that locomotive downtime due to retrofit may likely result  in lost
revenues.
       One way in which operators may overcome this problem is to buy new locomotives to
take the place of those being retrofitted. Such a procedure would virtually eliminate the indirect
cost associated with the retrofit. This is an option, however,  only if the locomotive manufacturers
can produce the extra units. At present, according to locomotive manufacturers, locomotive pro-
duction is below demand even though production facilities are operating at full capacity. It is
reasonable to assume that conditions of motor power shortage relative to demand for transpor-
tation will persist throughout the compliance period,  resulting in lost revenue when units are
removed for retrofit.
        The time lost may be significantly reduced by scheduling retrofits during regular locomo-
tive maintenance. Nationally, the average maintenance cycle is 4 years for an intermediate overhaul
and 8 years for a heavy overhaul.  The length of the cycle for an individual railroad is a function of
locomotive mileage.  Table 7-5 shows the national average adjusted regionally to reflect different
                                           7-5

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                     TABLE 7-4
ANNUAL DIRECT COST OF 2- AND 5-YEAR RETROFIT PROGRAMS
Region
National
East
South
West
Total Direct Cost
(thousands of dollars)
2-Year
Max.
34,632
15,830
4,434
14,368
Min.
24,082
11,037
3,096
9,949
5-Year
Max.
13,853
6,332
1,774
5,747
Min
9,633
4,415
1,238
3,980
Cost as Percentage of
Net Revenue
2-Year
Max.
1.35
2.04
0.82
1.09
Min.
0.94
1.42
0.58
0.75
5-Year
Max.
0.54
0.82
0.33
0.44
Min.
0.38
0.57
0.23
0.30

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                                        TABLE 7-5
                AVERAGE MAINTENANCE INTERVAL BY DISTRICT (years)
                   (Source: 1971 ICC Statistics and Operators' Estimates)
Type of
Maintenance
Intermediate
Heavy
Regional Average Maintenance
Interval (Years)*
National
4.0
8.0
East
5.5
11.0
South
4.0
8.0
West
3.5
7.0
"These figures do not include the effects of deferred maintenance as practiced by some roads in financial distress.
  average locomotive miles per year. The maintenance cycle is shortest in the West, where
  locomotives travel more miles per year and longest in the East, where miles per year are lowest.
         An intermediate overhaul generally takes about 2 to 3 days, while a heavy overhaul takes
  about 14 days.  The estimated time required to retrofit a muffler ranges from 3 days for a GM
  road locomotive to 1 day for a switcher. Table 7-6 shows the number of lost locomotive days
  charged to retrofit under different conditions.  Line 1, for example, gives lost days by type of
  locomotive if the locomotive is taken out of service specifically for retrofit.  One can see that
  there are no lost days for any type of locomotive if all retrofitting is done during heavy overhaul.
                                       TABLE 7-6
                            DAYS LOST DUE TO RETROFIT
                     (Source:  Manufacturers' and Operators' Estimates)
Basis of Retrofit*
If done by itself
If done during regular
intermediate overhauls
If done during regular
heavy overhaul
Locomotive Manufacturer and Type
GM
Road
3
1
0
GM
Switcher
1
0
0
GE
Road
2
0
0
Other
Road
2
0
0
Other
Switcher
1
0
0
"Assumes no lost time due to travel to and from shop and no muffler retrofitting done during emergency repairs.
                                           7-7

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       As is shown, the total lost locomotive time due to muffler retrofits depends on how many
locomotives can be treated during the normal maintenance cycle.  Table 7-7 shows the expression
used to compute total lost days for each line or district.  The first term represents the time lost by
GM road locomotives undergoing intermediate overhaul. The remaining three terms account for
time lost by those locomotives that will not be due for routine maintenance during the compliance
period and that, therefore, must be specially called in for muffler retrofit. (Recall from Table 7-6
that, except for GM road locomotives, units undergoing intermediate or heavy overhaul will
experience no extra time lost due to retrofitting a muffler.)
       The equation in Table 7-7 has been used to compute lost locomotive days for each region.
These have been summed  to give a national total. The figures are shown in Table 7-8. Two com-
pliance periods are used to illustrate the decrease in lost time with a longer retrofit period. We
see from the table that increasing the period from 2 to 5 years results in a decrease of the lost
locomotive days per year by 70 percent.

                                     TABLE 7-7
                  EQUATION FOR TOTAL LOST TIME PER DISTRICT
LT  =     N,
                  GM
      +    NGM  X
                                x Y x  *
                                        3days
                                m
                 NGEO  x(  i -T?-
                 L          \      lm
                                    X   1 day
                                                        for
                                                                   >  0
          N
                  GM
                       X  l dav
for
('-f
where
         N
          SW
                m
                     = number of years allowed for retrofit
                     = number of GM road locomotives
                     = number of GE and "other" road "locomotives

                     = tota* num^er °f switchers of all makes
                     = time interval for "Intermediate" maintenance
                                       7-8

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                                      TABLE 7-8
          LOST LOCOMOTIVE DAYS BY REGION AND COMPLIANCE PERIOD
Compliance
Period
2-year
program
5-year
program
Lost
Locomotive
Days
Yearly
Total
Yearly
Total
Region
National*
17,048
34,096
2,044
10,220
East
(29 roads)
9,252
18,504
1,129
5,645
South
(8 roads)
2,143
4,286
203
1,013
West
(22 roads)
6,378
17,048
712
3,562
  'Locomotive days lost nationally is not the sum of the three regions, since the national was calculated
   using an average maintenance cycle and the regional was adjusted to reflect different utilization rates.
       A change in the compliance period affects only the number of lost locomotive days.  The
direct cost of the retrofit program does not change. If we take the total number of lost locomo-
tive days resulting from a 2-year period and assign it the number 1, then the total number of lost
days for a 3-year program is 0.76, the total of a 4-year program is 0.52, and the total of a 5-year
program is 0.29.  As the compliance period is lengthened, lost locomotive days decrease; thus, the
indirect cost of the program decreases.
       The calculations of lost locomotive days must be translated into dollar costs. A number
of problems arise in calculating the value of a locomotive.  First, should a distinction be made
between road locomotives and switchers?  It seems desirable to treat the transportation revenue
earned by rail service as being earned by both road and switch engines, since the lack of either
(if both are used to full capacity) would cause a reduction in service. We have therefore assumed
that each has the same value per day.
       Secondly, what value should be assigned to a locomotive-day? If all roads are operating
at full capacity, then removing a locomotive causes a daily loss of revenue amounting to the value of
one locomotive-day.  A locomotive-day is thus evaluated at the value of the average product.  This
technique is further justified in capital theory, which states that the value of a piece of capital is
the present value of its discounted future stream of earnings; that is, the present value of the
marginal product.
       Given the conditions just stated, the value of a locomotive-day was calculated by taking
total transportation revenue and dividing by the total number of locomotive days available.
Table 7-9 shows these calculations nationally and regionally. Table 7-10 gives estimates of the
indirect costs of a 2-  and 5-year retrofit program by incorporating the lost locomotive-days from
Table 7-8 and the value of a locomotive day from Table 7-9. Note that the shorter the compliance
period, the larger the total indirect costs. This is a  function of the increase in the number of lost
locomotive-days as the compliance period is shortened.
                                          7-9

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                 TABLE 7-9
REGIONAL ANNUAL REVENUE PER LOCOMOTIVE DAY

Total tranportation
revenue (millions of $)
Transportation revenue
per locomotive day ($)
Region
National
$12,417
1,251
East
$4,497
1,186
South
$2,121
1,256
West
$5,799
1,304
                TABLE 7-10
   ESTIMATED LOST REVENUE DUE TO RETROFIT
             (Thousands of Dollars)

Region

National
East
•South
West
2- Year Program

Per Year
21,982
10,973
2,692
8,317

Total
43,963
21,946
5,383
16,634
5- Year Program

Per Year
2,557
1,338
254
928
Total
12,785
6,690
1,270
4,640
                   7-10

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    Table 7-11 arrives at the annual net retrofit cost by combining the direct and indirect costs and
subtracting the reduction in operating costs that would occur as a result of a reduction in traffic.
Cost reductions were determined from the ICC detailed accounts and include the following:

    Account No.                                 Description

       365                                    Dispatching Trains
       367                                    Weighing, Inspection, and Demurrage Bureaus
       368                                    Coal and Ore Wharves
       371                                    Yard Conductors and Brakemen
       373                                    Yard Enginemen
       374                                    Yard Switching Fuel
       382                                    Train Enginemen
       383                                    Train Fuel
       387                                    Trainmen
       388                                    Train Supplies and Fuel
       395                                    Employees'Health and Welfare Bureaus

    The estimates of cost reductions used here are much lower than those used by the ICC.*
They have claimed that 80 percent of costs are out of pocket or variable costs. This might be true
if railroads were curtailing service in the face of falling demand. Variabel cost may constitute 80
percent of total cost, but the situation dealt with here is an unplanned reduction in capacity in
the face of full utilization of equipment.  Under these circumstances, it seems unlikely that the
railroads would curtail other operations but rather that they would attempt to offset locomotive
shortages by changes in labor and equipment usage patterns. In addition, if there are adjustment
costs and since the cutback in capacity is temporary, the railroads would be expected to respond
differently from a situation in which the reduction was anticipated to be longer. Table 7-12 gives
the total net cost of the 2- and 5-year programs. Again, it points up the cost differential associated
with different compliance periods. Much of the computed retrofit cost is the result of lost revenue
to the railroads. Figure 7-1 shows the breakdown of annual cost into direct and indirect com-
ponents for compliance periods of 2 to 5 years.
    The annual costs shown in Table 7-11 are best understood in the context of total operating
revenue for each region. Table 7-13 shows that the eastern roads would pay a higher percentage of total
total revenue toward a retrofit program than would the other regions.
*See U.S. Interstate Commerce Commission, Bureau of Accounts, Explanation of Rail Cost
Finding Procedures and Principles Relating to the Use of Costs.  St. 7-63, Washington, D.C.,
1 November 1963 and U.S. Interstate Commission, "Rules to Govern the Assembling and
Presenting of Cost Evidence," Docket No. 34013,321  I.C.C.
                                           7-11

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         TABLE 7-11
ANNUAL NET COST OF RETROFIT
      (Thousands of Dollars)
Direct Cost
2-year program
max
min
5-year program
max
min
National

$34,632
24,082

13,853
9,633
East

$15,830
11,037

6,332
4,415
South

$4,434
3,096

1,774
1,238
West

$14,368
9,949

5,747
3,980
Indirect Cost
2-year program
5-year program
21,982
2,557
10,973
1,338
2,692
254
8,317
928
Reduction in
Operating Costs
2-year program
5-year program
4,964
597
2,748
335
555
53
1,856
207
Net Cost
2-year program
max
min
5-year program
max
min

51,650
41,100

15,813
11,593

24,055
19,262

7,335
5,418

6,571
5,233

1,975
1,439

20,829
16,410

6,468
4,701
           7-12

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                                    TABLE 7-12
                     TOTAL NET COST OF RETROFIT PROGRAM
                                (Thousands of Dollars)*
Compliance
Period
2 years
3 years*
4 years*
5 years
National
Max
103,300
95,221
87,143
79,065
Min
82,200
74,121
66,043
57,965
East
Max
48,110


36,675
Min
38,524


27,090
South
Max
13,142


8,875
Min
10,466


7,195
West
Max
41,658


32,340
Min
32,820


23,505
  'These represent linear interpolations of the 2- and 5-year programs.
                                    TABLE 7-13
             ANNUAL RETROFIT COST AS A PERCENTAGE OF 1971 TOTAL
                               OPERATING REVENUE
Compliance
Period
2 years
5 years
National
Max
0.42%
0.13%
Min
0.33%
0.09%
East
Max
0.53%
0.16%
Min
0.43%
0.12%
South
Max
0.31%
0.09%
Min
0.25%
0.07%
West
Max
0.36%
0.11%
Min
0.28%
0.08%
*Net operating revenue is defined as transportation revenue minus variable transportation costs. Subtracting
 rents, taxes, and interest payments from net operating revenue gives net operating income.or profit from
 freight operations.
                                         7-13

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   60
   50
   40



z
o

= 30
 C/3
 O
 u
   20
   10
                      _L
 Q TOTAL ANNUAL COST



 O DIRECT ANNUAL COST




COST OF LOST LOCOMOTIVE DAYS
    _L
JL
                      3          4          5


                    COMPLIANCE PERIOD (YEARS)
Figure 7-1.  Cost of Retrofit Program as a Function of Compliance Period
                              7-14

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     Annual retrofit cost as a percentage of net operating revenue* gives the best indication of the
rail industry's ability to pay for a retrofit program (see Table 7-14).  Retrofit constitutes a small per-
centage of net operating revenue both nationally and regionally.  As we have seen earlier, however,
the eastern railroads will pay the highest percentage of net revenue for the retrofit program. This
partly reflects the fact that eastern roads as a group tend to earn less profit than roads in other
regions.

                                       TABLE 7-14
              ANNUAL RETROFIT COST AS A PERCENTAGE OF 1971 NET
                                 OPERATING REVENUE
Compliance
Period
2 years
5 years
National
Max
1.96%
0.60%
Min
1.56%
0.44%
East
Max
2.48%
0.95%
Min
0.31%
0.70%
South
Max
1.22%
0.38%
Min
0.97%
0.27%
West
Max
1.58%
0.49%
Min
1.24%
0.36%
     Bankrupt roads constitute a special subset for which financial and operating problems are
substantially different than for normal roads.  This subject will be treated elsewhere.
     To give a more detailed picture of the industry's ability to pay for a retrofit program, program
cost as a percent of net operating revenue has been computed for each Class I railroad (including
bankrupt roads but excluding those with negative net revenues).  Figure 7-2 shows how the rail-
roads are distributed with respect to cost-to-net revenue ratio.  The figure shows that the impact
of a 2-year program is much greater than that of a 5-year program.

The Impact on Marginal Railroads
     The adverse effects of extra operating costs is greater on firms in financial distress than those
that are healthy. This is of concern in the case of the railroads, because a number of them face
difficulties in maintaining profitable operations. It is important to estimate the number of rail-
roads that may have trouble paying the cost of a retrofit program even though the magnitudes of
the expenses involved in such a program are small relative to other expenses faced by the railroads.
(For example, a 30-percent increase in the price of diesel fuel would increase operating costs by roughly
$125 million.**  This would represent from 2.5 to 12.0 times the annual cost of a muffler retrofit
program, depending on the compliance period allowed.)
*Net operating revenue is defined as transportation revenue minus variable transporation costs.
Subtracting rents, taxes, and interest payments from net operating revenue gives net operating
income, or profit from freight operations.
**This figure is computed by using as a baseline the total cost of fuel for all Class I railroads in 1971,
which was $417 million [67 ].
                                           7-15

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                 25  -
                                       5-YEAR PROGRAM
                                                2-YEAR PROGRAM
                               1.0    1.5   2.0   2.5    3.0   3.5   4.0+

                                  PERCENT OF NET OPERATING REVENUE
Figure 7-2.   Distribution of Railroads by Retrofit Cost as a Percent of Net Operating Revenue
            for 2- and 5-year Compliance Periods. (Maximum Total Cost Assumed. Bankrupt
            Roads Included; Made with Negative Net Operating Revenue Excluded.)
                                         7-16

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       This section attempts to gauge the extent of the problem posed in paying for a retrofit
program by determining how many railroads are in financial distress. This is done by computing,
for each road, several financial ratios that are generally accepted as indicating the financial condition
of a business enterprise. A summary of the number of roads with unfavorable values for each ratio
is then given. This technique does not give a quantitative definition of which railroads cannot
afford a retrofit program.  At best, it gives a rank ordering. The cutoff value that determines
financial distress is arbitrary.
       The following financial ratios were computed:

        1.    Current assets/total assets
       2.    Operating  ratio (operating expenses/operating revenues)
       3.    Total liabilities less stockholder equity/total assets
       4.    Income after fixed charges/total assets
       5.    Retained earnings/total assets
       6.    Net income/total assets
       7.    Net income/operating revenue

       All bankrupt roads are excluded from this discussion, which is concerned only with roads
that have not been declared bankrupt but that may be in financial distress.
       In most cases these ratios parallel those used by Edward Altman [1 ]. Ratios 1  and 2 are
measures of the liquidity* of a railroad, while 2,4, 6, and 7 are measures of profitability and
efficiency. Ratio 3 measures solvency.
       With respect to ratio 1, the analysis seems inconclusive. A large number of roads had
ratios of current to total assets in excess of three standard deviations from the mean. This indi-
cates that  the distribution of values of this ratio did not approximate a normal distribution. This
being the case, ratio 1 does not constitute a valid indicator of which roads may be in distress.
       The analysis of ratio 5 (retained earnings/total assets) indicated that 14 railroads have
negative retained earnings, while 2 have zero, showing that these roads lack liquidity.  While internal
financing may not be important in the rail industry, the negative retained earnings indicate that
these roads are drawing down cash reserves.**
       The most commonly used measure of profitability is 2, the ratio of operating revenue to
operating  expenses. Three roads have  operating ratios greater than one, indicating that expenses
exceed revenue.  An additional seven roads have operating ratios more than three standard deviations
higher than the mean.  Certainly, the three roads and possibly some of the seven must be considered
to be in an adverse position. Ratios 6  and 7 are similar measures, in that a road with a negative net
income will have a negative ratio for both 6 and 7.  Six roads have negative  net incomes. In addi-
tion, two other roads must be considered to be poor performers as measured by the ratio of net
income to total assets (6).
*Liquidity is the ability of a firm to convert assets into cash.
**This may also represent an insufficient amount of funds allocated to depreciation.
                                            7-17

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        Ratio 4 indicates that nine roads have negative income and two have zero income after
 fixed charges. These roads are unprofitable by definition. The ratio of total liabilities (less stock-
 holder equity) to total assets (3) appears to have also yielded inconclusive results.  One road stands
 out as being extremely poor by this measure, and there are four other roads for which this ratio is
 greater than one.
        A word of caution should be issued in the interpretation of any ratio that uses total assets.
 Under the betterment accounting procedure, total assets tend to be inflated. However, to the
 extent that this bias is uniform throughout the Industry, it is possible to compare different roads.
 It is not possible to compare these ratios with other firms outside the rail industry.
        Table 7-15 summarizes the preceding findings with respect to the named ratios. As
 mentioned before, the table lists worst-performers as indicated by each ratio, the cutoff point
 being arbitrary.  More significant is Table 7-16, which shows how many of the railroads contained
 in the previous table appear under more than one ratio. Table 7-16 shows that 12 roads are in
 distress with respect to three or more indicators. It can reasonably be presumed that these 12, at
 least, could have difficulty in financing a retrofit program.

 The Impact on Bankrupt Railroads
        Of the 71 Class I line-haul railroads in the United States, 7 are bankrupt:  Boston and Main,
 Central Railroad of New Jersey, Erie Lackawanna,  Lehigh Valley, Penn Central Transportation Co.,
 The Reading Co., and Ann Arbor. These seven railroads operate about 20 percent of the locomo-
 tives owned by Class I railroads in the U.S. Not surprisingly, the total cost of retrofit for these,
 roads (see Table 7-17) is about 20 percent of the total cost for the entire muffler retrofit program.
        These railroads will have difficulty financing the cost of a muffler retrofit program. There
 is no question that the financial positions of these roads are bad. All seven have negative net
 income, and are'currently meeting their deficits in part by drawing down cash reserves. Many of
 these road's are currently receiving some form of subsidy, and all are in default  on interest payments,
 bonds, and  taxes.

 The Impact on Users of Rail Transportation
        The effect of a muffler retrofit program may be felt by  railroad users in either or both of
 two ways. First, the possibility exists that the railroads may  try to recover their retrofit expenses
 through a rate increase. Second, the withdrawal of locomotives from service could result in
 reduced hauling capacity and a consequent decline  in the quality of service. Either of these develop-
 ments would tend to encourage some shippers to go elsewhere for transportation services. This
 discussion examines the possible magnitude of these effects.

 The Effect on Railway Freight Rates
       The  ability of the rail industry to recapture the cost of a muffler retrofit program depends
on the characteristics of the market it faces. The establishment  of AMTRAK and the low volume
(and high price elasticity) of passenger service probably precludes the railroads from recovering any
of the retrofit costs through increases in passenger fares. Rather, increased revenues would be
more likely to come from increasing freight rates.
                                           7-18

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                                   TABLE 7-15
              NUMBER OF RAILROADS IN UNFAVORABLE FINANCIAL
                   POSITION RELATIVE TO EIGHT INDICATORS
                    (For Each Indicator, Railroads Listed in Order of
                           Increasingly Favorable Position)
              Indicator
Number of Roads in Unfavorable Position
 1.   Current assets/total assets

 2.   Operating ratio


 3.   Total liabilities (less stockholders'
     equity)/total assets


 4.   Income after fixed charges/
     total assets
 5.   Retained earnings/total assets


.6.   Net income/total assets
7.   Net income/operating revenue
Inconclusive

4 roads greater than 1 (expenses  > revenues)
4 roads between 1 and .85

3 roads greater than 1
2 roads equal 1
2 roads between .99 and .71

8 roads negative
1 road zero
13 roads  negative
1 road zero

4 roads negative
4 roads zero
2 roads positive but less than .011

4 roads negative
2 roads zero
2 roads positive but less than .031
                                       7-19

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                         TABLE 7-16
    NUMBER OF RAILROADS DESIGNATED AS BEING IN FINANCIAL
       DIFFICULTY BY ONE OR MORE FINANCIAL INDICATORS
Number of Financial Indicators,
      N, in Table 7-15
Number of Railroads Appearing
under N Indicators in Table 7-15
            1
            2
            3
            4
            5
            6
           7
           2
           6
           3
           2
           1
                         TABLE 7-17
        NET COST OF MUFFLER RETROFIT PROGRAM FOR THE
              SEVEN BANKRUPT CLASS I RAILROADS
Length of
Program
2 Years
5 years
Annual Cost
Max
$10,569,000
3,197,000
Min
$8,393,000
2,326,000
Total Cost
Max
$21,139,000
15,984,000
Min
$16,786,000
11,631,000
                            7-20

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     Freight rate increases must be approved by the ICC. Inquiries to the ICC indicate that the
Commission places no a priori limits on the magnitude of rate increases that may be requested.
It is entirely the railroad industry prerogative to decide if requests for rate increases are to be
submitted to cover the costs shown in Table 7-12. Any cost factor could form a legitimate basis
for increasing rates to recover costs. Furthermore, the ICC is considering environmental aspects in
its rate determination. As a result of litigation involving the environmental effects of various rate
structures, the ICC has prepared serveral Environmental Impact Statements showing their concern.*
     In summary, there are strong indications that the rate increases that could be requested by
railroad companies to defray the costs of noise reduction would fall within the practice of the ICC.
No a priori bias would be applied by ICC agents, and they could be expected to act with a positive
attitude toward the objective of improving the quality of the environment.
     To place the level of expenditure and possible freight rate increase in perspective, previous
cost increases and subsequent rate increases may be used for reference.  In the ICC report served
4 October 1972, in Ex Parte 281, a rate increase for railroad freight was authorized.  The railroads
claimed in their rate request that expenses had increased $1.312 billion from January 1971 to
April 1972.  The authorized rate increases were:

       •   .National Average                  3.44%**
       •    East                             3.60%
       •    South                            3.10%
       •    West                             3.44%

These increases, if fully applied, would have increased revenue by $426 million; however, the most
usual case is that they are not fully applied.  The industry estimates that only 85 percent, or $349
million, will actually be realized.***
       Since the rate increase of September 10,1972, costs have risen by $930 million.  About
80 percent of this rise has stemmed from  wage increases and increased payroll taxes. In light of
these higher costs, in April of 1973 the railroads applied for a  5-percent rate increase.  The maxi-
mum cost of the 2-year muffler retrofit program is about $51 million, which is only 5.5 percent of
the $930 million cost increase that led to the request for a 5-percent rate increase. The rail industry
claims that if the entire $930 million cost increase is to be recovered, it will require a 7.5-percent
increase in rates.****
    *See ICC Docket, Ex Parte 281 and Ex Parte 344F, Supplement 927.
   **The National average was calculated by using regional data.
  ***These figures come from estimates made by the rail industry. They assume that the elasticity
of demand is zero-an unlikely situation.  The question of elasticity is considered later in this
section.
****Again, this estimate assumes that the elasticity of demand for rail service is zero.
                                            7-21

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     The amount of the recoverable costs and the attendant freight rate increase necessary will
 depend on the elasticity of demand for rail freight.*  The annual (maximum) retrofit costs for the
 2-year program represent about 0.4 percent of 1971 freight revenue, while the 5-year (minimum)
 program represents only about 0.1 percent of freight revenue (see Table 7-13).
     Data from Friedlaender [47]  for 1961 have been used to calculate an overall rail freight demand
elasticity of-0.7. Using this elasticity, we can estimate the increase in freight rates necessary to
offset the increased costs. The freight increases are shown in Table 7-18. Also shown is the percent
these increases would represent of the 1971 average rate per ton-mile, which was $.01594.

                                      TABLE 7-18
                  RATE INCREASE THAT WOULD ENABLE RAILROADS
                          TO RECOVER RETROFIT EXPENSES
Length of
Program
2-year
max
min
5-year
max
min
Rate Increase
(Cents per Ton-Mile)

.0232
.0184

.0076
.0057
Percent of 1971
Average Freight Rate

1.46%
1.15

0.48
0.36
     These rate increases must be interpreted carefully. They were calculated by using demand
elasticities derived from 1961 data. Since then, a number of changes have taken place that would
probably increase the elasticity of demand for rail service.

     •    First, the near-completion of the interstate highway system has improved the service
          rendered by trucks and has reduced operating costs.

     •    Second, the rise in interest rates has made the cost of holding inventories higher and
          might have made shippers more sensitive to other service characteristics, causing a
          downward shift in the demand curve and potentially increasing its elasticity.
 •"Elasticity of demand is the ratio of the percent rise in quantity demanded to the percent rise
 in price.  An elasticity coefficient of-0.1, therefore, indicates that a 10-percent price increase
 would result in a 1-percent decrease in demand.
                                           7-22

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    •   Third, shifts among the various commodity classes of freight might have resulted in an
         increase in the elasticity. For example, if the price elasticity of demand for rail service
         is higher for mineral ores than for manufactured products and if the share of mineral
         ores has increased relative to manufactured product, then the overall elasticity would
         have increased.

    We have attempted to make some estimates of the new elasticity, taking into account the  shift
in the distribution of commodities. The results should be interpreted only as tentative. We have
used the 1961 elasticities for each commodity group but have weighted tham by the 1971 com-
modity distribution.
    Data from Friedlander [47] have been used to obtain the following elasticities for the five
major commodity groups:

               Commodity                                  Elasticity

            Agriculture                                         0.5
            Animal products                                    0.6
            Products of forests                                  0.9
            Products of mines                                    1.2
            Manufacturing and other                            0.7

These figures represent the pre-1964 commodity  classification used by the ICC. To determine the
current elasticity of demand, we used these commodity group elasticities and weighted them by
the current distribution of freight within these groups.  These weighting factors are:

                Commodity                                  Elasticity

             Agriculture                                        .097
             Animal products                                    .0002
             Products of forests                                 . 144
             Products of mines                                  .420
             Manufacturing and other                            .387

 To determine the distribution, it was necessary to take the current freight classifications and assign
 them to one of these categories.
      The overall elasticity was calculated to be -0.953, significantly more than the estimate of
 -0.7 obtained from Friedlander's data. Even more interesting is the distribution of elasticities by
 district. To arrive at these estimates, it was necessary to assume that the rate per ton-mile for
 each of the 1971 commodity classifications was  equal for each of the three districts.  Although
 this is not the case, we believe the errors to be small. The estimated elasticities are:

      •    East          -0.99
      •    South        -0.95
      •    West         -0.83
                                             7-23

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These figures indicate that the eastern roads, which are in financial difficulty, would have the most
trouble recovering the cost of a retrofit program.  The western roads, which, as a group, are the
most profitable, would easily recover the cost of a retrofit program.
     Given the energy crisis, however, even this tentative analysis may not be valid. As discussed
earlier, railroads use less energy per ton-mile of freight moved than trucks, pipelines, or airlines. As
a result, railroads would be impacted less than these other competitive modes by increases in fuel
costs.
     It is not possible to accurately predict at this point, the effects of any rate increases the ICC
might grant to the railroads to recover the costs of a retrofit program. The possible effects of
increased rates on demands for rail service are directly related to the energy situation. If com-
petitive modes of transportation (i.e., trucks, pipelines, and airlines)  are more severely impacted by
increased fuel rates, the fact that railroads increased their rates to cover the costs of a retrofit pro-
gram might well be insignificant.

The Effect on Quality of Service
     It has previously been shown that, to accomplish a retrofit program within a compliance
period of 5 years or less, some locomotives would likely have to be withdrawn from service in
addition to those undergoing maintenance by the usual schedules.  The number of locomotive-days
taken up in this manner is given in Table 7-19 in absolute numbers and as a percentage of locomotive
days available. If, under normal conditions, the railroads are operating at or near full capacity, then
the figures shown in the table represent the upper bound of lost freight hauling capability.

                                       TABLE 7-19
           ANNUAL LOCOMOTIVE DAYS TAKEN UP BY RETROFIT PROGRAM
Compliance
Period
2-year


5-year


Locomotive
Days
Absolute
% of Total
Available
Absolute
% of Total
Available
Region
National
17,048

.194%
2,044

.023%
East
9,252

.225%
1,129

.027%
South
2,143

.197%
203

.0187%
West .
6,378

.174%
712

.0195%
     The impact of decreased hauling capability on the various commodities shipped by rail depends
on how the railroads react to the capacity decrease.  There are two ways in which demand for rail
service can be made to equal the available supply: non-price rationing or price rationing.
     In the case of non-price rationing, the railroads could simply allow service to decline in quality
while maintaining the same rates. The resulting delays and uncertainties in the transporation
network would have differential impacts on the various commodities being shipped. Those items
                                           7-24

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highly sensitive to the quality of service will tend to be diverted to other modes of transportation.
Commodities in this category are high-value products, for which transportation charges are a small
fraction of total value, and perishables.
     Price rationing involves raising the price of service (with the approval of the ICC) to decrease
demand to the level of the new, reduced capacity.  Such a policy would affect commodities sensitive
to freight rates. Examples of these would be mineral ores and semi-finished products. Such goods
would tend to be shipped by other modes, or the quantity shipped would be reduced.
     The probable magnitude of the effect of price rationing can be estimated. Table 6-19 shows
that, in the worst case, capacity would decline by about 0.2 percent nationally. Assuming that the
elasticity of demand for rail transportation is about -0.7 gives a price rise of 0.28 percent necessary
to effect the required reduction in demand. This amounts to an average increase of 0.004 cents
per ton-mile relative to the 1971 average freight rate.  This increase is fairly small, so minimal changes
in transportation patterns may be expected as a result of the retrofit program.

Summary and Conclusions Concerning Initial Economic Analysis
Impact on the Railroad Industry
     Cost.  The cost of a muffler retrofit  program is highly sensitive to the compliance period
allowed. Maximum total cost for a 2-year program is estimated to be $103 million.  Allowing 5
years for compliance would reduce the total cost to approximately $79 million.

     Change in net revenues. The impact  of a 2-year program would be to reduce overall Class I
railroad annual net operating revenues by  about  2 percent.

     Effect on prices. For the railroads to recover the expense of a retrofit program would require
an average freight rate increase of approximately .023 cents per ton-mile in the 2-year case and
.008 cents per ton-mile in the 5-year case. These figures represent, respectively, 1.46 percent and
0.48 percent of the 1971 average freight rate.

     Effect on capacity.  A 2-year retrofit program would result in an annual loss of as many as
17,000 locomotive-days, or about 0.2 percent of the total available, for the duration of the pro-
grams. This would drop to about 0.02 percent for a 5-year program.

     Impact on marginal railroads. Approximately a dozen railroads are in financial difficulties,
as indicated by the computed values of a  number of standard financial ratios. These roads may
have difficulty in raising the funds necessary to pay for a retrofit program.

     Impact on bankrupt railroads. Seven roads are presently bankrupt, and may not be able to
finance a retrofit  program without an external source of funds. The total program cost for these
roads would be $21 million for a 2-year program and $16 million for a 5-year program.
                                            7-25

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 Impact on Users of Rail Services
     Prices. Increases in freight rates would tend to encourage some shippers to seek alternate
 modes of transportation. This would occur primarily among shippers of commodities having
 prices sensitive to transportation cost, such as semi-finished products. It is not likely, however,
 that the small rate increases foreseen by this study would cause any major hardships or dislocations.
     The energy crisis may make any railroad rate increases insignificant compared with competitive
 modes of transportation, which would be more severely impacted by rising fuel costs.

     Quality of service.  A decrease in the hauling capacity of the railroads may result in the
 diversion of some freight to other modes of transport. Which commodities would be affected
 depends on how the railroad would decide to reduce demand to the level of supply.  If rates were
 raised, the effect would be the same as discussed in the previous paragraph. If rates remained
 constant but shipping delays were allowed to develop, commodities sensitive to transit time (such
 as perishables) would be most affected.  Such diversions, however, will tend to  be localized and on
 a small scale in view of the small reductions in capacity anticipated.

 SUBSEQUENT ECONOMIC COST AND IMPACT ANALYSES
 The Cost of Retrofitting Mufflers on Locomotives
     The costs of installing mufflers on operating diesel railroad locomotives fall into three categories:

     1.   Initial direct cost, consisting of the costs of materials (including the muffler and other
          hardware), labor, capital (including the cost of new shop facilities if required), and testing.

     2.   Initial indirect cost, consisting of the net revenue lost due to taking locomotives out of
          service for retrofit  and the costs of developing suitable muffler designs.

     3.   Continuing cost, consisting of the annual costs of maintaining  mufflers and costs of
          extra fuel consumed by locomotive having mufflers.

This discussion contains detailed estimates of each of these cost categories. These estimates are
refinements of the cost estimates contained in the original Background Document, refinements
made on the basis of questions raised in EPA Docket No. ONAC 7201002, and information sub-
mitted to that docket.*
    The costs projected here are computed for muffler designs based on the analyses presented in
Appendices G and H. That is, the basic muffler designs are arrangements of expansion chambers and
baffles, with no internal sound-absorbing materials or unconventional chamber configurations.  The
mufflers are presumed to effect a 10-dB reduction in exhaust noise level while meeting manufacturer
"Costs presented here are as of 1973, the last year for which complete data are available, unless
otherwise stated. The effect of inflation would be to raise the absolute costs by 8 to 10 percent
per year, but the percentage impacts would remain unchanged.
                                           7-26

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warranty restrictions on additional backpressure (5-in. H20 for turbocharged engines, 21-in. H20 for
Rootes blown). It is also presumed that the mufflers are designed to fit the space currently available
within or above the engine hood and to require no rearrangement of major internal components
such as dynamic brake assemblies.  The feasibility of designing mufflers within these constraints
has been analyzed in Appendices G and H.

Initial Direct Costs
     The initial direct cost of a muffler retrofit program is determined by:

         The cost of materials, including mufflers and other required hardware.
         The hourly cost of labor.
         The man-hours of labor required for retrofit.
         The cost of capital equipment.
         The cost of performing noise tests.

     Cost of Materials. The primary material cost incurred in a muffler retrofit program is the cost of
the muffler itself. Since no locomotive exhaust mufflers have been manufactured on a production
basis, there are no data on the actual cost of such units. Therefore, the probable cost of such
units will be estimated on the basis of the current price  of mufflers designed for similar diesel en-
gines, but not built for locomotive applications (i.e., without size restrictions).  The example chosen
is the Maxim  M-31 silencer designed for a turbocharged 16- or 20-cylinder GM 645 series diesel
engine.  The 1975 list price of this muffler is $2206, with discounts of up to 40 percent available
for volume purchases.  This muffler averages 20-dB attenuation over the band ranging from 37.5 to
5000 Hz, measures 14.3 ft long by 4.5 ft in diameter, and weighs 3200 Ib. This unit is substantially
larger and more effective than would be required for locomotive exhausts, which need only about
a 10-dB noise reduction.  Therefore, the price shown represents a highly conservative (i.e., over-
stated) estimate of the price of mufflers for locomotives. We have chosen $1500 as a typical price
to be paid for a muffler to be installed on a turbocharged locomotive. This figure agrees with the
$1500 price price estimated for EMD  series 20, 30, 35,  39,40, and 45 locomotives by the Associa-
tion of American Railroads [20].
     The $ 1500 price  applies only to turbocharged locomotives, which, according to the analyses
of Appendix  G can have mufflers installed directly on the turbocharger outlet stack. Rootes-
blown road locomotives, on the other hand, typically have a space problem when mufflers are
added to the  exhaust line. The most effective way of quieting such units, according to the Appen-
dix G analysis, is to enlarge the existing segmented exhaust manifold collector into a single manifold-
muffler. It is estimated that the cost of this will be the cost of a replacement manifold, which is
$3690 [20],  plus $1000 to cover internal baffles and resonance chambers that may be required.
These figures give a total cost of approximately $4700 for muffling a Rootes-blown road locomotive.
      Switchers, which are Rootes-blown, do not have the space limitations of road locomotives, since
they have room for mufflers over their low hoods. Switchers, it is claimed, need their low hoods for
visibility, and mufflers would interfere with this visibility.  The first half of this statement is only
partly true, as shown by the frequent use of old high-hooded GP7 and GP9 locomotives as switchers.
The second statement is not true at all, since the volume of the muffler can be distributed over the
                                            7-27

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 length and breadth of the hood so that the vertical dimension need not be large. For example,
 a muffler having the same volume as the Maxim MSA-1 for a 12-cylinder EMD 645E engine
 (42.4 ft) could be built to have dimensions of 5 ft in width, 10 ft in length, and less than 1 foot
 in height. This muffler would easily fit over the hood of an EMD SW1500 switcher with minimum
 visibility interference.
      The cost of switcher mufflers, therefore, is based on the price of a Maxim MSA-1 muffler spark
 arrester designed for a 12-cylinder Rootes-blown GM 645E engine, such as is used on an EMD
 SW1500 switcher locomotive. The 1975 list price of this muffler is $848, with discounts available
 for quantity purchases. Therefore, $700 is selected as the  1973 price for switcher mufflers.
      Some turbocharged road locomotives will require hardware changes to allow installation of the
 muffler.*  EMD turbocharged units will require heat shielding for dynamic brake cables, larger
 turbocharger removal hatches, and heavier turbocharger exhaust ducts.  General Electric units will
 require new roofs that can accommodate the mufflers.  The material cost for these hardware changes
 is shown in Table 7-20.
                                      TABLE 7-20
      HARDWARE MODIFICATIONS AND MATERIAL COSTS FOR TURBOCHARGED
                                 ROAD LOCOMOTIVES
          Make
    Modification Required
Materials Price
          EMD
         GE
Apply new turbocharger exhaust
duct

Replace turbocharger removal
hatch

Apply heat shields to dynamic
brake cables
                   TOTAL

Apply new hood roof
                                                                   $ 8001
    3001
                                                                      251
                                                                   $1135
  $20002
 Source: Garin, p. 12 in AAR, 1974 [20].
 ^Source: Estimate of P. Baker, General Electric Co., as stated to M. Rudd, BBN, August 1973.
         The estimate assumes that the cost of body modification would include only the pur-
         chase of a new, center cab section; the original side doors would be used again.
*Rootes-blown locomotives will require no modifications, because the muffler consists simply of
a larger manifold, having no effect on the locomotive internal arrangement or cab design.
                                         7-28

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     Hourly Cost of Labor.  Computed here is the average cost of labor in railroad maintenance for
 the year 1973, the last year for which statistics are available.  The cost of labor consists of wages
 (including overtime compensation), fringe benefits, and payroll taxes.  Because these quantities vary
 depending on the quality of labor, the average must be weighted for the prevailing mix of skilled
 craftsmen and other employees. The average cost of supervisory labor must also be included.
     Presented first is the average hourly wage rate for skilled and other workers. These were
 obtained by dividing the total 1973 compensation by the total hours worked for each of the two
 labor categories. The result is shown in the third column of Table 7-21 for the three U.S. railroad
 regions.
     The next step is to determine, for each labor category, the average wage rate times an appropriate
 multiplier for fringe benefits and payroll taxes. AAR Sources [5] indicate that this  multiplier is
 1.16 for all regions. The result is shown in the last column of Table 7-21.

                                       TABLE 7-21
                AVERAGE 1973 HOURLY WAGE RATE FOR SKILLED AND
                                   OTHER WORKERS
Labor
Category

Skilled


Other

Region
East
South
West
East
South
West
Compensation 1
($ millions)
457.9
162.7
458.2
91.7
39.9
112.6
Hours Worked1
(million)
69.3
25.1
68.9
17.9
8.3
22.2
Average Wage Rate,
including Overtime
($/hr) '
6.61
6.49
6.45
5.12
4.83
5.07
Average Hourly
Labor Cost
($/hr)
7.67
7.53
7.72
5.94
5.60
5.88
 Source: Betts, 1973.

     The third step is to combine the skilled and other labor costs for each railroad region, weighting
 the average according to the appropriate labor mix. For all Class I railroads in 1973, the skilled
 crafts represented 84 percent of the hours paid for under the category Maintenance of Equipment
 and Stores.*  The remaining 16 percent were other laborers. The resulting weighted average hourly
 labor costs for each region are shown in the first column of Table 7-22. To obtain a national average,
 the regional figures are weighted according to the percentage of locomotives found in the last column
 in Table 7-22.
*Source: ICC Statement A-300, 1973.
                                           7-29

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                                       TABLE 7-22
              1973 WEIGHTED AVERAGE HOURLY LABOR COST DEVIATION
Region

East
South
West
Weighted
Average Hourly
Labor Cost 1
($/hr)
7.47
7.22
7.43
Hourly
Weighting Factor^
(% of Locomotive
Population)
36
18
46
National Weighted
Average Hourly
Labor Cost
($/hr)

7.41

   1 Source: Computation in text.
   2Source: Computed from. ICC Transportation Statisitcs, 1973.
   ^Excludes supervisory labor. Add $0.51 per hour to account for supervision; see text

     The computation so far does not include supervision. Supervisory personnel make up about
 6 percent of the labor input in the Maintenance of Equipment and Stores account, and their average
 compensation was about 15 percent higher than the average of all workers in that sector. Multiply-
 ing 0.06 X 0.15 X  $7.41 gives a figure of $0.51 per hour, which is added to the average labor cost
 to obtain a total of $7.82 per hour.

     Labor Required for Retrofit. The estimates of required retrofit labor given in the Background
 Document were based on informal discussions with railroad maintenance personnel. Since that time,
 the Association of American Railroads has submitted detailed information to the docket on this
 topic.  A summary of the labor hours by work item and the total labor cost per locomotive is given
 in Table 7-23.

     Cost of Capital Equipment. The muffler retrofit program will be carried out primarily in railroad
 shops.  If the maitenance shops do not have enough unused capacity to perform the work, they will
 have to acquire  new facilities. In the latter case, the cost of such facilities would be charged to the
 retrofit program.
     Peabody and Associates [57] have estimated that the curent level of excess capacity in rail diesel
 shops, unadjusted for possible retirements, is 14.3 percent. They calculated this figure by taking the
 level of expenditures adjusted to constant dollars for each year from 1969 to 1973 and by taking the
 year in which expenditures were highest as defining the level of full capacity. An annual productivity
increase of 1.0 percent was allowed for.
     In addition to using total maintenance expenditures as an indicator, excess capacity can be
estimated by examining the labor hours in that sector; labor hours represent a physical measure of
input.  If it is assumed that the ratio of capital to labor required to maintain locomotives did not
                                           7-30

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                                     TABLE 7-23
            LABOR MAN-HOURS AND TOTAL LABOR COST FOR MUFFLER
                                RETROFIT PROGRAM
Locomotive

Turbocharged
road

Rootes-blown
Road
Switcher
Item
Exchange turbocharger duct
and turboremoval hatch
Apply heat shields for dynamic
brake cables
Apply muffler
TOTAL
Replace manifold
with manifold silencer
Apply muffler
Man-Hours
per Locomotive^
33
9
9
51
9
9
Cost
@ $7.92/hr
$260
73
73
$406
$ 73
$ 73
     1 Source: Obtained by dividing AAR labor cost for each item (Garin, pp. 12, 16, and 17 in
             AAR 1974) by the AAR "labor rate" of $14.00. The AAR "labor rate" includes
             shop overhead; i.e., cost of capital equipment, which is treated separately in this
             development.
change from 1969 to 1973, then any decline in labor hours worked must be reflected in an equivalent
percentage of the capital equipment standing idle (barring retirements of equipment).
    During the period from 1969 to 1973, the labor input in the maintenance sector decreased
by 13 percent.  If one allows for a 1 percent annual increase in productivity in both capital and
labor, then the  predicted  13 percent excess shop capacity is increased to about 17 percent. The
labor required for the proposed retrofit program is less than 1 percent of the labor hours currently
used in the Maintenance of Equipment and Stores sector.
    One other factor to consider is the possible retirement of capital over the period 1969 to 1973.
A sample of 10 roads, which was conducted by Peabody Associates, indicated that 95 percent of the
capacity in diesel shops that existed in 1969 is still in existence today.  This figure reflects the
conservative assumption that all retirements reduced capacity while all new investment had no effect
on capacity. A more realistic appraisal would be obtained from net investment (i.e., investment minus
depreciation) less retirements. However, even with these conservative assumptions and the assumption
that the sample of 10 roads gave a true picture of the industry, there will be sufficient capacity to
complete the retrofit program, and further acquisition will be unnecessary.
                                          7-31

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      Cost of Testing. The cost of installing mufflers on locomotives includes testing each unit to
 determine whether it needs treatment. Two types of stationary tests are:

      1.   Load cell test. The generator output is connected to a bank of resistors that absorb the
          electrical output, so that the engine may be run at full throttle under load while stationary.
          This is the only test for units that do not have dynamic brakes capable of absorbing the
          generator output.  Disadvantage: stationary load cells found in railroad yards may not be
          in an acoustically acceptable environment.

      2.   Self-load test.  The generator output is dissipated through the dynamic brake resistor
          grid. Advantage:  this test can be performed at any location.  Disadvantage: on EMD
          locomotives, a separate fan cools the resistor grid; noise from this fan may bias the test
          results.

      A problem may exist in  providing enough acoustically acceptable load cells to test locomotives
 that do not have dynamic brakes. One solution:  railroads can buy portable load cells. These are
 commercially available and can be built large enough to accommodate locomotive generator outputs
 (typically, 2500 kW maximum at 60 Vdc). They can  be mounted on trucks and transported to
 acoustically acceptable sites near yards or shops accessible to locomotives. Units of this size are not
 generally available, but discussions with load cell suppliers indicate that no design or manufacturing
 problems would prevent their being supplied. The projected price for such a unit is $ 100,000 at
 current cost levels.*
     The total cost of acquiring portable load cells can be estimated by assuming that

     •    Half the locomotive population will be|tested by this means. Note  that all GE locomotives
          (15% of the population) can be tested under self-load, and it is assumed that stationary
          cells can accommodate the remaining 35%.

     •    An average of one locomotive per day will be tested by each cell for two years.  Note that
         in actual use each cell would spend several days in transit, followed by several days
         measuring locomotives at each site.

The number of load cells needed would therefore  be obtained by computing

                                          (0.5 X 27,000 locomotives)
                       (2 years X 365 days per year x 1 locomotive per cell per day)

which gives an answer of 18.49, or approximately 20 cells. The total cost of $2,000,000, divided
by 27,000 locomotives, comes to $74 per unit.
'Source for information on load cells:  conversations with D. Partridge, Simplex Co., Springfield,
Dlinois.
                                            7-32

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     Another piece of equipment that will be required for testing will be a sound level meter. Type
2 meters, with fast and slow readings, are available, with calibrators, at about $200 each. The precise
number required is not known, but it is assumed to be 500 (i.e., one meter for every 54 locomotives).
The total cost would be $100,000.
     The labor used in testing each locomotive would consist of one technician for approximately 2
hours.*  Using the average of the skilled labor costs derived above (Table 7-21) and allowing for 6
percent supervisory time at a 15 percent labor cost premium, an average labor cost of $8.18 per hour is
obtained, or $16.36 per locomotive.

     Summary of Initial Direct Costs. Table 7-24 summarizes the direct cost of locomotive retrofit.
     Note that the subtotal figure represents costs incurred only by those locomotives actually retro-
fitted, or approximately 75 percent of the population.

                                      TABLE 7-24
           INITIAL DIRECT COSTS OF RETROFITTING EXHAUST MUFFLERS
                                  TO LOCOMOTIVES
Cost Areas
Muffler
Additional Hardware
Labor
Subtotal
Testing
Total
Locomotive Type
EMD Road,
RB
$4690

73
$"4763"
91
$4854
EMD Road,
TC
$1500
1135
406
$3041
91
$3132
GE Road
$1500
2000
406
$3906
91
$3997
Switcher
$700

73
$773
91
$864
Initial Indirect Costs
     Two elements comprise indirect initial costs: (1) cost net revenue due to locomotive downtime
and (2) cost of developing suitable muffler designs. The first of these categories will be analyzed in
two phases:  the cost of locomotive downtime and the expected number of lost locomotive-days.
*It is assumed that protable load cells will be located in areas easily accessible by locomotives in the
course of their normal operations.  There will, therefore, be negligible cost for locomotive transit
time or down time or for crew time.
                                           7-33

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      Cost of Locomotive Down time. The marginal value of a locomotive-day is the extra net
  revenue the locomotive would have generated had it been available for use. This is defined as the
  gross revenue per locomotive-day less the locomotive daily operating expenses.  If there is excess
  capacity in the locomotive fleet, then the revenue generated by an extra locomotive is zero; that is,
  down time is free, since there are idle locomotives.  At present, however, the railroads' hauling capacity
  is under considerable strain.  The value of marginal revenue is, therefore, taken to be the average per
  revenue per total locomotive in the fleet.* Dividing the total locomotives (27,117) times 365 days
  per year into 1973 gross operating revenues ($14.2 billion) gives an average revenue figure of $ 1438
  per locomotive-day.
      To show that this is a correct procedure an example is presented.  If retrofit were to be per-
  formed over a 4-day period in which railroads were closed, the lost revenue would be the revenue
  that would have been earned over those 4 days.  The total lost revenue could be expressed in terms
  of revenue per locomotive times the number of locomotives. If revenue per locomotive were to
  be derived by including only serviceable locomotives and then were to be multiplied by the total
 number of locomotives, the estimated revenue loss would exceed the actual revenue loss. Of course,
 lost revenue per serviceable locomotive could be calculated and then multiplied by the number of
 serviceable locomotives. Thus, computations of total revenue loss must be done using either serviceable
 locomotives or total locomotives consistently in both the numerator and the denominator. Either
 method gives the  same answer, as long as one is consistent. Total locomotives were chosen, since it
 avoids using one population for lost revenue and another for direct cost.
     To obtain the true cost to the railroad, this figure must be reduced by an amount equal to the
 expenses saved  by not having  to operate the locomotive. In the Background Document, this was
 done by identifying those ICC cost accounts that would be reduced and by calculating the level of
 these reductions (see Table 7-11).  The ratio of expenses to revenue thus derived was 4964/21,982  =
 .226. The AAR submission to the docket (p. 62) [20] uses a ratio of expenses to revenue of
 39,826,000/64,978,000 = 0.61 (Welsh, p. 62) [20]. The $39,826,000 figure does not appear on that
 page but can be calculated by subtracting from lost revenue, $64,978,000, net losses of $25,152,000).
 (While the AAR claims that 0.61 is the ratio used in the Background Document, it is not.) However,
 the 0.61 figure is consistent with the ICC evaluation of railroad expenses, which are claimed to be
 about 80 percent out-of-pocket expenses (i.e., variable).  Using the ICC figure and a 1973 operating
 ratio (total operating expenses divided by total operating revenue) of 79.3, the ratio of variable
 expenses to revenue is 63.4. In the subsequent calculations, 0.61 is used since this is the ratio AAR
 uses and it is consistent with the ICC percent-variable (i.e., out of pocket) calculations. Using $ 1438 as
 as the value of a locomotive-day, the reduced expenses equal $877 (i.e., 0.61 X $1438), and the net
 cost of a locomotive-day is $561.
*Some concern may arise over whether one should divide gross revenues by the total number of
locomotives (27,117) or the number of serviceable locomotives (26,245).  The choice is arbitrary,
as long as the same figure is used to compute both revenue per locomotive and total lost revenue.
See subsequent discussion.
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    Number of Lost Locomotive-Days,  Table 7-25 shows the EPA estimate of the time lost per
locomotive during retrofit. This table is based on Table 7-25 of the original Background Document,
which, in turn, was derived from conversations with railroad maintenance personnel. The EPA
figures are contrasted in the table with the elapsed-time estimates provided by the AAR in their
submission to the docket (Garin, p. 16) [20].  The difference arises because of the large amount
of extra work entailed in the AAR projected retrofit program, work involving the relocation of
dynamic brakes, fans, and cooling system pipes.  If this type of work (which is necessitated by the
AAR space-inefficient muffler design) is discounted, the two estimates are not dissimilar.
    The actual number of days lost by the total fleet depends on how frequently locomotives
undergo major repair. As shown in Table 7-25, some time is saved if mufflers can be retrofitted
                                      TABLE 7-25
                            DAYS LOST DUE TO RETROFIT

Estimator


EPA2










AAR3

Basis of
Retrofit1
If done by
itself
If done
during
regular
intermedi-
ate over-
hauls
If done
during
regular
heavy
overhaul
Done by
Locomotive Manufacturer and Type
EMD Road,
RB
3



1





0


2.5 -54
EMD Road,
TC
3



1





0


3-3.5
GEand
Other Roads
2



0





0


2.5 - 54
Switcher
1



0





0


3-3.5
     1 Assumes no lost time due to travel to and from shop and no muffler retrofitting done during
      emergency repairs.
     2Source: EPA Original Background Document, June 1974.
     SSource: AAR, 1974.
     ^Depends on whether extended-range dynamic brakes are present.
                                           7-35

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   while other repairs are being made. The EPA original Background Document gave an average
   maintenance interval of 4 years for intermediate overhauls and 8 years for heavy overhauls.*
       The annual total of lost locomotive-days for the nation is now computed, assuming a 2-year
   compliance period, and the annual cost of those lost days. In any given year, one-eighth of all
  locomotives undergo heavy repairs,and another eighth undergo intermediate overhaul. The number
  of lost days is therefore given by
                          LT = NER X ^-|x 3 days j + Ux 1 day) ]

                                    + NGEx(fx2days)
  where
      LT  =  lost time in locomotive-days,

      NER = number of HMD road locomotives,

             = number of GE and other road locomotives,

             = number of switchers.
 The total number of locomotives in each category is shown in Table 7-26. It is assumed, in the
 interest of being conservative, that no locomotive retirements will take place during the retrofit
 period. Inserting the figures in the table into the preceding expression gives a total of 5 1,840
 locomotive-days lost.  This total is based on the assumption, however, that all locomotives would
 be retrofitted, whereas in fact only 75 percent would actually be retrofitted. Therefore, the
 number of lost locomotive-days would be  38,880 (5 1 ,840 times 0.75). At $56 1 per day (the cost
 of one lost locomotive-day), the cost per year to the industry would be $ 1 0.9 million, or $2 1 .8 1
 million over the 2-year complaince period.

     Cost of Developing Mufflers.  At present, mufflers designed for railroad service conditions are
 not commercially available. It may be assumed that it will be necessary to develop, fabricate, and
 test several prototypes of each basic design before the designs can be approved for service. In the
 absence of detailed designs, it is not possible to plan such a development program and project its
 costs. However, we can make some reasonable assumptions to estimate the cost.
     It is assumed that six basic muffler designs are to be developed and tested, with several models
 based on each design.  If the cost of the development and test program for each design is $500 000
 the total effort would  cost $3 million.                                                  '    '
*Peabody and Associates (1974) report an average interval of 7.3 years for overhaul. They do not
discriminate between intermediate overhauls, in which the cylinders are changed in place and the
bearings are renewed, and heavy overhauls, which involve lifting off the cab and rebuilding the loco-
motive components as necessary [57].
                                           7-36

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                                      TABLE 7-26
                NUMBER OF LOCOMOTIVES BY TYPE (1973 AVERAGE)
Type of Locomotive
EMD Rootes-blown Road
EMD Turbocharged Road
GE and Other Road
Switchers
Total
Number
7786
9579
4381
5371
27,117
                  *Source: Railway Locomotives and Cars, May 1974. Due to
                           a small discrepancy in the total number reported in
                           this reference relative to the ICC total, the figures
                           in the reference were scaled downward by a factor
                           of 0.985 to give a total of 27,117.

Continuing Costs
     Two types of operating costs may be affected by muffler retrofit. First, mufflers will probably
need to be maintained. Second, the backpressure imposed on the diesel engine by the muffler may
result in degraded fuel economy and, thus, higher fuel costs.

     Maintenance Requirements. The original Background Document does not explicitly identify
extra maintenance costs due to muffler retrofit. The original analysis noted that mufflers are
similar in construction, materials, and service conditions to the exhaust manifolds that presently
exist on locomotives. There is no evidence to show that exhaust manifolds fail in service or require
other than occasional attention. Accordingly, it was assumed that the extra effort required to
maintain mufflers would be small compared to the other identified costs.* A highly conservative
estimate would be to assume that mufflers will require replacement at every major overhaul, or
approximately every 8 years. If $1600 is allotted for parts and labor per locomotive for a locomo-
tive population of approximately 27,000, with 75 percent having mufflers, an average annual expendi-
ture  of $4.1 million per year is calculated.
*This is the case, for example, with mufflers on heavy diesel trucks. Conversations with truck fleet
operators indicate that service failures of such mufflers are virtually unknown,and that an
occasional patch weld is the most maintenance required.
                                          7-37

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     Fuel Costs.  An increase in the back pressure on an engine exhaust line increases the work the
 engine must do to pump exhaust gases through the line. The result is a decrease in overall engine
 efficiency. There are, however, no test data available on the magnitude of this effect for large diesel
 engines. General Electric estimates that "If forced to run with 20°F higher pre-turbine temperatures,
 the increase in fuel consumption would be on the order of 1 percent [70]. The AAR (1974) also
 cites the 1-percent figure, although without any supporting data. Therefore, 1 percent will be used
 as a conservative figure appropriate to line-haul operation. If I 'percent is multiplied times the 1972
 railroad fuel consumption of 3690 million gallons (for line-haul freight and passenger operations;
 source: ICC statistics [67,68]), we obtain an extra 36.9 million gallons of diesel oil consumed per
 year. At the 1975 wholesale price of $0.30 per gallon for diesel fuel, this amounts to an extra
 $11.1 million per year.

Summary of Locomotive Retrofit Costs
     Tables 7-27 and 7-28 show the breakdown of initial and annual costs for the entire locomotive
retrofit program.  The total parts and labor costs were obtained by multiplying 0.75 (the fraction
of locomotives needing retrofit) by the numbers of locomotives in each category as shown in
Table 7-26, and then by the direct costs for each category as given in Table 7-24.  Testing cost was
obtained by multiplying $91 from Table 7-24 by the total number of locomotives. As before, it
was assumed that no locomotives would be retired during the retrofit period.

Economic Impact of Muffler Retrofit
     In the public docket for the proposed noise regulation on diesel electric locomotives, a num-
ber of economic issues have been raised, including the availability of labor, the impact on railroad
financial viability (which includes the impact on freight volume), and the impact on product prices
as a result of possible freight rate increases. This discussion provides an analysis of these and other
issues associated with the economic impact of muffler retrofit. Included are:

     •   An evaluation of possible labor shortages in the rail sector.

     •   A discussion of alternate measures of financial impact on the railroads.

     •   A description of the current economic condition of U.S. Class I railroads, along with a
         discussion of the issue of the differential impact of fuel costs on railroads and
         trucks.

     •   Consideration of the question of freight diversion.

     •   Consideration of the impact of retrofit on freight rates and on the U.S.  economy.
                                            7-38

-------
                                TABLE 7-27
SUMMARY OF INITIAL LOCOMOTIVE RETROFIT COSTS FOR A 2-YEAR PROGRAM
                            (Figures in $ Millions)
Initial Direct Costs (2 yrs)
Parts and Labor
Testing
Total
Initial Indirect Costs (2 yrs)
Lost Locomotive Time
Muffler Development
Total
Total Initial Costs (2 yrs)

$65.63
2.47
$68.10

$21.81
3.00*
$24.81
$92.91
    '"Estimate based on conservative assumptions; no data available.  See Text.
                                TABLE 7-28
                      SUMMARY OF ANNUAL COSTS OF
              LOCOMOTIVE RETROFIT FOR A 2-YEAR PROGRAM
                         (Figures in $ Millions Per Year)
      Initial Costs (Direct and Indirect;
          obtained from Table 7-27)
      Continuing Costs (annual average)
          Extra Maintenance
          Extra Fuel
          Total
$46.45


  4.05*
 11.10*
$15.15
       *Estimate based on conservative assumptions; no data available. See text.
                                   7-39

-------
 Labor Supply
     The ability of the railroads to perform a retrofit program depends on whether the required labor
 is available.  To odentify whether a labor shortage exists, a means for testing for labor shortages must
 first be established.
     Firms adjust to labor shortages first by increasing the number of hours worked per employee
 and then, if the increased demand for workers is sustained, by adding new employees. Thus, in the
 short run, the number of hours rises, and in the long run, the  number of employees rises.  Increases
 in hours worked and number of employees are therefore indicative of short-term and long-term
 labor shortages, respectively. The hours that should be considered are hours worked, including
 straight time and overtime.  One should not consider only overtime, since the distribution of hours
 between overtime and straight time is, in part, a function of institutional arrangements (e.g., union
 contracts).  Thus, a rise in overtime does not necessarily indicate a labor shortage.
     The last 4 years have constituted a period of decreasing labor hours and decreasing employment
 in the Maintenance and Equipment and Stores sector (ICC designation).  The number of employees,
 the number of hours for which employees were paid (including vacations and holidays), the total
 hours worked, and the average hours worked per employee all declined from 1970 to 1973. Comparing
 1970 to 1973* average hours paid per employees increased, while hours.worked per employee de-
 creased, indicating an increase in paid time off.  Average overtime hours per employee decreased
 each year from 1970 to  1972 and then increased from 1972 to 1973, but were still below the 1970
 level.  These trends are summarized in Figure 7-3.
     The Maintenance of Equipment and Stores sector does not exhibit any of the characteristics
 of a labor market in which a labor shortage exists. However, the rise in overtime from 1972 to
 1973 could indicate shortages in specific categories in labor; i.e., the rise in overtime  could be the
 result of an increase in overtime of specific categories of labor, and offsetting reductions in overtime
 and lay-offs in other categories of labor could have caused average hours worked to remain constant
 and overtime hours to rise.  This would indicate a shortage in specific trades.  To determine whether
 this has been the case, trends in hours worked and workers employed in specific trades shall be
 examined.
     In the 25 categories of labor listed under Maintenance of Equipment and Stores, one cateogry
(helper apprentice, 65*) had more employees in 1973 than in 1970.  Average hours worked per
employee increased for the same time period in three categories (electrical workers B & C, 59, 60;
skilled trades helper, 64).  The adjustment in hours and employment may have begun more recently.
Labor demand would have reached a low point and then increased during this period.
     From 1972 to 1973, average hours worked per employee increased in five categories (inspectors,
52; boilermakers, 55; electrical workers B & C, 59, 60; skilled trades helpers, 64; and gang foreman
in stores, etc., 69). In three cases, average hours per employee remained unchanged, and in the
rest, they declined. During the same period (1972 to 1973), employment increased in five categories:
general, assistant general, and department foreman, 50; electirical workers.B, 60; helper apprentices,
65; regular apprentices, 66; and classified laborers, 70. In two of the remaining 25 categories,
employment was virtually unchanged, and in all others it decreased.
*Numerical designations refer to ICC Standard Accounts.


                                          7^0

-------
    300
                                                  125
CO
oc
O
250
            tO
            OC
            15
            O
100
    200
                  I
                        I
I
       70        71        72         73
                       YEAR

       a-TOTAL SERVICE HOURS (MILLIONS)
       b-TOTAL HOURS WORKED (MILLIONS)
                                                  75
      	I	I	I
   70        71         72         73
                   YEAR
   AVERAGE OVERTIME HOURS PER EMPLOYEE
CO
01
UJ
    150
    125
    100
                 I
                                  I
       70         71         72        73

                       YEAR

       TOTAL NUMBER OF EMPLOYEES (THOUSANDS)
                                              to
                                              oc
                                              O
                                                    70
                            71
                       72
                                                                                       73
                                                                    YEAR
                                                    a-AVERAGE TOTAL SERVICE HOURS PER
                                                      EMPLOYEE (THOUSANDS)
                                                    b-AVERAGE TOTAL HOURS WORKED PER
                                                      EMPLOYEE (THOUSANDS)
                   Figure 7-3.  Patterns in Maintenance of Railroad Equipment and Stores

-------
      Thus, the following categories in which there appear to be some recent increases in labor input
 (either through increased hours or increased employment) can be identified:

           Foreman (general, etc.), 50
           Inspectors (equipment, shop, electrical, etc.), 52
           Electrical  workers B & C, 59,60
           Skilled trades helpers, 64
           Helper apprentices, 65
           Regular apprentices, 66
           Gang foreman (stores, etc.), 69
           Classified laborers (shops, engine houses, etc.), 70.

 In the 16 categories not listed, the labor input has been reduced by reducing hours and reducing
 employment, indicating that there is not a shortage of labor in these  16 categories and that, in fact,
 they could probably  be expanded by increasing hours.
     In four categories (50,65,66,70), average hours per employee decreased, while employment
 increased. If the 1973 hours worked per employee were increased to the 1970 levels,  the increase
 in total hours worked would be 2 to 3 percent.
     Category 50 is supervisory labor, which is not likely to be affected by a muffler retrofit program.
 If it should be, however, then the current labor input could be increased by 3 percent  (of the  1973
 total) by increasing hours worked to the  1970 levels. Category 70 (classified laborers) is an un-
 skilled occupation that could be increased through new hires or by increasing hours worked to the
 1970 levels, thus increasing the labor input by 2 percent (of the 1973 level).
     Categories 65 and 66 are not homogenous, since they include helper and regular apprentices,
 respectively, in different trades.  It would be inappropriate, therefore, to consider an overall increase
 in hours, particularly  if the distribution of apprentices in different trades has changed  over time.
 Increases in the number of apprentices from 1972 to 1973 do indicate the industry is training journey.
 men, which in turn may indicate an inability to hire trained workers in 'the skilled trades. The number
 of apprentices has only increased by 99 from 1972 to 1973; the 1973 level is still below the 1970
 levels.
     Hours worked have increased from 1972 to  1973 for:

     •    Inspectors, 52
     •    Electrical workers B & C, 59,60
     •    Skilled trades helpers, 64
     •    Foreman (stores, etc.), 60.

     The average hours worked per employee in categories 59 and 60 in 1973 exceeded the 1970
levels.  However, the number of employees in Category 59 was 11 percent (111 employees) fewer
in 1973 than in 1972, but in Category 60,12 percent more (15 employees). In Categories 52, 64,
and 69, the average hours worked per  employee was less in 1973 than in  1970. Since 69 is a super-'
visory classification for stores and ice and reclamation and timber treating plants, this group would
be unaffected by a retrofit  program.
                                           7-42

-------
                                             TABLE 7-29
             LEVELS OF EMPLOYMENT AND AVERAGE HOURS WORKED IN 1970 AND 1972 COMPARED TO 1973
Categories
50
52
59
60
64
65
66
69
70
1970
Level of
Employment
larger
larger
larger
larger
larger
smaller
larger
larger
larger
1970
Average
Hours Worked
per Employee
larger
larger
smaller
smaller
larger
larger
larger
larger
larger
1972
Level of
Employment
smaller
larger
larger
smaller
larger
smaller
smaller
larger
smaller
1972
Average
Hours Worked
per Employee
larger
smaller
smaller
smaller
smaller
larger
larger
smaller
larger
Increase in 1973 Hours Worked
if the Hours were Increased to the
1970 Level but Employment Remained
at 1973 Level (hrs per employee)
3% (67)
2% (45)
None (73 exceeds 70)
None {73 exceeds 70)
2% (29)
3% (64)
1%(20)
4% (80)
2% (33)
10

-------
      Table 7-29 shows, by category, the increases in 1973 hours worked that would occur if the
 hours were increased to the 1970 level per employee: 64 would increase labor input by about 2
 percent, and 52 would increase by about 2 percent.
      There seems to be a strong indication that a labor shortage does not exist and that hours could
 be increased to provide the labor required for a retrofit program.  The exceptions to this are:

      •   The increase in training identified by apprentice categories 64 and 65 (one might also
          assume that skilled trades helpers, 64, is an entry level job that can provide skilled
          workers through upgrading)

      •   The electrical workers B & C, 59 and 60.  The fact remains that the number of apprentices
          in  1973 is less than the 1970 level.

      As shown in Table 7-30, the total hours required for a retrofit program are small compared to
 the total hours worked in the maintenance sector:

                                      TABLE 7-30
                 MAN-HOURS REQUIRED FOR LOCOMOTIVE RETROFIT
Locomotive
Type
EMD (RB)
EMD (TC)
GE & Other
Road
Switcher
Man-Hours
Per Locomotive
9
51
51
9
Locomotives
in Service
7786
9579
4381
5371
Total
Man-Hours
70,074
488,529
223,431
48,339
Total Hours 830,373
Annual total hours over 2 years 4 1 5, 186.5
Annual total hour as a percent of 1973 hours
covered in Maintenance of Equipment and Stores Sector.* 0.19%
*Total hours worked in Maintenance of Equipment and Stores in 1973 was 221.04 million hours.

Impact on Railroad Revenue and Profits
     The question considered in this section is the appropriate base to use for comparing the total
cost of retrofit. A retrofit program has both a short- and a long-term impact on railroads. The
                                          7-44

-------
short-run impact occurs over a 2-year period and then disappears. Some costs continue after
retrofit (e.g., increased fuel costs) and must be considered separately.
     Since the nonrecurring costs of a retrofit program cover only a 2-year period, the appropriate
base against which to compare these costs is net revenue.  A firm will sustain short-term losses so
long as it covers its variable costs, and net revenue is a measure of the excess of revenue over
variable costs. Net operating income measures the excess of revenue over variable plus fixed costs
and is, therefore, indicative of the firms long-term ability to pay. (Note that in no case should
recurring costs be compared to net income after taxes, since taxes will be reduced by increased
costs.)
     The total annual nonrecurring costs are $46.45 million. The 1973 net operating revenue
of railroads was $3,097.68 million. The short-term costs of a retrofit program would therefore
represent  1.50 percent of the 1973 net revenue per year over each of the 2 years. As pointed out
in Table 7-28, the  increased fuel costs would be $ 11.10 million. During the first 2 years (while
retrofit is being carried out), the increased fuel costs would be 25 percent of this for the first
year and 75 percent for the seond year. These percentages represent the average portion of the
fleet that  will have completed the retrofit program in the first and second years, respectively.
Thus,  $2.78 million is added to the first year and $8.33 million to the  second year retrofit costs,
making the first year $49.23 million and the second year $54.78 million.
     It is  assumed that no extra maintenance (beyond the retrofit itself) will be  necessary in the
first 2 years. Thus, the first year costs are 1.59  percent and the second year costs are 1.77 percent
of net operating revenue.
     The  recurring expanse of $ 15.15 million per year represents 1,83 percent of the 1973 net
railway operating  income before Federal income taxes. (The 1973 net income before Federal
income taxes was  $830.7 million).

Financial Impact
     In general, the adverse effect  of extra operating costs is greater on firms in  financial distress
than on healthy firms. This is of particular concern in the case of the railroads, a number of which
face difficulties in maintaining profitable operations. The extent to which this is a problem is
illustrated by the  seven lines that are presently bankrupt.  It is clearly important to estimate the
number of railroads that might have trouble paying the cost of a retrofit program.
     It should be  noted  that it is impossible to predict whether a firm already in difficulty will be
bankrupt as a result of this ( or any other) externally imposed cost, for two reasons. First  a
declaration of bankruptcy is not necessarily related to a firm's financial position at any one
moment but is based instead on the management's opinion of the firm's viability in the long term.
Thus, a short-term nonrecurring expense would not necessarily have an impact.  Second, the
magnitudes of the expenses involved in such a program are small relative to other problems faced
 by the railroads.
     While it is unlikely that the cost of retrofitting mufflers would actually cause bankruptcy, it
is still true that roads in financial trouble may have difficulty affording the program cost.  This
 section attempts to gauge the extent of this problem by determining how many railroads are in
 financial distress. This will be done by computing, for each road, several financial ratios that are
 generally accepted as indicating the financial condition of a business enterprise.  A summary of the
                                              745

-------
 number of roads that have unfavorable values for each ratio is then provided. Of course, this
 technique cannot provide a quantitative definition of which railroads cannot afford a retrofit pro-
 gram. At best, it gives a rank ordering. The cutoff value that determines financial distress is
 entirely arbitrary.
      The following financial ratios were computed:

      1.   Current assets/total assets.
      2.   Operating expenses/operating revenues.
      3.   Total liabilities less stockholders' equity/total assets.
      4.   Income after fixed charges/total assets.
      5.   Retained
      6.   Net income/total assets.
      7.   Net income/operating revenue.

 In most cases these ratios parallel those used by Edward Altman [ 1 ]. Ratios 1 and 5 are measures
 of the liquidity* of a railroad, while 2,4, 6, and 7 are measures of profitability and efficiency.  Ratio
 3 measures solvency.
     With respect to ratio 1, the analysis seems inconclusive. A large number of roads had ratios
 of current-to-total assets in excess of three standard deviations from the mean. This indicates that
 the distribution of values of this ratio did not approximate a normal distribution. This being the
 case, ratio 1 does not constitute a valid indicator of which roads may be in distress.
     The analysis of ratio 5 (retained earnings/total assets) indicated that 14 railroads have negative
 retained earnings, while 2 have zero, showing that these roads lack liquidity. While internal
 financing may not be important in the rail industry, the negative retained earnings indicate that
 these roads are drawing on cash reserves.* *
     The most commonly used measure of profitability is operating ratio 2, the ratio of operating-
 revenue-to-operating-expense.  Three roads have operating ratios greater than 1, indicating that
 expenses exceed revenues. An additional seven roads have operating ratios more than three
 standard deviations liigher than the mean. Certainly, the three roads and possibly some of the
 seven must be considered to be in an adverse position.  Ratios 6 and  7 are similar measures, in that
 a road with a negative net income will have a negative ratio for both 6 and 7. Six roads have nega-
 tive net incomes.  In addition, two other roads must be considered to be poor performers as  measured
 by the ratio of net-income-to-total-assets (6).
     Ratio 4 indicates that nine roads have negative income and two have zero income after  fixed
 charges. These roads are unprofitable by definition.  The ratio of total liabilities (less stockholder
equity)-to-total-assets (3) appears to have also yielded inconclusive results. One road stands  out
as being extremely poor using this measure, and there are four other roads for which this ratio is
greater than 1.
     A word of caution should be issued in the interpretation of any ratio that uses total assets.
Under the betterment accounting procedure, total assets tend to be inflated.  However, to the
 *Liquidity is the ability of a firm to convert assets into cash.
**This may also represent an insufficient amount of funds allocated to depreciation.
                                            7-46

-------
extent that this bias is uniform throughout the industry, it is possible to compare different roads.
It is not possible to compare these ratios with other firms outside the rail industry.
     Tables 7-31 through 7-37 show the railroads that had unfavorable values for each of the seven
financial indicators described above.  The railroads are rank-ordered for each ratio, the railroad
with the most unfavorable ratio being listed first.

Freight Diversion as a Result of Differential Impacts of Fuel Costs
     The manner in which fuel prices will affect the distribution of freight between rail and truck
can be demonstrated  using the graph in Figure 7-4.

                                       TABLE 7-31
                       RATIO 1-CURRENT ASSETS/TOTAL  ASSETS
Ratio
.06
.06
.06
.07
.07
.08
.08
.08
.08
.09
Railroad
Missouri-Kansas-Texas
Pittsburgh & Lake Erie
Texas Pacific
Bangor & Aroostook
(B) Lehigh Valley
(B) Reading
(B) Erie Lackawanna
Central Vermont
Western Maryland
Long Island
ICC No.
47
68
67
7
42
59
30
14
70
43
        (B)  Indicates bankrupt road.
                                            7-47

-------
                TABLE 7-32
RATIO 2-OPERATING EXPENSES/OPERATING REVENUE
Ratio
143.4
114.1
104.7
103.4
92.0
92.9
90.3
89.5
89.5
88.0
87.1
84.8
Railroad
Long Island
Pennsylvania Reading Seashore
Pittsburgh & Lake Erie
Bangor Aroostook
(B) Ann Arbor
Lake Superior & Ishpeming
Grand Trunk Western
(B) Lehigh Valley
Western Maryland
(B) Penn Central
(B) Reading
(B) Boston & Maine
ICC No.
43
57
58
7
3
41
35
42
70
56
59
9
                TABLE 7-33
 RATIO 3-TOTAL LIABILITIES LESS STOCKHOLDER
           EQUITY/TOTAL ASSETS
Ratio
11.11
2.33
2.02
1.10
1.00
1.00
.99
.89
.75
.73
.71
Railroad
Pennsylvania Reading Seashore
Grand Trunk Western
Central Vermont
(B) Central Railroad of New Jersey
Georgia
Missouri-Kansas-Texas
Clinchfield
(B) Erie Lachawanna
(B) Penn Central
(B) Ann Arbor
(B) Lehigh Valley
ICC No.
' 57
35
14
13
33
47
21
30
56
3
42
                   7-48

-------
                  TABLE 7-34
RATIO 4-INCOME AFTER FIXED CHARGES/TOTAL ASSETS
Ratio
-.30
-.28
-.12
-.06
-.06
-.05
-.04
-.04
-.02
-.02
-.02
-.01
-.01
.00
.00
Railroad
Pennsylvania Reading Seashore
Long Island
Grand Trunk Western
(B) Penn Central
(B) vAnn Arbor
(B) 'Lehigh Valley
(B) Central Railroad of New Jersey
(B) Reading
(B) Boston & Maine
Western Maryland
Delaware
Fort Worth & Denver
Chicago Rock Island & Pacific
(B) Erie Lackawanna
Chicago, Milwaukee, St. Paul & Pacific
ICC No.
57
43
35
56
3
42
13
59
9
70
23
32
19
30
18
                  TABLE 7-35
     RATIO 5-RETAINED EARNINGS/TOTAL ASSETS
Ratio
-.31
-.29
-.15
-.13
-.06
-.05
-.04
-.04
-.03
-.03
-.03
-.02
-.02
-.01
-.01
-.01
-.01
-.01
.00
.00
Railroad
Pennsylvania Reading Seashore
Long Island
Grand Trunk Western
(B) Penn Central
(B) Ann Arbor
(B) Lehigh Valley
(B) Central Railroad of New Jersey
(B) Reading
Chicago, Milwaukee, St. Paul & Pacific
(B) Boston & Maine
Baltimore & Ohio
Delaware & Hudson
Western Maryland
Chicago & Northwestern
Chicago, Rock Island & Pacific
Kansas City Southern
Burlington Northern
Fort Worth & Denver
(B) Erie Lackawanna.
Monon
ICC No.
57
43
35
56
3
42
13
59
19
9
6
23
70
17
19
40
10
32
30
49
                      749

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              TABLE 7-36
    RATIO 6-NET INCOME/TOTAL ASSETS
Ratio
-.28
-.26
-.11
-.04
-.04
-.03
-.02
-.01
-.01
.00
.00
.00
.00
.01
.01
Railroad
Long Island
Pennsylvania Reading Seashore
Grand Trunk Western
(B) Penn Central
(B) Ann Arbor
(B) Lehigh Valley
(B) Reading
(B) Central Railroad of New Jersey
(B) Boston & Maine
Fort Worth & Denver
Chicago, Rock Island & Pacific
Monon
Delaware & Hudson
Missouri-Kansas-Texas
Western Mayland
ICC No.
43
57
35
56
3
42
59
13
9
32
19
49
23
47
70
              TABLE 7-37
RATIO 7-NET INCOME/OPERATING REVENUE
Ratio
-7.24
-6.87
-1.97
-1.22
-1.06
- .85
-.40
-.14
-.14
.00
.00
.03
.03
Railroad
Pittsburgh & Lake Erie
Bangor & Aroostook
Grand Trunk Western
(B) Lehigh Valley
(B) Ann Arbor
(B) Penn Central
(B) Reading
(B) Boston & Maine
(B) Central Railroad of New Jersey
Fort Worth & Denver
Chicago, Rock Island & Pacific
Monon
Delaware & Hudson
ICC No.
58
7
35
42
3
56
59
9
13
32
19
49
23
                7-50

-------
                  (9
                  UJ
                  OC
                  LL.
                  O
                  UJ
                  5

                  5
                      M
                                  T       Z'         M*
                                  VOLUME OF RAIL FREIGHT
                  Figure 7-4. Effect of Fuel Prices on Distribution of Freight

Line Q represents the quantity of freight service (truck and rail) necessary to produce a given level
of output (given level of GNP). Any point on Q (and the combination of rail and truck freight it
represents) is a possible equilibrium position.  Line ZZ' represents the volume of rail and truck
freight that can be carried for a constant dollar expenditure on freight.  That is, if the level of
expenditures is K, the total expenditures on freight and truck freight are constrained to
PrQr + PtQt = K, where Qr and Qt are the quantities of truck and rail freight, respectively, and
Pr and Pt are the freight rate for rail and truck, respectively. Note that the slope of line ZZ' is
equal to -(Pr/Pt), which is the ratio of the price of rail freight to the price of truck freight. The
equilibrium position (which minimizes total freight cost at Pr/Pt relative freight rates) is the
tangency point at n. The volume of freight is Qt and Qr. Line MM' represents a different price
ratio, which has a lower relative cost of rail freight.
     Fuel composes part of the cost of providing both rail and freight service. The following cost
functions are assumed to represent the cost of providing truck and rail services:
and
                                    Cf=f(Qi)+PbQ!
where Qt is the quantity of truck freight in ton miles. Qr is the quantity of rail freight in ton miles,
P is the price of fuel, a is a constant that reflects fuel consumed per ton-mile of freight for trucks, b
is a constant that reflects fuel consumed per ton-mile of freight for rail, and f(Q) represents the
other nonfuel cost elements.
                                           7-51

-------
      Trucks consume four times as much as rail per ton-mile of freight, therefore a = 4b.  If fuel
 price increase the impact on cost will be

                                          dDt
                                          aF
 and
                                          3Cr
 Since a = 4b, the change in cost per ton-mile on trucks is four times that of railroads. For example,
 if freight rates Pj and Pr are increased to fully reflect the increased fuel costs, rates increase to PI
 + dPa (for truck) and Pr + dPb (for rail).  This means that the slope of line ZZ' will change so that
 the new price ratio will be similar to line mm'.  The new equilibrium position j will be at a point
 on Q so that the quantity of rail freight will increase or the quantity of truck freight will decrease.
     One possibility is that the Q may shift down towards the origin (for example Q! ). This would
 indicate that either the quantity of transportation services needed to support a given level of out-
 put had decreased or that the level of output (i.e., GNP) had decreased.  In any case, the relative
 share of total transportation will be larger for rail (than for truck) after the fuel price increase. *
     One additional  observation should be made. First, it has been assumed that the price increase
 per BTU (of fuel) will be equal for rail and truck. If it is higher for rail than for truck, this will
 offset some rail  fuel  efficiency advantage. If it is greater for trucks (which seems most likely, due
 to the effect of market structure in petroleum) it will cause even a greater shift to rail.

Impacts on Consumers
     The impact of a muffler retrofit program on consumers can be measured by  the price increases
that would result if rail freight rates are increased. Table 7-38 shows both the direct and indirect
rail inputs for the commodities listed. The first column shows the cents of rail transportation per
dollar of output for each commodity listed. For example, commodity 24, motor vehicles, requires
2.9^ of rail transportation per dollar of sales. The 2. 91 reflects all rail transportation inputs for
raw materials, intermediate inputs, and the final product.
     The second column shows the percent increase in selling price that would result from a
 1 -percent increase in rail freight rates.  Note that this does not allow for a shift to other modes. If
truck or water transport is used in place of part of the rail transport (because truck or water is
cheaper after the rail price increase), the price increases will be smaller than those shown.  The
figures in the table, therefore, represent the maximum expected price increases resulting from a
1 -percent rail freight  rate increase.
*This result depends upon Q being mathematically a convex set. The intuitive argument for
convexity is that as rail is substituted for trucking transportation, the substitution becomes more
difficult because in some applications rail service is quite inferior to truck. For a discussion of the
theoretical points relating to this analysis, see C. E. Ferguson, The Neoclassical Theory of Produc-
tion and Distribution,  Cambridge University Press, 1969 or R. Frish, Theory of Production, Rand
McNallyA Co., 1965 [48].

                                           7-52

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                                               TABLE 7-38
                   EFFECT OF A 1-PERCENT RAIL FREIGHT RATE INCREASE ON COMMODITY PRICES
Ul
co
Department of Transportation Sector
1. Agriculture
2. Iron ore mining
3. Nonferrous mining
4. Coalmining
5. Miscellaneous mining
6. Construction
7. Ordnance
8. Food and drugs
9. Textiles and apparel
10. Lumber and products
11. Furniture
12. Paper and paper products
13. Printing
14. Chemicals
15. Plastics, paints, and rubber
16. Petroleum and products
17. Stone, clay, glass products
18. Iron and steel
19. Nonferrous metals
20. Fabricated metals
21. Farm, construction machinery
22. Industrial machinery
23. Electrical machinery
24. Motor vehicles
25. Aircraft
26. Other transportation equipment
27. Scientific, optical instruments
28. Communications
29. Utilities
30. Services
3 1 . Auto repairs
32. Government enterprises
33. Business travel, gifts
34. Miscellaneous Manufacturing
35. Scrap sales
Rail Transportation
(cents per dollar
of selling price)
2.0^
15.3
6.2
20.8
12.4
2.2
1.4
2.4
.9
7.5
2.3
5.1
1.4
3.8
2.0
1.0
3.8
3.9
2.7
1.8
2.7
1.7
1.1
2.9
.9
2.2
.6
.3
2.7
.5
1.0
4.4
2.2
2.7
14.5
% Increase in Selling
Price for a 1% increase
in Freight Rates
.02
.153
.062
.208
.124
.022
.014
.024
.009
.075
.023
.051
.014
.038
.020
.010
.038
.039
.027
.018
.027
.017
.011
.029
.009
.022
.006
.003
.027
.005
.010
.044
.022
.022
.145

-------
     The freight rate increase necessary to offset the increased costs due to retrofit are shown in
Table 7-39. This analysis assumes that there will be no reduction in freight volume as a result of
these price increases. Given the small increases, this is a reasonable assumption.  This analysis
should not be construed as a recommendation for a freight increase, nor is it assumed that one
would be granted.
                                     TABLE 7-39
    FREIGHT RATE NECESSARY TO OFFSET INCREASED COSTS DUE TO RETROFIT
                                     (In Millions)
1973 freight revenue
Retrofit cost (including fuel)
year 1
year 2
Percent increase in rates necessary
to recover all costs
year 1
year 2
Recurring costs
Percent increase in rates necessary
to recover all recurring costs
$13,793.7
49.23
54.78
0.36%
0.39%
$ 15.15
0.11%
                                       7-54

-------
                                        Sections

               ENVIRONMENTAL EFFECTS OF THE FINAL REGULATION
       Beginning in 365 days, the regulation being promulgated will stop the noise emitted by
railroad trains from increasing, and 4 years from the date of promulgation, will progessively
reduce the noise presently emitted by railroad locomotives. As a result, the number of people
currently subjected to annoying levels of railroad noise will be reduced.
       A detailed analysis of both the number of people presently adversely impacted by railroad
noise and the number who would potentially be relieved of such impact was presented in the Back-
ground Document for the proposed regulation. Since then studies utilizing different assumptions
have been instituted by the Agency to attempt to more clearly assess the nature and extent of rail-
road noise and its possible abatement. Both analyses are presented in this section.

INITIAL ANALYSIS OF IMPACT RELATED TO ACOUSTICAL ENVIRONMENT
Case Studies of Railroad Lines
       Ten cities with widely varying populations were selected to make detailed comparison of
train traffic with population densities near railroad tracks and with the type of land use adjacent to
tracks (see Table 8-1).  Such comparisons provide a basis for determining how many people are
exposed to railroad noise, how often they are exposed, and what activities they are engaged in at the
time.
       The schedules of trains moving over the railroad lines were determined from The Official
Guide of the Railways, July 1973 [26], or  from  employee timetables. Estimates of speed maxima
and minima were taken from employee timetables or obtained from railroad employees. Speeds for
AMTRAK trains were not  obtained.  The period between 10:00 p.m. and 7:00 a.m. was desig-
nated as night, and the rest of each 24-hour period was designated as day. Table 8-2 summarizes
the results of the 10 case studies.

Analysis of Train Noise Impact
       There are three major noise sources that contribute to L$n (see discussion of Ldn at the
end of this section for a definition of L^n) at point along and away  from railroad tracks: loco-
motives, wheel/rail interaction, and horns or whistles.
                                           8-1

-------
         TABLE 8-1
LAND USE NEAR RAILROAD LINES

City and State
Newton, Mass.
Boston, Mass.
Valparaiso, Ind.
St. Joseph, Mo.
Akron, Ohio
Somerville, Mass.
Michigan City, Ind.
ECalamazoo, Mich.
Altoona, Pa.
Ft. Lauderdale, Fla.
Lewiston, Maine
Denver, Colo.
Cheyenne, Wyo.
Cambridge, Mass.
Macon, Ga.
Average
Land Use Within 500 Ft of Track
(Percent)
Residential
75
59
43
42
40
30
29
22
16
12
12
12
9
8
_6_
28
Business
21
9
8
13
23
18
15
5
18
22
19
3
11
24
_4.
14
Industrial &
Other
4
32
49
45
37
51
56
73
65
66
68
85
79
68
90
Mileage
Studied
6
7
9
26
25
7
17
20
6
21
11
51
15
9
25.
58 Total 255
           8-2

-------
                                            TABLE 8-2
              TRAIN TRAFFIC AND COMMUNITY CHARACTERISTICS NEAR TYPICAL RAILROAD LINES
CITY ft STATE
Akron, Ohio
Altooni, P«.
Boston, Mm.
Cheyenne, Wyo.
Columbus, Ind.
Denver, Colo.
Durhun, N.C.
Mkhigm City, Ind.
Newton, Miss.
Valparaiso, Ind.
POPULATION
542,775
81,795
961,071
40,914
27,141
1,047^11
100,764
39,369
91,066
20,020
NUMBER OF
FREIGHT TRAINS
DAY
22
7
0
?
1
24
11
5
7
19
NIGHT
18
5
8
?
1
10
1
2
1
10
MAXIMUM
FREIGHT
SPEED (mph)
55
50
40
7
50
60
65
50
50
60
NUMBER OF
PASSENGER TRAINS
DAY
0
2
0
2
0
4
0
2
0
0
NIGHT
0
2
0
0
0
0
0
0
0
0
MAXIMUM
PASSENGER
SPEED (mph)
—
70 '
—
1
—
7
— .
50
—
—
LAND USE
(%}
RESIDENTIAL
40
16
59
9
1
12
?
29
75
43
BUSINESS
23
18
9
11
7
3
?
IS
21
8
OTHER
37
65
32
79
7
85
?
56
4
49
NO. OF PEOPLE
PER SQUARE MI.
WITHIN 500 FT
1,662
3,090
20,660
1,471
730
3,027
1,780
608
5320
1.528
MILEAGE
STUDIED
LAND USE
25
6
7
15
—
51
—
17
6
9
POPULATION
31
12
7
9
20
26
31
43
6
9
00
u>

-------
        Figure 8-1 shows some L$n profiles that were calculated by applying the prediction tech-
 niques to actual operations on a specific railroad line. The profiles shown in Figure 8-1 were
 calculated from the following data supplied by Penn Central:

        10:00 p.m. and 7:00 a.m.
        6 freight trains
        each 14 loaded cars and 10 empty cars
        40 mph
        and
        7:00 a.m. and 10:00 p.m.
        36 passenger trains, each
        40 mph

 Passenger trains with eight cars correspond to the national average passenger loading of cars [25].
 The curve for two cars is displayed to demonstrate the influence of the number of cars on the
 results.
        Since there are no crossings along the branch picked for this study, no whistle noise was
 considered. In addition to the usual geometric attenuation, atmospheric absorption and ground
 surface attenuation were included in the calculation for Figure 8-1. (See the discussion of Excess
 Attenuation of Railroad Noise at the end of Section 8.)
        Figure 8-2 shows L
-------
                                                          \      i  i i  i
                                               TOTAL
                                               FREIGHT LOCOMOTIVES
                                               FREIGHT WHEEL/RAIL
                                               PASSENGER LOCOMOTIVES
                                               (8CARS)
                                               PASSENGER WHEEL/RAIL
                                               (SCARS)
                                               PASSENGER LOCOMOTIVES
                                               (2 CARS)
                                               PASSENGER WHEEL/RAIL
                                                     \     \
      100
                     1000

DISTANCE FROM TRACK (FEET)
10000
Figure 8-1.  L^ vs Distance From the Track for the Dorchester Branch of Penn Central

-------
oo
         M

          z
          4.
          o
          CM
 •o
'
  c
 -o
                                                                TOTAL
                                                                FREIGHT LOCOMOTIVES
                                                                FREIGHT WHEEL/RAIL
                                                                PASSENGER LOCOMOTIVES
                                                                PASSENGER WHEEL/RAIL
                                                                WHISTLES a HORNS*
                                                          ** OBSERVER EVEN WITH CROSSING
                                                            SEE ATTACHED GRAPH FOR
                                                            COMPLETE PROFILES
                                                           \       ^
             30
                        100
                                                       1000

                                   DISTANCE FROM TRACK (FEET)
                                                                             10000
                                  TO Distance From Track for N$tional Avenge Train Traffic

-------
    20

    19

    18


-------
                80
                70
             O
             UJ


             O  60

             O
             z

             O
                .»
            UJ  50
            o
            X
            UJ

            tn

            UJ


            ?  40
             o
             Ul
X
UJ

UJ

Q.

8
a.
             to
             o
             O

             I-
                30
                20
                10
                           fO dB LOCOMOTIVE
                           QUIETING


                           5 dB LOCOMOTIVE
                           QUIETING

                           PRESENT EQUIPMENT
                 4O
                50
60
70
80
                     Ldn (EXCLUSIVE OF WHISTLES AND HORNS)


Figure 8-4.  Thousands of People Exposed to Various Ljn by 7.2 Miles of Track on the Dorchester

          Branch of the Perm Central
                                     8-8

-------
    20

    19
    18

to   17
i!   «
UJ
O   15
UJ
B   i4
5~ 13
                CO
              •S310
                o
              X Z  9
              O 13
              U
              <
              tr
              O
              (X
              UJ
              o
              Z
              Z
              CO
              5
                                            I
                                   10 dB LOCOMOTIVE
                                   QUIETING
                                    5 dB LOCOMOTIVE
                                    QUIETING
                                   PRESENT
                                   EQUIPMENT
                             I
                       I
                    40      50      60      70      80
                  Ldn(EXCLUS1VE OF WHISTLES AND HORNS)

Figure 8-5.  Distance From Track at Which Various Ldn Occur Due to National Average Train
          Traffic
                                    8-9

-------
                                 10 dB LOCOMOTIVE
                                 QUIETING
                                5 dB LOCOMOTIVE
                               QUIETING
                             PRESENT EQUIPMENT
           "40         50        60         70         80
              Ldn( EXCLUSIVE OF WHISTLES AND HORNS)
Figure 8-6.  Millions of People Exposed to Various L(jn by National Average Train Traffic
                              8-10

-------
       Population densities used to construct Figures 8-3 and 8-6 were obtained from the U.S.
Department of Commerce, Bureau of the Census. The census results show 28,098 people living
within 1000 feet of the 7.2 miles of track comprising the Dorchester Branch of Perm Central. The
population density in the first 500 ft next to the line was taken to be one-half of the density for
the entire region, in keeping with national trends.
       The figures for the number of people exposed to noise from national average train traffic
were based on estimates of 30,000 miles of railroad rights-of-way in urban areas in the U.S. Urban
areas are defined as the 40 Standard Metropolitan Statistical Areas (SMSAs) having average popula-
tion densities in excess of 500 people per square mile and a total population greater than 250,000.
The 40 SMSAs defined have a total land area of 58,200 square miles and a total population of
71,082,000, for an average population density of 1220 people per square mile.  This figure must be
modified, however, since there tends to be a concentration of industrial, commercial, and other
nonresidential activities in the vicinity of rail lines. Land use and zoning maps indicate that the
residential population density in the vicinity of a railroad line tends to be about 50 percent of the
average density for the entire region.

REFINEMENTS ON INITIAL ANALYSIS OF IMPACT RELATED TO ACOUSTICAL
ENVIRONMENT
       This discussion contains an estimate of the number of people exposed by noise from rail-
road trains to noise levels of L(jn = 55 dB or more. This analysis differs from the analysis in the
original Background Document; it contains  a more rigorous estimate of the number of miles of
track in urbanized areas and more conservative assumptions regarding the transmission of railroad
noise into communities. This discussion also contains a recomputation of the exposure estimates
given hi the Background Document on the basis of improved data regarding numbers of locomotives
and their average sound levels.
       The number of people exposed depends on five factors:

        1.   The number of miles of railroad track in urban areas
        2.   The population density near railroads
        3.   The number of train operations per day
        4.   The noise level of the trains
        5.   The propagation of the train noise into the community.

Each factor will be addressed in turn.

Miles of Railroad Track
        The original background document  cited a Federal Highway Administration/Federal Rail-
road Administration (FHWA/FRA) report (1971) to the effect that there are 30,000 miles of rail-
road track in urbanized areas in the United  States. The FHWA/FRA report cited no source for that
figure, and direct inquiry with those agencies did not uncover a rationale for its derivation.  In this
analysis, therefore, an independent estimate shall be derived.
        According to a survey of 106 cities  [52], the percentage of the land in  central cities presently
devoted to railroad averages  1.7 percent in  cities of 100,000 or more people and 2.4 percent in
                                           8-11

-------
 cities of 250,000 or more.  The total land area of central cities having populations greater than
 100,000 is approximately 9.84 X 103 sq mi [5 1 ] . If it is assumed that half of the land used by
 railroads is right-of-way (the remainder occupied by yards and terminals) and that the typical right
 of-way is 100 ft wide, the following calculations results:
           X  .017 X  9,840 mi2  X            =  4416 miles.
 Therefore, it is estimated that there are approximately 4000 miles of right-of-way in centra] cities.
        In another category of built-up areas, the urban fringe land area is 14,700 sq. mi. The per-
 centage of that land used by railroads is not known; a figure of 1 percent, therefore, is assumed, of
 which half is devoted to rights-of-way. A calculation similar to the preceding one gives a figure of
 388 1 miles of right-of-way, which is rounded to 4000. The estimate, therefore, of the total mileage
 in urban areas, the sum of mileages in central cities and urban fringes, is approximately 8000 miles.

 Population Densities
        Hoyt [51] gives 58.6 million as the total population of central cities having populations of
 100,000 or more. Dividing that figure by the total area of 9.84 X 103  sq mi. (see preceding discus.
 sion) gives an average density of 5.9 X 103 people per sq. mi. Census maps of land in the vicinity
 of central-city railroad lines indicate that the population density near rail lines is slightly less than
 half that of the local average [8] . One reason is probably the concentration of industrial and com-
 mercial property near rights-of-way. It is therefore estimated that the population density near
 central city rail lines is approximately 2500 people per sq mi.
       The population of the urban fringe is roughly 48 million.  Dividing by the area (14,700
 sq mi.) gives an average density of 3300 people per sq mi. Statistics on the density near railroad
 tracks are not available. It is reasonable to assume, however, that  the ratio of the density near
 tracks to the  average density is less than one, but greater than the  ratio for central cities because of
 the prevailing lower concentrations of industry and commerce in urban fringes. It is therefore esti-
 mated that the  near-tracks population density in urban fringes is 2500 people per sq mi., or the
 same density as was derived for the central cities.

Traffic Volume in Urban Areas
       Statistics  on the frequency of train movements along urban rights-of-way may not exist.
However, these statistics can be estimated on the basis of a study of train movements through high.
way grade crossings in urban areas [45] .  If it is assumed that the traffic observed at grade crossings
is a representative sample of traffic along the rail network as a whole, then the distribution of
traffic at grade crossings can be used to determine the statistics in which we are interested. The
distribution observed in Reference is given in Table 8-3.
       The mean of this distribution is approximately 8 trains per day.
       As a check on this figure, the average traffic on a random segment of railroad line can be
estimated from a knowledge of national train traffic totals. Tables 8-4 and 8-5 show the numbers
of miles of right-of-way, train-miles per year, and road locomotive-miles per year, as derived from
ICC statistics for  1971  (the latest year for which detailed data is available). From these statistics,
                                            8-12

-------
                         TABLE 8-3
           DISTRIBUTION OF URBAN GRADE CROSSINGS
                 BY VOLUME OF TRAIN TRAFFIC
Trains per Day
Oto2
3 to 5
6 to 10
1 1 to 20
21 to 40
over 40
Percent of Grade
40
18
20
13
6
3
Crossings






                          TABLE 8-4
COMPUTATION OF NATIONAL AVERAGE DIRECT-POWERED TRAIN TRAFFIC
Train
Type
Freight
Passenger
Miles of
Right-of-Way
(a)
210 X 103
40 X 103
Train-miles
per Year
(b)
425 X 106
42 X 106
Average Trains Per
Day Per Segment of
Right-of-Way
(b *a*365)
5.5
2.9
  'Source: ICC, 1971.
                            8-13

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                                      TABLE 8-5
                          AVERAGE TRAIN CHARACTERISTICS1
Train
Type
Freight
Passenger
Train-miles
per Year2
(a)
430 X 106
6.95 X 106
Road Locomotive
Miles per Year2
0>)
1280X 10«
100 X 10*
Locomotives
per Train
(b-a)
3.0
1.4
Car-miles
per Year2
(c)
29620 X 106
389 X 105
Cars per
Train
(c-a)
68.8
5.6
1 Figures include all forms of motive power.
2 Source:  ICC, 1971.

-------
the average number of trains per day over a segment of right-of-way and the number of locomotives
per train can be computed.  These are displayed in the third column of Table 8-4 and 8-5, respec-
tively, for freight and passenger traffic. If it is assumed that right-of-way in cities is used for both
freight and passengers, then it can be seen from the third column that the total average train traffic
(freight plus passenger) is 8.4 trains per day.  This total agrees with the previous estimate. Assuming
that freight trains are distributed randomly in time, it is estimated that at the average location four
freight and one passenger trains pass during the day (7 a.m. to 10 p.m.) and two freight and one
passenger trains pass at night.
        Average locomotives per train and cars per train are similarly developed in Table 8-5.  The last
characteristic, train speed, is obtained by inspection of railroad employee timetables for the North-
eastern United States. These timetables show 33 mph as the average maximum allowed speed for
freight trains and 36 mph for passenger.

people Exposed
        To determine the number of people exposed to various levels of L
-------
        The energy radiated by the cars in a train as measured at 100 ft is expressed as


        SENELc » 72 + 30 log ^  + 10 log t,                                       (8.3)

 where V is train speed in miles per hour and t is the passby time in seconds (Source:  Bender et aL
 1974).                                                                                 '
        For a train speed of 33 mph and a passby time of 73 sec (70 cars X 50 ft/car •*• 48 ft/sec),
                                             .
        SENELT = log ^Iog-i  -IQ-    + log'1  -io                               (8-4)

                 = 101.9dBAat 100ft.

 In the preceding expression, T denotes total.
        To compute the equivalent day-night energy level, the SENELs for all events are summed
 and divide by 24 hours, while the nighttime events are weighted by a factor of 10. Table 8-4 shows
 that approximately six trains move over the average segment of track each day. (Passenger trains
 are typically 10 to 20 dB quieter than freight trains and so are excluded from the exposure estimate
 (see figure IX. 15 of Reference 8.) Assuming that the train movements are distributed evenly through
 the day, this traffic breaks down into two night and four day events. The equivalent number of
 movements is therefore 2 X 10 + 4 = 24. The Ljn at 100 ft from a segment of average track is,
 therefore,

       Ldn  = SENELT + 10 log 24- 10 log (3600 sec/hr X 24hrs)
                                                                                    (8-5)
            = 66.3 dBA.

       The model for train noise propagation into communities is based on the model developed
 for urban highway noise by Kugler, Commins, and Galloway [72] .  The theory on which that
model is based shows the noise falloff with distance from the track (or highway) to be 4.5 dB per
doubling of distance. In addition, there will be another 4.5 dB of attenuation caused by the
shielding effects of the first row of buildings next to the track. This attenuation behavior is
approximated by using a straight line falling off at a rate of 6 dB per doubling of distance. This
approximation is reasonably accurate (given the uncertainty of the precise location of the shielding
buildings)  out to about 700 ft, which is beyond the limit of the range of interest. With this propa-
gation model and the L&n level at 100 ft (called L100), the range, r, to any Ljn level can be com-
puted using the expression

       r = 100 ft X  10
-------
in Table 8-6, which shows the distribution of people by L
-------
                 TABLE 8-6
PRESENT DISTRIBUTION OF PEOPLE BY
                             INTERVAL



Ldn
Interval
65-70 dBA
60-54
55-60
Distances
of Strip
Boundaries
from Track
(ft)
65-116
116-207
207-367

Width
of
Strip
(ft)
51
91
160
Aggregated
Area of
Strips
in U.S.
(sq. mi.)
155
276
485

People
Within
Strip
(million)
0.387
0.690
1.213
            TABLE 8-7
PRESENT AND PROJECTED POPULATIONS
 EXPOSED TO VARIOUS LEVELS OF Ldn
            (Cumulative)
Ldn
55 dBA
60
65
70
Millions of People Exposed to Given
Ldn or Greater
Present
2.29
1.80
0.39
—
4 dB Locomotive Noise
Reduction
1.77
0.83
0.30
—
               8-18

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                                      TABLE 8-8
                     DISTRIBUTION OF PEOPLE BY LH,, INTERVAL
                           ASSUMING MUFFLER RETROFIT
Ldn
Interval
65-70 dBA
60-65
55-60
Distances
of Strip
Boundaries
from Track
(ft)
51-90
90-160
160-285
Width
of
Strip
(ft)
39
70
125
Aggregated
Area of
Strips
in U.S.
(sq. mi.)
118
212
379
People
Within
Strip
(million)
0.295
0.530
0.948
the exposed population is weighted by its Fractional Impact (FIj), as given by the following
expression:*

       Fli =  0.05 (Li - 55) for LI > 55 dBA

       FIj =  0           for Li < 55 dBA

The ENI is then computed using the formula

       ENI = ]C Fli '  pi »
              i

where PJ is the population in the ith exposure interval.
       Applying these expressions to the population figures shown in Tables 8-6 and 8-8 gives the
results shown in Table 8-9. A muffler retrofit program will reduce the Equivalent Noise Impact by
151,000 people.

Impact Related to Land
       These regulations will  have no adverse effects relative to land.

Impact Related to Water
       These regulations will have no effect on water quality or supply.

Impact Related to Air
       The use of more efficient exhaust muffling systems can cause a change in the back pressure
to the engine and may result in a change in the exhaust emissions level. The data, at present, are
                                          8-19

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                                        TABLE 8-9
                     EQUIVALENT NOISE IMPACT FOR PRESENT AND
                         QUIETED LOCOMOTIVE POPULATIONS
Ldn
Interval
Population
Pi
(millions)
Fractional
Impact
Fi
FIjXPj
(millions)
Current Noise Impact
65-70 dBA
60-65
55-60
0.387
0.690
1.213
0.625
0.375
0.125
0.242
0.259
0.152
Total ENI = 0.653
Projected Noise Impact with Muffler Retrofit
65-70 dBA
60-65
55-60
0.295
0.530
0.948
0.625
0.375
0.125
0.184
0.199
0.119
Total ENI = 0.502
insufficient to make other than a general statement concerning the directions the various emission
levels take when a different back pressure is applied, since the behavior of the various engines and
exhaust emission control systems vary widely. However, internal combustion engine exhaust
emissions  are affected  by changes in exhaust system back pressure, and they must be con-
sidered. It is important to note, however, that motor carrier exhaust  emissions are higher
than rail carrier exhaust emissions  per ton  mile of  goods transported, indicating that,  in the
overall balance,  rail carriers are  already more efficient than motor carriers from  an exhaust
emission standpoint.
       It must also be noted that promulgating stricter rail carrier noise regulations at this time
may inadvertently divert cargo traffic from the rails toward motor carriers due to difficulties in
compliance with regulations, thereby causing an increase in total exhaust emissions to the atmos-
phere as well as increasing noise emissions.  Based on the analysis presented, problems such as this
are not expected to arise as a result of the proposed regulation.
                                         8-20

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DAY NIGHT EQUIVALENT NOISE LEVEL (Ldn)
       Lan is a modified energy-equivalent sound level. The energy-equivalent sound level
is the level of the continuous sound associated with an amount of energy equal to the sum of the
energies of a collection of discontinuous sounds. Leg is defined by
where NL is the instantaneous overall noise level in dB(A) at time t, and the time period of interest
is from time t! to time t2 . L^n is determined precisely like Lgq, except that all noise levels NL
measured at night (between 10:00 p.m. and 7:00 a.m.) are increased by 10 dB(A) before being
entered into the above equation.

EXCESS ATTENUATION OF RAILROAD NOISE
       Many mechanisms cause attentuation of s'«und beyond that caused by geometric spreading,
including molecular absorption in the air, precipitation, barriers, ground cover, wind, and tempera-
ture and humidity gradients.  The attenuation variest with location, time of day, and season of the
year.  To account for the attenuation produced by these highly variable sources, it is necessary to
compile detailed records of wind, temperature,  humidity, precipitation, and even cloud cover on a
statistical or probabilistic basis.  The following discussion  is directed at a base case that includes two
reliable sources of excess attenuation: atmospheric molecular absorption and attenuation associated
with variations in the physical characteristics of the atmosphere near the ground.  Both attenuations
vary with frequency.  The attenuation factors were evaluated for reference conditions of 50°F and
SO percent relative humidity.
       Figure 8-7 shows how atmospheric molecular absorption and variations of atmospheric
characteristics near the ground change the shape of the locomotive noise spectrum.  The high
frequencies become less important as the sound travels outward from the source. The attenuation
of the overall sound level (logarithmically summed octaveband sound levels) was found to be about
2 dB per thousand feet out to 400 ft.  That value was used to calculate the propagation of locomo-
tive noise described in this report. The value for the effective overall attenuation coefficient for
locomotive noise is about the same for throttle  position 8 and throttle position 1 .
       Figure 8-8 shows how the frequency-dependent attenuations change the shape of the spec-
trum of wheel/rail noise. Notice that here, too, the high frequencies become less important as the
sound travels outward from the source. The attenuation of the overall sound level (logarithmically
summed octaveband sound levels) was about 3 dB per thousand feet out to 3000 ft. That value
was used to calculate the propagation of locomotive noise described in this Background Document.
                                          8-21

-------
                  90
               ^n  80
               o
              M
              O
              o
              9  70
              o
u

UJ
_J
o
z

o

Q


00
UJ
              8
              a
              UJ
              £
               I
              
-------
                 80
                 70
             r— «
             ce
             <
             (D
              $.
             (VI
             o

             8  60
               •
             o
              o>
              CO
                 50
              LU
              >
              UJ



              Z  40
              D
              O
              CO
              S  30
              O
              o
                      I    I   1   I    I   I   I    I
                                    25'
          1000'
                       I
                                    3000'
I   i    I   I
rn
                   16     63    250   1000  4000
                      32     125    500    200   8000

                OCTAVEBAND CENTER FREQUENCY (Hz)


Figure 8-8. Influence of Frequency-Dependent Attenuations of Wheel/Rail Noise, Train No. 6,
         Region 2
                                  8-23

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                                    Section 9

                 ECONOMIC EFFECTS OF THE FINAL REGULATION
    The costs incurred in the muffling of newly manufactured locomotives may be more readily
identified than in the case of locomotive retrofit. The following discussion identifies the major
cost areas involved in the muffling of newly manufactured locomotives, including initial costs as
well as increased operating and maintenance costs incurred.

EQUIVALENT ANNUAL INCREASED LOCOMOTIVE MANUFACTURING COSTS ATTRIBUT-
ABLE TO MUFFLER INTRODUCTION
                                            Unit Incremental        Total Cost
                           No of             Manufacturing         (Millions of
       Type          Locomotives [8]           Cost 181             Dollars)

    GMRoad                843                $302543630         S2.55-S3.06
    GM Switcher             146                $ 242-$ 605         S0.04-S0.09
    GERoad                100                $1815              $0.18
                            1089                                   $2.77-$3.33
    Total Annual Manufacturing Cost = $2,770,000-$3, 330,000
    Total Annual Manufacturing Costs Expressed as a Capital Investment Depreciated Over 25 Years.
                                $110800            .  $I33i200
    Annual Incremental Manufacturing Costs = $110,800-$ 133,200
    Equivalent Annual Increased Manufacturing Costs (over 25 years, i = 12%)
                    = 6.77 x $110,800 + $110,800  =  $ 860,900
                    = 6.77 x $133,200 + $133,200  «  $1,034,900

    Equivalent Annual Increased Manufacturing Costs = $860,900-$ 1,034,900

    •   The A verage Cost Increase Per Locomotive Will Be
         $2550-$3060 per locomotive average cost increase.
                                        9-1

-------
         Expressed As a Percentage of New Locomotive Costs
         $337,000     '                    $337,000

         where $337,000 equals the 1975 average price of a new locomotive without a muffler
         [72].
              The addition of mufflers to newly manufactured locomotives should cause an
         approximately 0.75 to 0.91 percent unit price increase.

EQUIVALENT ANNUAL INCREASED FUEL COSTS ATTRIBUTABLE TO MUFFLER INTRO-
DUCTION ON NEWLY MANUFACTURED LOCOMOTIVES (OVER AN ESTIMATED 25-YEAR
FLEET REPLACEMENT PERIOD)
     •   Population of owned locomotives [68], assumed constant = 27,11 7.
     •   A verage No. of new locomotives manufactured annually = 1 089.
     •   Annual Fuel Cost Increase (Based on 1% Increased Consumption):
         After 25-yr. fleet replacement period* = $1 1,900,000.
         To determine an annual increased fuel cost for the initial 25 year period during which
         fuel costs attributable to muffled locomotives increase in a gradient fashion as the
         number of muffled locomotives similarly increases, the equivalent annual cost has been
         calculated:
         First Year Increased Fuel Cost:
           = 1089 new locomotive's x $1 1.900,000
                   27,1 17 fleet locomotives

           = $480,000

         Equivalent Annual Increased Fuel Cost (over 25 yrs., i = 1 2%):
           = 6.77 x $480,000 + $480,000
           = $3,730,000
         Equivalent Annual Increased Fuel Cost = $3,730,000.

MUFFLER REPLACEMENT COSTS
     It is anticipated that mufflers can be designed to last the life of the locomotive and will
require only highly infrequent replacement. Mufflers may be constructed of heat resistant, anti-
corrosive alloys that will extend their useful lives. Also an important consideration is the fact that
the muffler will be located within the carbody of the locomotive and will be sheltered from the
*$ 11,900,000 annual fuel cost increase computed by updating AAR's (1% or 40,000,000 gal./
year) increased fuel costs estimate of $11,600,000 at 1974 prices (29 cents/gal.) to 1975 price of
(30 cents/gal.).
                                        9-2

-------
harmful effects of exposure to the elements. Further, industrial mufflers have been designed to have
useful lives of more than .20 years and it is expected that locomotive mufflers may be designed for
similarly long life spans. Accordingly, it is expected that muffler replacement costs will be
negligible.

SUMMATION OF THE MAJOR COSTS INCURRED THROUGH THE ADDITION OF MUFFLERS
TO NEWLY MANUFACTURED LOCOMOTIVES:
     •   Annual incremental locomotive manufacturing costs attributed to muffler introduction:
                                $860,900-$ 1,034,900

     •   Equivalent Annual increased fuel costs (over 25 yrs., i =  12%);
                                $3.730,000

     •   Total Cost:             $4)590,900-$4,764,900

     •   Costs to be incurred by bankrupt and marginal railroads:
         Seven bankrupt railroads may absorb approximately 22 percent of the cost for the
         industry.*

         Eleven marginal railroads may absorb approximately 6 percent of the cost for the
         industry.

         NOTE:  (1)  All dollar amounts used in the preceding  discussion have been converted
                 from 1973 and 1974 dollars to 1975 dollars, using the Bureau of Labor
                 Statistic's "Wholesale  Prices and Price Indexes, WPI Code 24-4, Railraod
                 Equipment", 1975.
                 (2)  Annual equivalent costs are the equal annual annuity  payments made
                 on a hypothetical loan borrowed by the user of a product to pay for the
                 additional annual operating, maintenance, and capital expenditures incurred
                 over the life  of the product due to the application of noise abatement tech-
                 nology.  The principal of this hypothetical loan is equal to the total present
                 value of these initial and future expenditures.
 *Percentage estimates based on present locomotive ownership, assuming that these railroads will
 buy new locomotives in numbers proportional to the size of their present fleets.
                                          9-3

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                              SECTION 10
                    INDEX OF PUBLIC COMMENTS ON THE

          INTERSTATE RAIL CARRIER NOISE EMISSION REGULATIONS
DOCKET NO.
PERSON OR
ORGANIZATION
                   COMMENT
PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
R001
Mr. B. Leath
    Commented that railroad acoustic warning
    signals are ineffective due to often load
    noise levels that exist -in motor vehicle
    interiors
    Suggested that roadway drop gates equipped
    with flasher units provide adequate visual
    warning without acoustic signals
R002
State of New
York, De-
partment of
Environmen-
tal Conser-
vation,
Albany
1.  Suggested that the term "retarder" be elim-
    inated from Section 201.1

    Suggested that railroad warning devices be
    regulated

3.  Suggested test equipment and requested the
    specification of error tolerances within
    the measurement procedures

    Commented that the 100 ft. measuring dis-
    tance in the standards is too far
   2


   4


   45



   46
 •R004
 Shell Oil
 Company
1.  Suggested that the Federal standards should
    not apply to private-owned cars
   28
 R005
 ADM Company
1.  Commented that since a track standard was
    not included in the regulation, quiet rail-
    cars might be penalized  for wheel/rail
    noise caused by faulty track
  .  Commented that the EPA rail car noise stand
    ards would require greater maintenance  than
    that prescribed by the FRA  (1974) railroad
    freight  car safety standards already in ef-
    fect
   15
                                   10-1

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DOCKET  NO.
PERSON  OR
ORGANIZATION
                   COMMENT
PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
R009         1.  Commented that the proposed regulations        35
Mr. R.           would have a substantial adverse economic
  Harnden        impact upon bankrupt and marginal railroads

             2.  Commented that adequate information as to      40
                 the number of people impacted by railroad
                 noise or benefited by the regulation was
                 not provided
             3.  Suggested that the regulation of railroad      40
                 equipment in rural areas is not called for

R010         1.  Commented that adequate information as to      40
Mr. E.           the number of people impacted by railroad
  Schmidt        noise or benefited by the regulation was
                 not provided

             2.  Suggested that the regulation of railroad      40
                 equipment in rural areas is not called for
R011
U.S. Depart-
ment of
Transporta-
tion
1.  Suggested that the terms "retarder" and
    "sound pressure level" be eliminated from
    Section 201.1

2.  Questioned why EPA chose to regulate only
    certain railroad equipment and not all rail-
    road facilities and equipment at this time

3.  Suggested that retarder noise emissions be     10
    regulated

4.  Suggested that a regulation be promulgated     12
    to protect railroad workmen from retarder
    noise
5.  Suggested the inclusion of noise standards     16
    for refrigerator cars in the regulation

6.  Suggested that refrigerator car owners'        18
    ability to pay for mufflers be considered
    apart from the economic position of the
    railroads
7.  Questioned the acoustical acceptability of     24
    the typical load cell test site
                                 10-2

-------
DOCKET NO.
PERSON OR
ORGANIZATION
                   COMMENT
AGE  NO.
IF  REPLY
IY  EPA
N  DOCKET
ANALYSIS
R011
DOT (cent.)
 8.  Questioned the validity of the self load-
    ing test

 9.  Commented that local enforcement of sta-
    tionary standards could result in obstruc-
    tion of routine railroad operation

10.  Suggested a moving locomotive standard as
    a substitute for a stationary standard and
    that EPA's definition of wayside surface
    conditions be improved

11.  Commented that it is appropriate to limit
    any rail car regulation to curves of 2
    degrees or more

12.  Commented that the 270-day standards pro-
    vide a disincentive to rebuild old locomo-
    tives into compliance or to specify new
    locomotives be delivered with the mufflers
    needed to comply

13.  Suggested $153 million for retrofit as op-
    posed to original EPA estimates of $80-
    $100 million

14.  Suggested types of test equipment that
    should be utilized

15.  Suggested certain sound measurement param-
    eters in the regulation

16.  Requested more than 270 days to develop
    compliance regulations

17.  Suggested that EPA propose property line
    standards on railroad noise
   25


   25



   26




   27



   28
                                                                34



                                                                45


                                                                45


                                                                46


                                                                50
R012
Illinois
railroad
Association
 (IRA)
 1. Questioned why EPA chose to regulate only
    certain railroad equipment and not all rail
    road facilities and equipment at this time

 2. Commented that mufflers may cause excessive
    backpressure when applied to locomotives

 3. Commented that local  governments do not
    have the ability to determine the technical
    feasibility and cost  of compliance of noise
    regulations
   36


   43
                                  10-3

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DOCKET NO.
PERSON OR
ORGANIZATIOis
                   COMMENT
PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
R012  (cent.)
 4.  Commented  that  local governments  could
    make  the federal regulation meaningless by
    exercise of  their non-preempted regulatory
    authority
   49
R013
Association
of American
Railroads
(AAR)
1. Questioned why EPA chose  to  regulate only
   certain railroad equipment and not all rail
   road racilities and equipment at this
   time
2. Suggested that EPA should prescribe noise
   standards for area-type sources such as
   yards
3. Suggested that EPA establish noise limits
   applicable to noise from special purpose
   equipment

4. Commented that a muffler which meets the
   proposed full throttle standard is not
   likely to meet the idle requirement too
5. Commented that EPA understimated retrofit-
   muffler introduction costs
6. Commented that the proposed regulations
   may have substantial adverse economic im-
   pact upon bankrupt railroads

7. Commented that mufflers may cause excessive
   backpressure when applied to locomotives
   and warned of increased chemical and
   particulate air emissions

8. Commented that carbon collection in mufflers
   presents a potential fire hazard

9. Commented that increased railroad rates to
   cover compliance costs may divert traffic
   to more fuel intensive and polluting modes


0. Commented that the application of mufflers
   will result in decreased reliability of
   locomotives
                                                                13



                                                                20



                                                                29


                                                                35



                                                                36



                                                                37


                                                                37




                                                                38
                                10-4

-------
DOCKET NO.
PERSON OR
ORGANIZATION
                  COMMENT
 'AGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
R013 (cont.)
(AAR)
1. Commented that muffler manufacturers would      39
   have difficulty in designing mufflers for
   particular engines unless they knew all the
   parameters of the engines involved
2. Suggested information be given as to whethej    40
   people were adversely affected by railroad
   noise from a health and welfare standpoint
   initially
3. Commented that, as a matter of statutory        42
   interpretation, EPA must regulate all rail-
   road noise sources according the noise con-
   trol act of 1972
4. Commented that the setting of federal emis-     43
   sion standards for locomotives and railcars
   should preempt every effort to control nois
   from that same equipment by local authorities
 R015
 Department  o
 Environments
 Quality,
 Portland,
 Oregon
1. Suggested that railroad warning devices be
   regulated
2. Commented that acoustic warning devices are
   not needed around railroad yards
      4


      6
 R016
 Fruit
 Growers Ex-
 press Com-
 pany , et.  al
 1.  Questioned why  EPA chose  to  regulate only
    certain railroad  equipment and not all  rail-
    road facilities and equipment  at  this time
 2.  Suggested the inclusion of noise  standards
    for refrigerator  cars in  the regulation
 3.  Requested an extension of the  period of
    time prior to promulgation of  the final
    regulation so that refrigerator car noise
    emissions could be studies in relation  to
    wheel/rail noise
     16

     18
                                                                                  4
                                  10-5

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DOCKET NO.
PERSON OR
ORGANIZATION
R017
Salt River
Project,
Phoenix,
Arizona
R018
National
Railroad
Passenger
Corporation
CAMTRAK
R019
Illinois
Environmental
Protection
Agency
R020
Donaldson
Company, Inc.
COMMENT
1. Commented that backpressure increase from
muffler installation will cause an increase
in fuel consumption
2. Suggested that the regulation of railroad
equipment in rural areas is not called for
1. Suggested separate regulations dealing with
passenger related cars equipped with
auxiliary power equipment
2. Commented that diesel electric locomotives
equipped with auxiliary power generators or
twin traction engines, and gas turbine
locomotives, may not be able to meet the
idle standard
3. Suggested that the moving locomotive stand-
ard should be speed related
4. Suggested certain sound measurement para-
meters in the regulation

1. Questioned the absence of track and right-
of-way standards in the proposed regulation
-^— — — — ———^~~'^~
1. Commented that muffler costs will be higher
than EPA estimates
2. Commented that mufflers may cause excessive
backpressure when applied to locomotives
3. Commented on retrofit problems of certain
types of locomotives
4. Commented that muffling/silencing systems
cannot be developed independently of the
locomotive manufacturers
PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
36
40
16
22
26
45
15
34
36
39
39
10-6

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DOCKET NO.
PERSON OR
ORGANIZATION
                  COMMENT
PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
R021
Minnesota
Pollution
Control
Agency
1.  Questioned the absence of track and right-
   of-way standards in the proposed regulation
2.  Questioned the interpretation of the pro-
   vision in the act for special local deter-
   minations
    15

    48
R023
Forestry De-
partment ,
Salem,
Oregon
1. Suggested that EPA consider the production
   and control of carbon particles in the
   locomotive exhaust
    36
R024
Town of
Bloomfield,
New Jersey
1. Commented that inadequate information was
   provided as to the number of people impacted
   by railroad noise nor the number to be bene-
   fited by the regulation

2. Requested that local railroad noise
   regulations not be prohibited by the EPA's
   regulatory action

3. Requested that EPA impose property line
   standards on railroad noise
    40
                                                                 48
                                                                  50
R025
General
Motors Cor-
poration
 (GM)
1. Commented on the proposed idle standard
2. Questioned the validity of the 6dB(A) con-
   version factor for changing measurements
   made at 50 ft. to an equivalent 100 ft.
   value
3. Commented that muffler installation will
   not always provide a 6dB(A) reduction of
   all locomotive noise levels
4. Questioned the distance at which  the meas-
   urements on noise emissions of an EMD
   6P40-2 locomotive were made
     20
     51
                                                                  51
                                                                  52
 R026
 Mr.  K.  K.
 King
 1.  Commented  that  the  proposed  regulations
    would have a substantial adverse economic
    impact upon bankrupt  railroads
     35
                                  10-7

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DOCKET NO.
PERSON OR
ORGANIZATION

R026 (cont.)
King




R028
South
Carolina
Department of
Health and
Environmental
Control

R029
City of
Chicago, De-
partment of
Environmental
Control



5030
Citizens
Against
Noise


5043
Mr. G.W.
Kamperman,
Kamperman
Associates


COMMENT


2. Commented that adequate information as to
the number of people impacted by railroad
noise or benefited by the regulation was
not provided
3. Suggested that the regulation of railroad
equipment in rural areas is not called for
1. Suggested that railroad warning devices
be regulated
2. Commented that acoustic warning devices are
not needed around railroad yards
3. Suggested that the standards be reviewed
periodically and strengthened as technolog-
ical advances are made
1. Commented that the 100 ft. measuring dis-
tance in the standards is too far
2. Commented on the interpretation of the
provision in the act for special local
determinations

3. Suggested that local railroad noise regula-
tions not be prohibited by the EPA's
regulatory action
1. Suggested the reduction of railroad warning
devices through the authority of the noise
control act
2. Suggested that the regulation be made
applicable to the operation of intraurban
mass transit systems
1. Suggested that the C-scale would be mote
appropriate for this regulation than the
A-scale


PAGE NO.
OF REPLY
BY EPA
IN DOCKET
ANALYSIS
40



40

4

6
49


46

48

48


5


19

•
45




10-8

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                                          REFERENCES

 (1).  Altman, E.I. (1971). "Railroad Bankruptcy Propensity,"/. Finance, Vol, XXVI, pp. 333-346.
 (2).  American Association of Railroad Superintendents (1972). "Computers - Who Needs Them?"
           Report of Committee No. 3, Annual Meeting.
 (3).  Baker, P.H., General Electric Co. (1973). Oral presentation before the Environmental Protection
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 (4).  Bender, E.K. et al. (1974). "Railroad Environmental Noise: A State of the Art Assessment,"
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 (5).  Betts, W.F. (1973). "Verified Statement before the Interstate Commerce Commission in Support
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 (6).  Beranek, L.L., Ed. (1971). Noise and Vibration Control, New York: McGraw-Hill Book Co.
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           teristics System (MACS)," Railroad International, October.
 (8).  Bolt Beranek and Newman Inc. (1973). "Contribution to Background Document for Rail Carrier
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 (9).  Bolt Beranek and Newman Inc. (1975). "Comparison of Alternative Strategies for Identification
           and Regulation of Major Sources of Noise," Report No. 2966, prepared for the Environmental
           Protection Agency under Contract No. 68-01-1547.
(10).  Burlington Northern Railroad Co. (undated). Diesel Locomotive Diagrams.
(11).  Coelen, C. (1973). Properties of the Adjustment Equation in a Model of the Demand for Workers.
           Unpublished Ph.D. dissertation. Syracuse:  Syracuse University Department of Economics.
(12).  Fair, R.C.  (1969). The Short-Run Demand for  Workers and Hours, Amsterdam North Holland
           Publishing Company, 1969.
(13).  Anon., "Retarders Are Key to Yards," Railway System Controls, June 1973.
(14).  Altman, Edward I. (1971), "Railroad Bankruptcy Propensity," Journal of Finance, Vol XXVI,
           pp. 333-346.
(15).  American  National Standard Specification  for Sound Level Meters, Sl.4-1971.
(16).  Bietry, M. (1973), "Annoyance Caused by Railroad Traffic Noise," Proceedings of a Congress on
           Traffic Noise, Grenoble, France, Jan.  9, 1973.
(17).  DOT (1970),  "A Study of the Magnitude of T%i^ttation Noise Generation and Potential Abate-
           ment, Vol. V, Train System Noise," U.S. Department of Transportation Report No.
           OST-ONA-71-1.
                                               Ref-1

-------
 (18).  DOT (1971), "Noise and Vibration Characteristics of High-Speed Transit Vehicles," U.S. Depart-
           ment of Transportation Report No. OST-ONA-71 -7.
 (19).  Embleton, T.F.W. and G.J. Thiessen (1962), "Train Noises and Use of Adjacent Land," Sound,
           1:1, pp. 10-16.
 (20).  EPA Docket 7201001.
 (21).  Friedlaender, Anne (1969), The Dilemma of Freight Transportation Regulations, Brookings Insti-
           tution, Washington, D.C.
 (22).  Kendall, Hugh C. (1971), "Noise Studied in Retarder Yards," Railway Systems Controls, July 1971
           pp. 9-13.
 (23).  Kurze, U. and L.L. Beranek, "Sound Propagation Outdoors" Noise and Vibration Control, edited
           by L.L. Beranek, McGraw-Hill, 1971.
 (24).  Kurze, U.J., E.E. Ungar, and R.D. Strunk (1971), "An Investigation of Potential Measures for the
           Control of Car Retarder Screech Noise," BBN Report No. 2143.
 (25).  Moody's Transportation Manual (1971).
 (26).  National Railway Publication Company (July 1973), The Official Guide to the Railways.
 (27).  Rand McNally & Co. (1971), Commercial A tlas and Marketing Guide.
 (28).  Railway System Controls (1972), "BN Studies Retarder Noise Abatement," Railway System
           Controls, November 1972, pp. 14-20.
 (29).  Rickley, E.J., R.W. Quinn, and N.R. Sussan (1973), "Wayside Noise and Vibration  Signatures of
           High Speed Trains in the Northeast Corridor," Department of Transportation  Report No.
           DOT-TSC-OST-73-18.
 (30).  Rapin, J.M. (1972), "Noise in the Vicinity of Railroad Lines. How to Characterize  and Predict It,"
           Centre Scientifique et Technique du Batiment, Cahiers, Building Research Establishment,
           Garston, Watford, WD2 75R.
 (31).  Ratering, E.G., "The Application of Vehicle Noise Test Results in the Regulatory Process,"
           Conference on Motor Vehicle Noise, General Motors, April 3-4, 1973.
 (32).  Rathe, E.J. (1968), "Effect of Barriere on the Noise of Railroad Trains," Eidgenossiche Material
           Prufungs-und Versuchsanstatt fur Industrie, EMPA No. 38 155/2, Bubendorf (in German).
 (33).  Ringham,  R.F. and R.L. Staadt, International Harvest Company Presentation to Environmental
           Protection Agency Office of Noise Abatement and Control, San Francisco, Calif., September
           1971.
(34).   Schultz, T.S. (1972), "Some Sources of Error in Community Noise Measurement," Sound and
           Vibration, 6:, 2, pp. 18-27,
(35).   Schultz, T.S. (1971), "Technical Background for Noise Abatement in HUD's Operating Programs,"
           Bolt Beranek and Newman Inc., Report No. 2005R.
(36).   Ungar, E.E., R.D. Strunk, and P.R. Nayak (1970), "Ah Investigation of the Generation of Screech
           by Railway Car Retarders," BBN Report No. 2067.
                                                Ref-2

-------
(37).  U.S. Bureau of Census, Census of Housing (1970), Block Statistics, Final Report HC(3).
(38).  U.S. Bureau of Census, U.S. Census of Population (1970), Number of Inhabitants, Final Report
           PC(1) - Al, United States Summary.
(39).  Wilson, G.P. (1971), "Community Noise from Rapid Transit Systems," in Noise and Vibration
           Control Engineering, Proceedings of the Purdue Noise Control Conference, July 14-16, 1971,
           p. 46, at Purdue University, Lafayette, Ind., edited by Malcolm J. Crocker.
(40).  Wyle Laboratories (1973), Preliminary Data from Wyle Laboratories Research Project No. 59141,
           "Communities Noise Profiles for Typical Railroad Operations."
(41).  "Business Week", McGraw-Hill, Inc., Sept. 8, 1923, p. 63.
(42).  "Railway Age," Simmons Boardman Publishing Corp, Jan.  27, 1975, p. 68.
(43).  Bolt, Beranek & Newman, Report No. 2709, "Rail Environmental Noise: A State of the Art
           Assessment," Cambridge, Mass.
(44).  E.K. Bender and M. Heckl (1970), "Noise generated by Subways above Ground and in Stations,"
           DOT Report No. OST-ONA-70-1 (January 1970).
(45).  Federal Highway Administration and Federal Railroad Aministration (1971). "Report to Congress:
           Railroad Highway Safety, Parts I and II."
(46).  Ferguson, C.E. (1969).. The Neoclassical Theory of Production and Distribution, Cambridge
           University Press.
(47).  Friedlaender, A.  (1969). The Dilemma of Freight Transportation, Washington, D.C.:
           Brookings Institution.
(48).  Frisch, R. (1965).  Theory of Production, Chicago:  Rand McNally & Co.
(49).  General Motors Corporation (1974). "Locomotive Exhaust Muffler Retrofit; Cost Study Reports
           Nos. 1-4."
(50).  Hultgren, T. (1960).  Changes in Labor During Cycles, New York: New York National Bureau of
           Economic Research.
(51).  Hoyt, H. (1968). Urban Land Use Requirements, 1968-2000, Homer Hoyt Institute, The American
           University, Washington, D.C., Research Monograph No.  1.
(52).  Manvel, A.D. (1968). "Land Use in  106 Cities," in Three Land Research Studies, National Com-
           mission on Urban Problems, Research Report No. 12.
(53).  McGaughey, R.S., Gohring, K.W., and McBrayer, R.N. (1973). "Planning Locomotive and Caboose
           Distributions," Rail International, November-December.
(54).  Murray, R.F. (1971), "Lessons for Financial Analysis," /. Finance, May, pp. 3275-3332.
(55).  New Jersey, State of. "Measurements of Locomotive Noise at Secaucus Shops, Erie Lackawanna
           Railroad," Docket submission to Department of Public Utilities, State of New Jersey  Docket
           No. 7312-1013.
(56).  Osthoff, F.C. (1974). "Railway Motive Power - 1973," Railway Locomotives and Cars, New York:
           Simmons Boardman Publishing Corp.
(57).  Peabody & Associates, Inc. (1974). "Analysis of the Costs of Compliance to the Proposed Interstate
           Rail Carrier Noise Emission Regulation," Report to the  EPA.
                                                Ref-3

-------
 (58).  Pinkepank, J.A. (1973). The Second Diesel Spotter's Guide, Milwaukee: Kalmback Books.
 (59).  Primbramsky, R., General Motors Copr. (1913). "Diesel-Electric Locomotive Noise Emission,"
            oral presentation before the Environmental Protection Agency and the Association of
            American Railraods, Washington, D.C., August 8.
 (60).  Remington, P.J., Rudd, MJ. and Ver, I.L. (1975). "Wheel/Rail Noise and Vibration; Vol. 2:
            Applications to Control of Wheel;Rail Noise," DOT Report UMTA-MA-06-0025-75-10.
 (61).  Rudd, M.J. and Blackman, E.S. (undated). "Computer Program for Predicting the Propagation of
            Railroad Noise," Bolt Beranek and Newman Inc. Technical Memorandum No. 199.
 (62).  Swing, J.W. and Pies, D.W. (1973). "Assessment of Noise Environments Around Railroad
            Operations," Wyle Laboratories Report WCR 73-5.
 (63).  Railway Equipment and Publication Co. (1973). Railway Line Clearances, Annual Issue.
 (64).  Rickley, E.J., Quinn, R.W., and Sussan, N.R. (1974). "Noise Land Measurements of Railroads:
            Freight Yards and Wayside," Department of Transportation  Report No. DOT-TSC-OST-73-46.
 (65).  U.S. Environmental Protection Agency (1974a). "Background Document/Environmental
            Explanation for Proposed Interstate Rail Carrier Noise Emission Regulations," Report No.
            500/9-74-005a.
 (66).  U.S. Environmental Protection Agency (1974b). "Information on Levels of Environmental Noise
            Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety," Report
            No. 500/9-74-004.
 (67).  U.S. Interstate Commerce Commission (1972). Eighty-Fifth Annual Report on Transport
            Statistics in the United States for the Year Ended December 31,1971.
 (68).  U.S. Interstate Commerce Commission (1974). Class I Railroads; Financial and Operating Statistics
           for the Twelve Months Ended December 31,1973; Statement No. 100.
 (69).  Wilson, T.A. and Echsten, O. (1964). "Short-Run Productivity Behavior in U.S. Manufacturing,"
           Review of Economic and Sta tistics, Vol. XLVI, pp. 41 -54.
(70).  Bellis, M.W., General Electric, from letter to BBN, Oct. 21, 1974.
(71).  Kugler, Cummins, and Galloway, "Design Guide for Highway Noise Prediction and Control,"
            Report NCHRP3 713, Transportation Research Board, National Academy of Sciences,
           November 1974.
(72).   "Transport Statistics in the U.S.; Year ended December 1970; Part I, Railroads; Table 37, p.  15.
                                               Ref-4

-------
Railroad Contacts
    Personnel in the operations departments of the following railroads were contacted in the
course of this study.
    AMTRAK
    Atchison, Topeka, and Santa Fe
    Baltimore and Ohio
    Boston and Maine
    Burlington Northern
    Chesapeake and Ohio
    Chicago, Milwaukee, St. Paul, and Pacific
    Chicago and North Western
    Chicago and North Western
    Chicago, Rock Island, and Pacific
     Denver and Rio Grande Western
     Durham and Southern
     Gulf, Mobile, and Ohio
     Illinoise Central Gulf
     Louisville & Nashville
     Norfolk Southern
     Norfolk and Western
     Penn Central
     Union Pacific
     Yard superintendents, yard masters, or engineering department personnel with the following
 railroad companies were contacted in the course of this study.
     Chicago, Milwaukee, St. Paul, and Pacific Railroad Yards,
     Bensenville, Illinoise
     Chesapeak & Ohio/Baltimore & Ohio Railraod Yard,
     Walbridge, Ohio
     Illinois, Central and Gulf Railroad Yard
     Markham, Illinois and Centreville, Illinois
     Norfolk & Western Railroad Yard,
      Bluefield, West Virginia
      Penn Central Railraod Yard,
      Elkhart, Indiana
      Boston and Maine Railroad Yard,
      Mechanicville, New York
                                           Ref-5

-------
 Southern Pacific Railroad Yard,
 Roseville, California
 Union Pacific Railroad Yard,
 Cheyenne, Wyoming
 Burlington Northern Railroad
 Chicago, Illinois and St. Paul, Minnesota
 Miscellaneous contacts in the railroad, or related, industry
 Association of American Railroads, Research and Test Department
Washington, D. C.
General Electric Company
Erie, Pennsylvania
General Electric Company Sales
Chicago, Illinois
General Motors/EMD
Lagrange, Illinois
                                     Ref-6

-------
                           Appendix A

MAJOR TYPES OF DIESEL-ELECTRIC LOCOMOTIVES IN CURRENT U.S. SERVICE
                       (1 JANUARY 1973)

-------
Manufacturer
3er.eral Motors
' ~1 of •f-T>_".*nt- 1 \rc
division)
*
*•—
I
Type
5v; it cher







General Purpose
Special Duty
Road Switcher
I
Model
NW2
NV/3,5
SW1
SW8
SW600
SW900
SW7
SW9
SW1200
svaooo
SW1500
GP/SD 7/7B
GP/SD 9/9B
GP/SD 18/28
GP 20
SD 24/24B
GP 30/30B
GP/SD/35
GP/SD 38
H.P. c
1000
1000
600
800
600
900
1200
1200
1200
1000
1500
1500
1750
1800
2000
2^00
2250
2500
2000
Turbo-
harged
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
Muffler
Type
A
A
A
A
A
A
A
A
A
A
A
B
B
B
C
C
C
c
B
Number
Sold
1119
20
660
306
15
260
^93
786
737
168+
546+
2803
4072
426
335
224
946
1645
1103*
Years
39-49
39-47
39-56
50-54
54-62
54-65
49-51
51-53
54-66
66-
66-
49-54
54-59
59-65
59-62
58-63
61-63
63-66
66-
Number In
Class I

721
J
^

' 628


• 1618
.
168+
546+
2550
3603
400
300
200
940
1642
1103+
Service
Class II

137


107


305
, .... .

—
133
21
9
i
%•>
—
3
3

-------
Manufacturer
C-er.eral Motors
(Electro-Motive
^ iV -5 ion ;





*•
10




General
Electric




Type
Road Switcher




Streamlined
Cab/Booster
Freight/
Passenger


Passenger Only
(Twin Engines)

Switcher


Road Switcher

!
Model
GP"39
GP/SD 40
SD 45
DD 35A/35B
DDA 4 OX
FTA/FTB
F2A/F2B
F3A/F3B
F7A/P7B
F9A/F9B
E7A/7B
E8A/E8B
E9A/E9B
44 ton
70 ton
95 ton
U25B/C
U28B/C
U23B/.C
H.P.
2300
3000
3600
5000
6600
1350
1350
1500
1500
1750
2000
2250
2400
400
500-
660
buu--
660
2500
2800
2250
Turbo-
charged
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Muffler
Type
• c
c
c
2C
2C
B
'B
B
B
B
-
-
-
-
-
-
D
D
D .
Number
Sold
87
2217 +
1362 +
45
47
1096
76
1801
3982
235
510
457
144
334
193
46
591
219
212+
Years
6.9-7.0..
66-
65-
63-65
69-71
39-45
46
45-49
49-53
54-57
45-49
49-53
54-63
40-56
46-58
49-56
59-66
66
68-
Number I
Cla.ss I
84
2213 +
1362+
45
47
| «
J
440
1207
205
245
226
.88

[• 18
J
- 524
. 219
212+
n Service
Cla_ss II
. 3
J:
	 . '
	
	
	

	
	
--
__
--
.

95

—
—
— , •

-------
1
Manufacturer
General
Electric
Alco
*
oj
Type
Road Switcher



Switcher


Road Switcher
Model
U30B/C
U33B/C
U36B/C
U503/C
Sl/3
S6
T6
S2/4
RS1/RSD1
RS2
RS2/3
RSD4/5
RS11/12/36
C415
RS32
C-420
RSD7/15
RSD2?
C-424
C-425
C-623
H.P.
3000
3300
3600
5000
660
900
1000
1000
1000
1500
1600
1600
1800
1500
2000
2400
2400
2500
2750
Turbo-
charged
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Muffler
Type
D
D
D
2D
-
E
E
E
E
E
E
E
D
D
D
D
D
D
D
Number
Sold
470+
497
157
66
653
100
55
2012
497
400
1312
203
436
26
164
102
80
91
135
Years
66-
67-
69-
63-70
40-53
55-60
58-69
40-61
41-60
46-50
50-56
51-56
56-63
66-68
61-68
54-60
59-67
64-66
63-68
Number Ir
Class I
470+
497+
157 +
66
! 92
]

• 681

76
1 564
]
348
26
121
] 119

89
91
i Service
Class II
__
—
—
—
7 Q


2Q3

i-l
_>
30

11
—
1
--
—
—
—

-------
Manufacturer
Alec





Baldwin
Li.T.a Kanilton
*
^


Fairbanks
Morse


V.Taitcomb
Plymouth
Ccoper Bessemer
Type
Road Switcher

Streamlined
Cab/Booster


Switcher


Road Switcher

Streamlined
Switcher

Road Switcher

Switcher
Switcher
Switcher
Model
C-430/630
C-636
FA/FBI
FA/FB/2
PA/PB1
PA/PB1/2/3
S-8
DS-4-4-10
S-12
RS-12
DRS-N-16
RS-N16
RF16/16B
H10-44
H17-44
H16-44/66
H24-66



Turbo-
H.P. charged
3000 Yes
3600 Yes
1500 Yes
1600 Yes
2000 Yes
2250 - Yes
800 No
1000 Yes
1200 Yes
1200 Yes
1600 Yes
1600 Yes
1000 No
1200 No
1600 No
2400 No
600
300
1200
Muffler
Type
D
D
-
-
-
-













Number
Sold
93
34
581
491
210
84
61
433
449
46
447
160
197
306
384
105



Years
66-68
67-68
46-50
50-56
46-50
50-53
50-54
46-51
51-56
51-56
47-55
50-53
44-49
50-58
50-63
53-56



Number I
Class I
84
31
—
—
—
—
22
136
190

36

40
164
105
31
—
I

n Service
Class II
—
—
—
—
—
—
15
46
3c

29

6
a
—
.
5
3
7

-------
Manufacturer
v. * »'•
Cu.Tjr.ins
H.K. Porter
Type
Switcher
Sv;itcher
Model



H.P.
0
170
500
Turbo-
charged



Muffler
Type



Number
Sold



Years



Number I
Class I
21


n Service
Class II
—
4
T

-------
                         Appendix B

REVIEW OF THE USE OF AUDIBLE TRAIN-MOUNTED WARNING DEVICES AT
          PROTECTED RAILROAD HIGHWAY CROSSINGS

-------
             REVIEW OF THE USE OF AUDIBLE TRAIN MOUNTED



             WARNING DEVICES AT PROTECTED RAILROAD -



             HIGHWAY CROSSINGS





B.I  Requirements For the Use of Audible Warning Devices



     The stopping distance of trains is much longer than



that of motor vehicles, they are much more difficult to



reaccelerate, and due to their length they often overlap



more than one road intersection at a time.  Therefore,



trains have traditionally had the right-of-way at level



crossings, while motorists are expected to look out for



trains and give way.  The burden is then placed upon



the railroad to assist the motorist in determining when



a train passage is imminent.  The traditional method of



doing this is to sound a whistle and/or bell and keep  a



headlight burning on the head ends of all trains, and  to



mark the crossing in some manner so as to attract the



attention of approaching travelers.



     Public Railroad-Highway grade crossings may be equipped



with one of the following, which are classified herein



into the three major headings shown:



      (a)  Unprotected



           (1)  Unilluminated  stop-look-listen  sign  or



"cross buck" at the crossing  generally accompanied  by



striping and words painted  on the  road surface and  passive



prewarning signs  in advance of  the crossing.





                            B-l

-------
          (2)  As above, plus continuous  (night time)
illumination of the crossing and/or the signs.
          (3)  As above plus flashing amber caution lights.
          (4)  Any of the above, plus "rumble strips11 on
the road surface.
     (b)  Protected (no gates)
     This group of systems may employ combinations of the
signs,lights, markings, etc. from  (a) above, but is distin-
guished by the addition of:
          (1)  Flashing lights generally plus bells, which
are actuated upon the approach of the trains(s) by virtue
of automatic electrical signals attached to the tracks.
These systems are arranged to be fail-safe, in that most
internal failures cause the signal to indicate the approach
of a train.
          (2)  Traffic lights may be used in some places,
in lieu of the characteristic flashing crossing lights,
but also conveying the intelligence that a train(s) is in
fact in the vicinity.
          (3)  Watchmen, stationed at the crossing, or
trainmen walking with their train, will "flag" motorists
or may activate lights or other devices.
     (c)  Protected With Gates
     In addition to active signals and advance warnings
as in (b) physical barriers are automatically dropped in
the motorists' path upon the approach of the train(s),
often with lights attached thereto.
                           B-2

-------
These gates may interrupt only the approaching highway
lanes (half gates)  or both lanes on each side (to discourage
driving around) and may be .supplemented by small
pedestrian gates at walkways.  However, these gates are
not constructed so as to physically restrain vehicles, but
are really a type of "sign", intended to assure driver
                        i
attention and realization that a train is to be expected.
Gates are commonly used at busy crossings where there are
two or more tracks, to add a degree of protection against
motorists proceeding as soon as one train has passed, when
there may be one approaching on another track.
     The cost of installation of crossing signals varies
widely and depends greatly upon particular local circum-
stances.  Modest installations with gates average about
$30,000, and may be as high as $60,000.  The annual cost
of inspecting, maintaining, and repairing protected
crossings is about $1,000 each, not including the cost
of roadway and track work.
     Complete grade separations may cost hundreds of
thousands of dollars, or even millions, and while many
are being constructed, the number  is not statistically
significant within the context of  the  overall problem.
 (When separations are installed, it is usually  possible
to arrange for the outright  closing of a few nearby
crossings, thus expanding  the safety benefit of this
large investment.)

                             B-3

-------
      The  level  of  crossing protection installed at a
 particular  location  is  determined by the hazard involved
 which is  effected  by the amount of road traffic,  the
 number and  speed of  trains passing and topography.   This
 may be determined  by the judgement of local  officials,
 the railroad managements,  or  both and is often established
 simply by a past record of accidents at a crossing in
 question.   The  investment in  crossing equipment may be
 the responsibility of the railroad,  the State  or  local
 government, the Federal government or any combination
 thereof.  This  question has been the subject of much
 controversy in  the past,  and  is  in a state of  flux
 at present, with the trend being toward greater govern-
 ment  responsibility  although  some railroads  continue to
 spend large sums of  their  own money  on  new systems  every
 year.   Automatic signal  system maintenance has  always
 been  the  responsibility  of  the railroad.
      Train-born signals  to  warn motorists and pedestrians
 of the  approach of trains are required  by most  States.
 Federal safety regulations  are confined  to the  inspection
 of such devices on locomotives, to the  end that -  if
 present - they shall be  suitably  located  and in good
working order (Safety Appliance Act,  45 USCA; 49 Code of
 Fed.   Regulation 121, 234, 236, 428,  429).  The  Federal
government has shunned greater regulatory responsibility
 in this field in the past.  There  is  a very significant

                            B-4

-------
Federal research and promotional effort underway to
improve grade corssing safety, however.
     The State laws requiring train-born signals do
not quanlify their loudness.  It is common for the State
laws to quatify the requirement to apply all public
crossings except in municipalities, leaving the use of
horms or bells in towns and cities to local discretion.
     A survey of the 48 contiguous States yields the
following summary of information regarding their
regulations:
     .. Requirements for sound signals at public crossings
        imposed by:
          Statute                       38
          Public Utility Commission      1  (Calif.)
          Common Law                     3
          Penal Code                     1  (N. Y.)
          None or no information         5

                                        48     \
         Requirement at private crossing: -  if view  is
        ^obstructed          	         1
         Signals to consist of:
          Whistle or bell               24
          Whistle and  bell               7
          Whistle                        6
          Bell only                      2  (Fla.  & R.I.)
-------
    Distance at which signal is to be sounded:



     Beginning at a minimum of distance  (35 States



     varying from 660 feet in Michigan to 1500



     feet in South Carolina, with an average of



     1,265, the most common being 1/320 feet



     (80 rods).



     Beginning at a maximum distance (3 States):



     Montana 1,320, Ohio 1,650, and Virginia



     1,800 feet.



     To continue until train:



          Reaches crossing          35



          Is entirely over crossing  3



    Exception of some form provided for incorporated



    areas in at least 15 States:



     California, Lowa, Indiana, Kentucky, Michigan,



     Minnesota, Missours, New Jersey, New York,



     Nevada, Utah, Virginia, Washington, Wisconsin,



     and Florida.



..  Exception provided at crossing with:



     Gates and/or watchmen - Delaware



     Flashing lights and bells - Illinois





(More is said about exceptions in a later section of



this report.)
                       B-6

-------
     Railroad operating rules reflect the ordinances in
effect in the areas through which they pass, generally
encouraging the use of warning signals at the discretion
of the operator to avoid accidents, but admonishing
against unnecessary soundings.  Specific supplementary
advice is contained in Standard Rule 14, which is adopted
by many carriers, requiring the sounding of signals in all
situations where two or more trains are at or approaching
a crossing simultaneously/ due to the extra hazard con-
sequent to the limited view and preoccupation of approach-
ing motorists and pedestrians when they see or hear just
one of the trains.
     Two good examples of State requirements for the
sounding of warning signals at crossings are those of
California and West Virginia, attached hereto as Appendix
Al, A2, and B, respectively.
     Over and above statutory and  regulatory requirements
for the use of warning signals on  trains,  the judiciary
and juries have  tended to assume that there is a burden
upon the operators of  railroads to employ  such devices.
Numerous judgments have been made  against  railroads  in
court  cases wherein the sufficiency  of  warnings were
questioned, particularly  by juries and  seemingly to a
relatively greater degree in California.   As a result,
railroads  are  reluctant to  dispense  with any ordinary
action which might be construed  to be a contributing factor
in crossing  accidents.  More will  be said on this  topic
                             B-7

-------
in a later section.

     In addition to requirements for warning travellers

at level crossings, the State of New Jersey Public Utilities

Commission has ordered that passenger carrying railroads

operating in that State sound a horn or whistle prior to

stopping at or passing through a. passenger station on

a track adjacent to a platform.  (January 20, 1972,

Docket 7010-525)  Subsequent modifications limited this

requirement to one long blast, during daylight hours, and

then only when the engineer has reason to believe persons

may be in the vicinity of such platforms.



B.2  Railroad - Highway Accidents,

     There are over 220,000 public rail highway crossings

at grade in the United States, of which 22% are actively

protected (Categories 2_ and 3) .  (There are also about

150,000 private crossings.)

     In 1972 there were almost 12,000 public crossing

accidents, resulting in 1,260 deaths.  These totals have

been decreasing slowly since 1966.  In 67% of these accidents

the train -struck a motor vehicle, in 28% a motor vehicle

struck trains and in 5% trains struck pedestrians or there
NOTE:  Figures in this section are taken from references
       (4) and (5).  Accident figures sometimes differ
       between references due to the $750 cost baseline
       for reporting accidents to the Federal Railroad
       Administration.  Crossing figures may differ due
       to the inclusion or exclusion of private crossings,
                            B-8

-------
were no trains involved.  39% of the collisions occurred
at crossings provided with gates, watchman, audible and/or
visible signals, while 61% were at crossings having signs
which did not indicate the approach of trains  (Category JL).
     63% of the collisions occurred during daylight, and
37% at night.  It is believed that about 67% of motor
vehicle traffic flows in the daytime, 33% at night, suggest-
ing a slightly higher crossing hazard at night  (37% of
the collisions with 33% of the traffic).
     Automobiles constituted 73% of the motor vehicles
involved, trucks 25%, motorcycles 1.3% and buses 0.3%.
  V
     When motor vehicles struck sides of trains, they
usually contacted the front portion thereof, particularly
during daylight; the propensity to strike elsewhere in-
creases at night.  The side of train category  appear to
be twice as hazardous at night, in that 53% of  them occur
then, with 33% of the traffic, with the peak occurring
between midnight and 2 a.m.  In fact, when these are de-
ducted  from the total, the train-strikes-vehicle  collisions
are in about equal proportion to the traffic distribution,
day and night.
     The propensity for accodents at actively  protected
crossings is also greater at night than in daylight, per
unit of traffic, perhaps indicating that driver alterness
is a more significant factor in these  cases.
                            iB-9

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        TABLE 1.  SUMMARY  OF PUBLIC  CROSSING  TYPES,




                  LOCATIONS AND ACCIDENTS  (1970)
                       URBAN
RURAL
TOTAL
5970
18050
4240
28260
(3624)
50860
(3827)
79120
(7451)
2970
14620
2680
20270
(1533)
12385
(3428)
144120
(4961)
8940
32670
6920
48530
(5157)
17471
(7255)
223240
(12412)
GATES  (category 3)



SIGNALS  (category 2)



OTHER OR MANNED



TOTAL ACTIVE



 (ACCIDENTS)



PASSIVE  (category 1)



 (ACCIDENTS)



GRAND TOTAL



 (ACCIDENTS)





     There were 70 fatalities  in  1972  at gates,  and



440 total at all active crossings,  somewhat  less than one



per 100 crossings.



     Accident rates and severity  are significantly higher



at actively protected crossings,  indicating  that the



greater hazards where they are installed are not fully



compensated for by the increased  protection.  The rates



are also higher in urban areas than rural, for both



active and passive crossings, so  that  in the very areas



where noise exposure is greatest, the  safety situation



is worst.
                            B-10

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     It could also be argued that the accidents which
occurred in spite of the active protection demonstrate
the ineffectiveness or waste of warnings such as train
horns in such areas.
     While vehicle traffic, train traffic and speed
continue to increase, protection installations are also
increasing, and the total number of crossings is de-
creasing.  The 1973 Highway Act provides a total of
$175 million over a three year period for crossing safety,
on a 90/10 Federal share basis, or a potential total of
$193 million, of which at least half is to be spent on
active protection systems.  Gate installations constitute
about 30% of all new protection, and since such systems
cost about $30,000 on the average, approximately 1,000
more gate installations should occur during this three
year period, in addition to those installed at railroad
initiative.  The Northeast Corridor is already on its
way to being totally without level crossings of any kind.

NOTE:  Reports of crossing statistics vary from year to
       year, are often based on different reporting
       criteria and may be for either public and private
       crossings.
                           B-ll

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 B.3  The Impact and Effectiveness of Locomotive Horns

 Acoustical Characteristics and Noise Impact
      The audibility of air horns,  the predominant warning
 devices which are the subject of attention herein, has
 been investigated (1)  as  part of a DOT program to make
 crossing warning systems  more effective.   It was found
 that the horns which are  presently employed are not very
 effective,  and to be so it would be necessary  to increase
 their loudness,  "warbling"  and/or  the use  of as many  as
 5 chimes (pitches)  have been  recommended.   Obviously,
 since the whole  purpose is  to gain attention and instill
 a sense  of  imminent danger  and alertness in persons
 located  at  1/4 mile distance,  such signals  are  bound  to
be disturbing -  by  definition.
      Figure 1 shows the approximate noise pattern  of  an
average  locomotive  horn.   In  order to increase  motorist
impact to a degree  sufficient to be of  real  value,  the
loudness would need to be  increased as  much  as  23  dB,
resulting in a loudness of  128  dB  at 100 feet.   (The
A and C weighted  loudness of  the common air  horns  are
almost identical; no distinction is  made in  the  literature)
     Loudness at  90° from the direction of movement is
5 to  10 dB less than straight ahead  and it is possible
                            B-12

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that this pattern could be improved somewhat, but the loud-
ness should be substantially maintained to at least 30°
each side of center due to the variation in angle of approach
of railroads and highways.
     This problem of audible warning is shared with emer-
gency vehicle sirens.  Fire, police and rescue units have
a parallel problem.  With motor vehicle' windows closed,
in modern, acoustically well constructed vehicles, and
with road noises and/or air conditioning, radios, etc.
competing with the warning devices, at least 105 dB is
needed outside a vehicle in order to gain the attention
of most drivers.  Research is underway to determine the
feasibility of installing warning devices inside motor
vehicles, which would be actuated by the approach of a
train or an emergency vehicle.
     In Figure 1 are shown the acoustical characteristics
of the common railroad air horns, the orientation of
train and vehicles  in a set of relatively high speed en-
counters, such that the motor vehicles shown would  have
a reasonable stopping distance to the point  and  instant
of train passage at a crossing.  Table 2  lists the  required
noise levels at vehicles  travelling at various speeds
 (exterior background noise  assumed dominated by  running
noise of vehicle)  to gain the attention  of the drivers;
the  50% attention  column  nearly  corresponds  to the  average
                             B-13

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dB
                                           tECOMMENDED
                                                                    AVERAGE
                                                                     TODAY
     ILLUSTRATION OF HORN
     LOUDNESS VS DISTANCE &
     EXAMPLE  OP  DISTANCES TO
     APPROACHING VEHICLES
     VEHICLE SPEED



     >_ 35 mph

     36 - 50 mph

     51 - 65 mph


    (SOURCE:  REF 1)
    TABLE 2


       dB OUTSIDE VEHICLE"FOR % FOR DRIVERS TO NOTICE

                50%                98%

                83                 101

                87                 105

                91                 109


STANDARD DEVIATION - 6dB
                                  B-14

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situation today.   To alert 98% of the drivers at (B)
it would be necessary to increase the sound levels by
about 30 dB, resulting in a level at 100 feet abreast of
the locomotive of about 130 dB.
     Figure 2(a)  illustrates the noise pattern which
characterizes most horns in use today, and Figure 2(b)
depicts the areas lying within an envelope in which the
noise from a horn being blown for a crossing will equal
or exceed 77 dB for some period with each train passage.
The 77 dB figure is chosen rather arbitrarily, largely
because it corresponds to a 1,000 foot boundary adjacent
to the track, which is compatible with the modest data
available on residential population alongside railroads.
It is also a reasonable number as regards nuisance levels
of intermittent noise intrusion, being used  herein
merely for the purpose of approximating the  scope of  the
impact of warning device noise.
     Some 202 miles of railroad route in 12  fereas of  10
cities of varying overall size, selected randomly, have
been reviewed.  The population within 1,000  feet of the
railroads in this examination average 2,410.  Therefore,
in urban areas, about 600 persons are usually exposed to
77 dB from an instant up to 10 or 15  seconds each time a
train passes a level crossing.

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LOCOMOTIVE HORNS - AVERAGE NOISE PROPAGATION UNDER



               IDEAL CONDITIONS
 800'
              1000'



     a) 77 dB Profile
                                                 o
                                                 o
                    4000'
       b)   Area subjected to 77dB  level or more


           Based upon extension of profile along route




                   FIGURE 2

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                          Table 3

                                        % of Population

     1.   Unprotected      33.0 million          16
     2.   Signalled        13.7                   6
     3.   Gated            (3.7)                 (2)
       Total              46.7 million          22

               (Signalled includes gated)

     This would indicate that one-fifth of the total
population is "within hearing" of a grade crossing.   In
fact, the noise patterns are probably much less severe
than shown here,  due to topographical features, and many
of the protected as well as some of the unprotected
crossings are covered by restrictive ordinances, so that
probably more like 10-15% of the people are exposed to
the 77 dB or greater level used here for illustration
(exterior to dwellings, etc.).
     If the use of horns was prohibited at all actively
protected crossings, 30% of these exposures would be
avoided.  If such a restriction was confined to crossing
with gates, 8% of the exposures would be avoided.  These
abatement measures would be noticeable to about 3% or  1%
of the population, respectively, allowing for attenuation
                             B-17

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locally and background noise and the fact that many

crossings are already covered by such rules.

     Assuming that the use of signals and gates corresponds

to the highest hazard levels or volume classes as depicted

by the Department of Transportation, the number of daily

train and vehicle passages at the crossings in question

has been estimated as shown in Table 4.


                          Table 4
                           Daily Trains    Daily Vehicles

Total over signalled
  crossings                 950,000         160,000,000

Average per signalled
  crossing                       20               3,300

Total over gated crossings  200,000          70,000,000

Average per grated crossing      22               7,800


     If the average train sounds its horn over a period of

12 seconds, the average citizen within 1,000 feet will experi-

ence the noise at 77 dB or more for an average of 8 seconds.

At gated crossings where horn blowing occurs 22 times per day,

the equivalent energy produced (L  ) is 50.1 dB, whereas at

signalled crossings where it occurs only 20 times per day, the

equivalent energy would be 49.7 dB.

     People residing within hearing of grade crossings

are generally conditioned to the sound, which tonewise
                             B-18

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is not particularly disturbing.   The most common casual
notice of the use of horns at crossings is expressed by
persons staying at motels, which are not infrequently
located on highways which parallel railroads and are near
road crossings.  Being otherwise unaccustomed to the sound,
it is quite noticeable, particularly at night.

Warning Effectiveness of Horns
     As noted above, at present only about half of all
motorists can notice the sound of a train horn when they
are driving and their windows are closed, even under ideal
conditions.  And the alerting capability - even if the
horn is noticeable - is still less.  It is impossible to
determine how many accidents have been prevented by the
routine sounding of horns, although it is apparent from
the experience of train drivers that many accidents have
been averted by the ad hoc sounding of horns, while an
even greater number have occurred in spite of it.  However,
these comments are directed to all crossings, passive
(unprotected) as well as active  (protected).  It is unlikely
that either routine or ad hoc use of horns at crossings
where lights are flashing and bells are ringing at the
crossing significantly improves ordinary driver attention,
particularly where gates are lowered as well.  On the other
hand, some drivers and most pedestrians can hear the horn
when it is sounded.  Also, in those occasional incidents
where a vehicle is stalled on a crossing the horn may serve

                             B-19

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 to divert people from continued efforts  to move their
 vehicle and to depart forthwith on  foot.  But in the latter
 case, sounding  on a routine basis  is probably not necessary.
     Attached hereto as Enclosures  C, D, and E are  (abridged)
 reports on three rather typical grade crossing accidents
 wherein the accidents occurred in spite  of crossing signals
 and the sounding of warnings by the train.  These are
 selected somewhat randomly, to illustrate by example a
 kind of crossing accident whi*ch is  all too common.

 B.4  Prohibition against the use of audible devices
     It is already quite common for the routine sounding
of horns or whistles to be prohibited, except in emergencies.
 It is also common for these prohibitions not to be enforced.
A careful search for cases where such prohibitions appeared
to, or were claimed to contribute to an accident has not
yielded evidence of a single such situation.
   .  Among the localities which restrict the use of horns
are those listed in Table 5.
                           B-20

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          Table 5.  Some Localities with Restrictions
                                         Notes
    The State of Florida                  (2)
    The State of Illinois                 (1)
    The State of Massachusetts
    Chicago, Illinois                     (1)  (2)  (3)
    Houston, Texas                        (1)  (2)
    Minneapolis, Minnesota
    Buffalo, New York                      (1)  (2)
    Philadelphia, Pennsylvania
    Knoxville, Tennessee                   (1)  (2)
    Durham, North Carolina                 (2)
    Mason City, Iowa                       (3)
    Warren Pennsylvania
    Elkhart, Indiana
    Toledo, Ohio
    Columbus,  Ohio
    Akron, Ohio
    Lynchburg, Virginia                   (1)  (2)
    San Bernadino,  California             (1)
    South Holland,  Illinois
    Elmhurst,  Illinois
    Lockport,  N.Y.
    Rochester, N.Y.

(1)  Contacted  local authorities in course of this study.
(2)  Specific Information contained in Enclosure F.
(3)  Not enforced.              B-21

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     The 15 states where requirements to use horns are
excepted, but not necessarily prohibited, in incorporated
areas are:
                          Table 6.
     California*                          New Jersey
     Florida                              New York*
     Iowa*                                Nevada*
     Kansas                               Utah
     Kentucky*                            Virginia*
     Michigan*                            Washington
     Minnesota                            Wisconsin
(*also have local-option provision)
     In 4 additional states there is a local option provision,
allowing cities and towns to relieve requirements:

                         Table 7.
     Illinois                             North Carolina
     Indiana                              West Virginia

     Two states permit silent running at crossings with
certain protection systems:
     ..  Delaware:  warning requirements do not apply when
        crossing is protected by watchman or gates.
     ..  Illinois:  requirements do not apply when crossing
        is protected by automatic signals (with or without
        gates).
                            B-22

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     One of the most comprehensive Noise Control Regulations
thus far drafted in the United States is that of the State of
Illinois.  As it stands, its property line limitations would
affect the use of audible crossing warning devices except that
its Rule 208, Exceptions, states:  "Rules 202 through 207
inclusive shall not agply to sound emitted from emergency
warning devices and unregulated safety relief valves."
     Thus, it can be seen that there is considerable
precedent for placing constraints upon the use of audible
warnings, with no apparent adverse effects.  However, they
are not uniformly enforced, and where enforced, the carrier
generally receives written instructions from the constraining
authority, and is nevertheless impowered to sound warnings
"in emergencies"..."in the event of impending accident"...
etc.

B.5  Judicial Background

     Tort litigation constitutes the bulk of the legal or
judicial history of grade crossing safety responsibility.
Abstracts of 2500 cases throughout the United States during
the period 1946 to 1966 have been surveyed  (3), checking
into 300 possibly related to the question at hand.
     In addition, 5 cases were cited by a cooperating
railroad as illustrative of the railroad liability  question.
One of these was found  to be inapplicable to the question
at hand, three were decided in favor of the railroad.  In
the other, a jury found for the plaintiff,  although a
                              B-23

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 whistle  had  in  fact been  sounded.   Of  these,  21  appeared  to
 be  somewhat  related and the case records were reviewed.
 Nothing  was  unearthed which would  appear to deter Federal
 or  local constraints on audible traincarried  devices at
 protected crossings.
     Several themes are woven through  the opinions rendered
 in  the many  cases on record.  These are certainly not
 uniformly respected, but  they are  sufficiently common as
 to  be noticeable:
     ..  Safety provisions, including warnings, should be
 compensurate with the specifics of local conditions.
     ..  The  railroad is expected to give "adequate and
 timely"  warning of the approach of a train.  The railroad's
 case is  often intended to show that their warning could
 have been heard by an attentive motorist.
     ..  To be cause for placing liability,  an omission on
 the part of  the carrier generally must be shown to have
contributed  to the event in question.
     .. Motorists are generally expected to be cautious
at crossings, to the extent even of stopping or look
 "and listen".
     ..  Contributory negligence on the part of a motorist
is generally taken into account.
     The fact remains,  however,  that courts,  especially
juries,  have extracted severe payments from railroads,

                             B-24

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seeming usually to give plaintiffs the benefit of all doubt.
For this reason, railroad companies are understandably at
pains to make any changes which could conceivably be con-
strued as a reduction in safety precaution (or increase in
hazard).  Also, the employees charged with operating trains
are usually subject to prosecution under criminal law if
negligence and/or violation of a statute might be involved,
and are thus inclined to err in the direction of sounding
their warning devices, not to mention their sincere personal
desire to avoid injury to even the negligent public, as
well as themselves.   (Collision between trains and large
trucks, especially those'carrying hazardous materials, are
very dangerous to the occupants of the train.)  A possible
fine for violation of a noise ordinance is not nearly as
imposing a threat as  the liablility, criminal action and con-
science which accompany the threat of collision.

B.6  Summary
     One of the railroad noise sources which has been
commented upon  in the course of interstate rail carrier
regulatory development by this Agency's Office of Noise
Abatement and Control, is that of  railroad train horns
which  are sounded routinely at grade crossings.  It  has
                              B-25

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been  suggested  that  such  sounding  be  prohibited  in  cases
where automatic,  active protection is in  operation  at
the crossing  itself, particularly  where this protection
includes gates.
      However, it  remains  that  the  routine sounding  of horns
might be contributing to  the prevention of some  accidents.
Certainly, a  small segment of  the  population is  exposed to
serious noise intrusion thereby and a reduction  in  their
welfare, particularly at  night.  But  it is the Agency's
position at this  time, that it would  be imprudent to single
out and restrict  night time use of horns,  since  the crossing
hazard with regard to driver behavior is,  if anything, worse
at night.
      In view of the questionable value of  train horns for
warning highway drivers, particularly at locations having
active crossing signals, it may be appropriate to encourage
the abolition of routine use of horns at crossings so
                                     v_
equipped, particularly but not necessarily only those
with gates.  The circumstances which determine hazard
levels as well as noise intrusion vary widely and are
peculiar to local circumstances.   It  is therefore concluded
that regulation of railroad warning be best left to the
option of local authorities at this time,   recommending
thereto that consideration be  given to restrictions upon
the routine sounding of train  horns at protected crossings.
                            B-26

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                         REFERENCES







1.   The Visibility and Audibility of Trains Approaching



    Rail-Highway Grade Crossings; J. P. Amelius, N. Korobow;



    NTIS-PB-202668'.





2.   Driver Information Systems for Highway-Railway Grade



    Crossings; K. W. Heathington, T. Urbanik.





3.   American Digest System, 6th and 7th Dicennial Digests.





4.   Rail Highway Grade Crossing Accidents from the Year



    1972, Department of Transportation, Federal Railroad



    Administration.





5.   Report to Congress on Railroad-Highway Safety, No. II,



    Department of Transportation, FRA/FHWA.
                             B-27

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                         ENCLOSURE A
Public Utilities Code Annotated of the
  State of California
Adopted May 31, 1951
Page 784
                         ARTICLE 8
                           CRIMES

                    Collateral References

§7678.  emission to sound bell or whistle.  Every person in charge of
a locototive-engine who, before corssing any traveled public way, omits
to cause a bell to ring or steam whistle, air siren, or air whistle to
sound at the distance of at least 80 rods from the crossing, and up to
it, is guilty of a misdemeanor.

                     Legislative History

     Enacted 1951.  Based on former Pen C §390, as amended by Stats 1949
eh 391  § 1 p 733, without substantial change.

                    Collateral References

   Cal Jur 2d Railroads   44
   McKinney's Cal Dig Railroads § 71.
   Am Jur Railroads  S  S  357 et seq.
                                B-28

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            PUBLIC  UTILITIES  CODE,  STATE  OF CALIFORNIA
                           (Abridged)

7604.   A bell, of at least 20 pounds weight, shall be placed on
each locomotive engine,  and shall be rung at a distance of at
least  80 rods from the place  where the railroad crosses any
street, road or highway, and be kept ringing until it has
crossed the street, road, or highway; or a steam whistle, air
siren, or an air whistle shall be attached, and be sounded
except in cities, at the like distance; etc.
                                B-29

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                                   ENCLOSURE  B

                       THE  WEST  VIRGINIA  CODE

                                  (Abridged)
§ 31-2-8.  Warning of approach  of  train at crossings; crossing
                 railroad tracks.

  A bell or steam whistle shall be placed on each locomotive engine, which shall
be rung or whistled by the engineer or fireman, at a distance of at least sixty
rods from the place where the railroad crosses any public street or highway, and
be kept ringing or  whistling for a time sufficient to  give due notice of the
approach of such train before such street or highway is reached, and any failure
so to do is a misdemeanor punishable by a  fine of not  exceeding one hundred
dollars; and the corporation owning or operating the  railroad shall be liable to
any party injured  for all damages sustained by reason of such  neglect.
       I. SCOPE OF STATUTE AS TO
               WARNINGS.
              A. In General.

   Mlchlc'i Jurisprudence. — For full treatment
 of accidents at crossings, see 15 M.J., Railroads,
 If 69-101. As to duty to give signal by bell or
 whistle, see 15 M.J., Railroads, §§ 81-83.
   ALR references.  —  Railroad  company's
 negligence in respect to maintaining flagman at
 crossing, 16 ALR 1273; 71 ALR 1160.
   Duty of railroad company to maintain flagman
 at crossing, 24 ALR2d 1161.
  Admissibility of evidence of train speed prior
 to grade-crossing accident, and competency of
 witness to testify thereto, 83 ALR2d 1329.
  The common-law requirement as to signals
 i* fully as exacting as the statutory duty. What
 the notice and warning to the public shall be
 depends, under the  common  law, upon  the
 circumstances of each case; but some adequate
 methods of apprising travelers of the crossing
 must be practiced. Niland v. Monongahela &
 West Penn Pub. Serv. Co., 106  W. Va. 528, 147
 S.E. 478 (1928).
  Both  bell  and  whistle are  not required
 without  statute. — There  is  no  absolute
 requirement upon a railroad company to blow a
 whistle and ring a bell at a crossing unless made
 so by statute. Niland v. Monongahela & West
 Penn Pub. Serv. Co., 106 W. Va. 528,147 S.E. 478
 (1928).
  The  methods  of apprising  travelers of a
crossing almost universally adopted are by the
ringing of a bell or the sounding of a whistle, but
in order to make both obligatory, the use of both
must be  called  for by a statute. Niland v.
Monongahela & West Penn Pub. Serv. Co., 106
W. Va.  528, 147 S.E. 478 (1928).
   Provisions  of  section   are   minimum
 requirements. — The provisions of this section
 as to warning signals are of broad application
 and  are minimum requirements, and in every
 case the compliance with this statute, plus the
 presence   of    an    efficiently   operating
 crossing-bell will not (apart from the question of
 contributory  negligence  of  the   plaintiff)
 constitute  an ironclad defense to the railroad,
 under all circumstances. Baltimore & O.R.R. v.
 Deneen, 161 F.2d 674 (4th Cir. 1947).
  Travelers  have the  right to assume that
 trains will give the usual signals at crossings.
 Morris v. Baltimore & O.R.R., 107 W. Va. 97,147
 S.E.  547 (19291.
  But railroad only owes duty to signal a*
 required  by statute. — The driver  of an
 automobile on a public crossing is an invitee, and
 the railway  company is bound only  to use
 reasonable  care   not  to  collide   with the
 automobile, and owes only the duty to give the
 signals provided by statute. Chesapeake A 0.
 Ry. v. Hartwell, 142 W. Va. 318, 95 S.E.2d 462
(1956).
  As this section is intended to protect penou*
on highway. — The duty imposed by statute to
sound a bell or whistle when  approaching a
public crossing  does not  require a railroad
company to give such warning elsewhere than
at the places so designated, because they are not
intended to afford protection to employees of the
operating company, but to petwnnriivvf'ftght

may use the railroad track* as part* of the public
highway. Jones v. Virginian Ry., 74 W. Va. 666,
88 S.E. 54,  1915C L.R.A. 428 (1914).
                                   B-30

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    II. FAILURE TO GIVE WARNINGS
      AS NEGLIGENCE; CONTRIBU-
           TORY NEGLIGENCE.
  Violation of section is negHgence.  — The
failure to give proper signals of the approach of
a train to a railroad crossing as required by this
section would constitute negligence on the part
of  a   defendant  railroad.   Cavendish  v.
Chesapeake & 0. Ry., 95 W. Va. 490, 121 S.E.
498 (1924).
  But  does not impose liability unless it
proximately causes injury.  —  Liability for
injury to baby  of 13 months could not be based
on failure to give signals since the failure was
not the proximate cause of the injury. Virginian
Ry. v. Armentrout, 158 F.2d 358 (4th Cir. 1946).
  Failure to ring the bell or blow the whistle at
crossings,  though required by  law, will not
render the company liable, unless that be the
proximate cause of the injury. Beyel v. Newport
News & Miss. Valley R.R., 34 W. Va. 538,12 S.E.
532 (1890).
  Thus, railroad is not liable if contributory
negligence is proximate cause. — Where one is
injured  by carelessly  driving on a  railroad
crossing in front of a moving engine or train, the
proximate cause of his injury must be regarded
as  his contributory negligence,  and  not the
negligence of the railroad company in failing to
ring the  bell  or  blow the whistle.  Cline v.
McAdoo, 85 W. Va. 524, 102 S.E. 218 (1920).
  Where the only evidence was that the warning
signals required by this section were  not given,
and that  the  failure  to do  so constituted
negligence on the part of defendant, it was held
that notwithstanding defendant's negligence, if
deceased's    contributory    negligence    is
established as a matter of law, plaintiff can have
no recovery. Arrowood v. Norfolk & W.  Ry., 127
W. Va. 310, 32 S.E.2d 634 (1944).
   And  signal requirement does not relieve
traveler of exercising ordinary care. — Failure
to ring bell or blow a whistle  on an  engine, as
required by this section, is negligence for which
a railroad  company is chargeable; but this does
not excuse the traveler on a highway  crossing
 a railroad track  from the exercise  of such
 reasonable care and caution as the law requires,
 to ascertain whether a train is approaching the
 crossing. Beyel v. Newport News & Miss. Valley
 R.R., 34 W. Va. 538,12 S.E. 532 (1890); Bassford
 v. Pittsburg, Cincinnati, Chicago & St. Louis Ry.,
 70 W.  Va. 280, 73 S.E. 926  (1912);  Cline v.
 McAdoo, 85 W. Va. 524, 102 S.E. 218 (1920);
 Robinson v. Chesapeake & 0. Ry., 90 W. Va. 411,
 110 S.E. 870, 22 A.L.R. 892 (1922); Cavendish v.
 Chesapeake & 0. Ry., 95 W. Va. 490,  121 S.E.
 498 (1924); Gray v. Norfolk & W. Ry., 99 W. Va.
575,130 S.E. 139 (1925); Berkeley v. Chesapeake
& 0. Ry., 43 W. Va. 11, 26 S.E. 349 (18%).
  Though a traveler has the right to assume that
warning signals required by this section will be
given, failure to give them will not excuse him
from exercising ordinary care, and taking the
necessary precautions for his safety. Arrowood
v. Norfolk & W. Ry., 127 W. Va. 310, 32 S.E.2d
634 (1944).
              III. EVIDENCE.
  The burden of proving that signals were not
given rests upon the plaintiff. Parsons v. New
York Cent. R.R., 127 W. Va. 619, 34 S.E.2d 334
(1945).
  No  conflict in   evidence  where  some
witnesses heard signals and some did not —
The fact that witnesses have heard signals given
by a locomotive approaching a crossing warning
travelers of danger, is not necessarily in conflict
with the evidence of other witnesses who did not
hear them; for the observation of the fact by
those who heard is consistent with the failure of
the  others  to  hear  them.  Cavendish  v.
Chesapeake &  0. Ry., 95 W. Va. 490, 121 S.E.
498 (1924).
  Unless  witnesses  not  hearing had equal
opportunity  to  do  so.  —   Testimony  with
reference  to  the  statutory   warning signals
which only goes so far as to establish that the
witnesses did  not hear the bell rung and the
whistle sounded  is not in conflict with the
testimony of other witnesses who testified that
in fact the whistle was blown and the bell rung.
An exception to the foregoing rule arises where
there was equal opportunity of a witness to hear
the signals and special circumstances or events
directed the attention of the witness  to the
failure  to give them. Holiman v. Baltimore &
O.R.R., 137 W. Va. 874, 74 S.E.2d 767 (1953).
  Witnesses in position  to  observe but not
hearing signals are entitled to peculiar weight.
— Where  the  witnesses were in a position to
observe with unusual care the circumstances
surrounding the accident, their testimony as to
 the neglect to sound the customary warnings by
 bell or whistle, or both, within a reasonable
 distance from  the crossing, a duty  dictated by
 reason  and required by this section, is entitled
 to peculiar weight. Casdorph v. Mines, 89 W. Va.
 448,  109  S.E. 774 (1921), citing Carnefix v.
 Kanawha & Mich. R.R., 73 W. Va. 534, 82 S.E.
 219 (1914); Southern Ry. v. Bryant, 95 Va. 213,
 28 S.E. 183 (1897).
   Thus, denial that signals  were  given may
 produce jury question. — The testimony of one
 witness, who denies that a railroad whistle was
 sounded on a given occasion, is  as positive
 evidence  as  the  testimony  of another who
 affirms the  fact,  where  each  has  equal
 opportunity of hearing and the attention of the
 former because  of  special  circumstances  is
 equally drawn with  that of  the latter to the
                                          B-31

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sounding of the whittle. The denial by the one
and the affirmance by the other produces  a
conflict of evidence, which it is the province of
the jury to determine. Tawney v. Kirkhart, 130
W. Va. 650, 44 S.E.2d 684 (1947).
  Whether a conflict arises between positive and
negative evidence of this character depends
upon the facts and circumstances of each case,
from which it may be determined whether such
negative evidence  has  any  probative value.
Cavendish v. Chesapeake  & 0. Ry., 95 W. Va.
490,121 S.E. 498 (1924); Tawney v. Kirkhart, 130
W. Va. 550. 44 S.E. 634  (1947).
  Since. If evidence conflicts,  question is for
Jwy. — Where the  evidence as to blowing the
whistle and ringing the bell is in conflict, the
question of fact is one to be determined by the
jury. Kelley v. Kanawha & Mich. Ry.. 99 W. Va.
568,130 S.E. 677 (1925); Tawney v. Kirkhart, 130
W. Va. 550, 44 S.E.M 634 (1947).
  Where the  evidence conflicts and is credible,
the question is one for the jury. Parsons v. New
York Cent R.R., 127 W. Va. 619, 34 S.E.2d 334
(1946).
  Where the  evidence conflicts as to whether
proper signals  by  ringing  bells  or  blowing
whistles were given, the court cannot say that
the verdict of the jury is ml supported by the
evidence. Coleman v. Norfolk & W. Ry., 100 W
Va. 679,131 S.E. 563 (1926).
  Question   of   traveler's    contributory
negligence held tor Jury. — See Arrowood v.
Norfolk & W. Ry., 127 W. Va, 310,2 S.E.2d 634
(1944).
  Evidence  held  insufficient  to  submit
railroad's negligence to jury. — In  action for
injuries sustained in crossing collision evidence
was insufficient to justify submission to jury of
question of railroad's negligence in  failure to
comply with this section. Baltimore & O.R.R. v.
Deneen, 161 F.2d 674 (4th Cir. 1947).
  Evidence held sufficient to sustain verdict
for either party.  — Conflicting evidence on
question of whether  railroad gave  statutory
warning signals required by this section was
sufficient on both  sides to have sustained s
verdict in  favor  of either party. Tawney  v
Kirkhart, 130 W. Va. 550. 44 S.El2d 634 (1947).
  Evidence   held   to   favor   railroad't
compliance with  section.  —  In  Krodel  v.
Baltimore & O.R.R., 99 W. Va. 374,128 S.E. 824
(1925), there was some conflict of testimony as
to sounding the whistle  and ringing the bell at
a railroad crossing, but it was  held that the
weight was in favor that the defendant complied
with the statute.
                                         B-32

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                         ENCLOSURE  C




   MULTIDISCIPLINARY ACCIDENT INVESTIGATION

                Case No. UC852D


                 (Abridged)
                  Prepared by

           University of California
            Los  Angeles, California
The contents of this report  reflect  the  views of
the performing organization  which is responsible
for the facts and the accuracy of the data pre-
sented herein.  The contents do not  necessarily
reflect the official views or policy of  the
Departcant of Transportation.  This  report does
not constitute a standard, specification or
regulation.
                        B-33

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               UCLA COLLISION INVESTIGATION PROGRAM

                       VEHICLE COLLISION REPORT
             Prepared for the U.S. Department of Transportation
                    National Highway Safety Bureau,
                       Under Contract FH-11-6690
Certain information contained in this report is obtained from indirect sources.
The opinions, findings, and conclusions expressed in this publication are those
of the authors and not necessarily of the National Highway Safety Bureau.
                               B-34

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U. C.  852D

                          1.  STANDARD CASE SUMMARY

1.1  SUMMARY TEXT

IDENTIFICATION:          This train versus automobile collision occurred on a Thurs-
                           day at 10:51  a.m. at a combination intersection/railroad
crossing in California.  Maximum occupant injury severity:  critical  (06)  Collision
causation: driver inattention.

AMBIENCE:                Day; weather clear and dry; roadway dry.

ROADWAY:                A straight,  asphalt, undivided roadway, 75ft. wide  with
                           curbs, in a suburban area with speed limit of 35 mph. The
collision site is at a railroad crossing, 25 feet before a T-intersection.  The road has a
negligible crown, and is upgrade at the site.  The roadway has three intersections  within
one-quarter  mile of this intersection.

TRAFFIC CONTROLS:       The lanes are separated by  broken white lines with opposing
                           lanes  divided by double-double yellow lines.  There  is a
railroad automatic signal and a traffic signal at the railroad crossing.  There were  no
crossing gates at the time of the collision. Four auto/train collisions at this site in past 3 yrs

VEHICLES:                 Vehicle  *1;  Freight traia weighing approximately 400 tons.
                           Vehicle  *2;  1967 Cadillac Coupe de Ville two-door hardtop
with power windows and seat.  No  apparent defects.  Collision damage to right door
causing intrusion of 12".  Occupant contact with intruding door and train.  Deformation
Index:  03RPMW2.

OCCUPANTS:              Vehicle  *2:  Driver;  59-year-old female, height, 64",
                           weight,  160  Ibs.  Lap belt in use. No  HBD or drugs.  In-
juries:  fractured rib, lumbar back strain, abrasions, and contusion.

                                        Right Front;  63-year-old female.  No  restraint
in use.  No  HBD or drugs.  Injuries:  compound, depressed skull fracture with cerebral
contusion, abrasions and contusions over body.

DESCRIPTION:

     Pre-collision;          Vehicle  *2,  the Cadillac,  approaching the T-intersection,
                           failed to stop at the railroad crossing in spite of the warning
ligSrs and bell.  Slowing for the  red light  at the intersection, the Cadillac entered the
tracks, into  the path of the train.  The train was eastbound at approximately 15 mph,
approaching the crossing.  The train engineer was sounding the whistle  and applied his
brakes  when he saw the Cadillac in crossing.
                                        B-35

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 U. C. 852D
     Collision;               The train struck the Cadillac in the right side, pushing it 150
            :                 ft. along the railroad tracks.  The Cadillac remained in a
position at a right angle to the railroad tracks.  Occupants of the Cadillac moved to the
right, and the right front occupant was struck by the intruding train.

     Post-collision:           Occupants were hospitalized.  Railroad crossing gates were
                             later installed at the crossing.

1.2  CAUSAL  FACTORS, CONCLUSIONS, RECOMMENDATIONS:

Matrix cell                            Explanation
("indicates positive factor)

     1                                  Driver inattention and/or distraction appear to be
                                       the chief cause of this collision.

    4                                  Air conditioning  on, with windows  rolled up, makes
                                       it difficult to hear train or warning bells.

    5                                  Right door penetration of 12"due to side impact.
                                       Door metal torn in area of hinges.

    5                                  It is recommended that integrated side structures
                                       be employed, combining strength of frame,  door
                                       sill, body pillars  and roof..

    5*                                 Right .door latch and hinges did not  fail.

    7                                  Driver's view of oncoming train partially blocked
                                       by shrubbery along tracks.

    7                                  Vehicles were allowed to stop on railroad tracks
                                      while waiting to turn at intersection.'

    7                                  It is recommended that visibility of  oncoming trains
                                      be maximized by  removing obstructions.  Vehicles
                                      should not be allowed to wait on railroad tracks.

    8*                                 Railroad crossing gate was installed  and light
                                      locations were altered after the collision.
                                       B-36

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U.C.#852D
     CROSS
     WALK
                       OLEAN
                        BUSHES
                       WARNING I
DER
                        1.3
                                                      N
                                    BUILDING
                                        OLIVE  TREES
                       LIGHTS! V*}?*,
                               ^3U£-X"*



                        TRAFFIC LIGHT_ — —  —
                                         FEET
                                0  20   40  60  80  100


                                     SCALE 1" =40'
                 r
                    1    VI-FREIGHT  TRAIN

                         V2-1967 CADILLAC COUPE DE VILLE
                            B-37

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 IDENTIFICATION
                                       ENCLOSURE  D
                           SOUTHWEST RESEARCH INSTITUTE

                                      CASE SUMMARY
                         (MV-TRAIIM-INTERSECTION COLLISION)
                                        CasoNo. 717&

                                        (Abridged)
      This accident occurred at the MKT railroad grade crossing on Eisenhauer Rd. at IH35 in San Antonio,
 Bexar County, Texas, on Thursday, September 30, 1971 at 1335 hours, involving the collision of a diesel
 freight engine and a 1970 four-door station  wagon with a lone driver. The westbound automobile was
 struck on its left side by the northbound locomotive. The area .is residential. The accident was injury-
 producing; AIS Severity Code No. 3.

 AMBIENCE

      It was daytime with partly cloudy sXies, 85°F dry bulb, 57 percent relative humidity, 10-mph breeze
 blowing from the southeast; the road  surfaces were dry and clear of debris and loose gravel.

 HIGHWAY

      Eis«nhauer  Rd. is a major access  artery between the interstate loop expressway system and the
 residential areas of northeast San Antonio. It  is a  41-ft-wide, four-lane, two-way roadway with an asphalt
 surface of the intermediate type in good  condition. The road is divided at this immediate area of the IH35
 access road-Eisenhauer  Rd. intersection  by 6-in.-high concrete channelizing islands. The traffic lanes are
 10 ft wide. Eisenhauer Rd. runs east-west and is bounded on both sides by a 6-in. curb. The road is straight
 and level. It is not crowned. The coefficient of friction on the dry surface was 0.61. A southbound, one-way,
 two-lane 24-ft-wide frontage road runs 60 ft east and parallel to a mainline, single track railroad right-of-way;
 both intersecting Eisenhauer Rd. at this point. An exit ramp from IH35 is immediately north of this inter-
 section and an entrance ramp is immediately south. These ramps connect IH35 to the frontage road.

 TRAFFIC CONTROLS

      The posted' speed  limit on Eisenhauer Rd.  is 30 mph. The speed limit is 40 mph on the frontage
 road. A railroad company-imposed speed  limit of 25 mph is assigned for 0.5 mile each side of the crossing.
 Traffic control devices consist of pavement markings, b-in.-high channelizing islands, regulatory, warning,
 and guide signs. There are two flashing amber lights, 36-in.-diameter yellow railroad advance warning signs,
 and black-on-white railroad  crossbticks. There are  neither traffic control signal(s) in the area nor a flashing
 red light or bell warning signals, gates, or guards to provide immediate warning of an approaching train.

 VEHICLES

      No.  1. 1968 GP40 Electromotive diesel freight engine. The 3-yr-old engine is considered to be in good
 operating  condition with no indicated defects.  Minor  secondary damage includes- bent brakeman's steps,
 bent coupling actuator lever, and airhose  torn loose, secondary vehicle deformation  index 12FDLW1. The
 retail repair cost was nil.

      No. 2. 1970 Oldsmobile Vista Cruiser, four-door, three-seat, yellow station wagon; odometer reading
 22,224 miles; valid Texas Motor Vehicle Inspection sticker with a damaged illegible  date; equipped with a
standard 350-cu in. eight-cylinder gasoline engine; automatic transmission, power steering, and power front
disc-type brakes; radio, heater, air conditioner, and tape deck; padded armrests, sunvisor, seat back tops,
interior rearview  mirror, windshield interbeam.  and instrument  panel.  Three seatbelts and two shoulder
straps for  front bench-type  seat and  three seatbelts for the second bench-type seat. The shoulder  straps


                                              B-38

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 were in the stored  position.  No defects were apparent or indicated. The last vehicle maintenance w'
 performed.it  13,663 miles on January 21,1971 and included lubrication and oil and filter change. Primai
 contact damage was 16-in. sheet metal and frame deformation to the left side, primary vehicle deformatic.
 index 09LPAW5. Secondary damage was to the tires, rear bumper, and roof. The retail replacement vali
 was $3075 (total less S200 salvage value).

 OCCUPANTS

      Vehicle No.  1. Engineer:  46-yr-old white male, 71 in.,  155 Ib  (estimated). An interview was nc
 obtained. He was familiar with the vehicle and the route traveled.

            Injury: None.

      Vehicle No. 2. Occupant No. 02. Driver: 42-yr-old white female of Latin-American extraction, 62 in.,
 132lb. She has been driving  20 yr and currently drives approximately 9000 miles/yr. She was en route
 from her husband's office to home, a distance of 10 miles. The accident occurred 1  mile from her destina-
 tion. She had no definite  ETA. She was familiar  with  the vehicle and with the route traveled. She has had
 no formal driver's education. Her physical condition was excellent. Her precrash state was rested with no
' stress: she was inattentive  to her driving task. Lap  and shoulder restraints were available, but not in use.

            Injury: Severe (not lire-threatening). AlS Severity Code No. 3.

 STANDARDS

      The following Highway  Safety Program Standards (HSPS) and/or Motor Vehicle Program Standards
 (MVPS) were relevant to this case:

      HSPS No. 4-Drivvr Education Use of Occupant Restraints. Radio, and Failure to Look for T'^t-
      HSPS No. ^-Identification and Surveillance of Accident Locations
      HSPS No. 13-Traffic (  ntrol Devices
      MVPS No. 201 -Occ-'pant Protection in Interior Impact
      MVPS No. 214-SiJe Door Strength.

 DESCRIPTION

 Precrash: The driver of vehicle No. 2 (passenger  car) was traveling to her home from her husband's office.
 She had left northbound  IH3S and turned west onto l-isenhauer Rd., passing under the IH3S overpass. She
 crossed the southbound  frontage  road  at a relatively low speed  (estimated not more than 25 mph) and
 drove in front of vehicle No. I  (diesel freight engine), which was moving north at about 25 mph with its
 horn blowing for-the crossing. There were no skidmarks from  vehicle No. 2 prior to impact. The car radio
 was in operation.

 Crash:  Impact occurred on the left side of vehicle No. 2, centered approximately at the "A" pillar line, as it
 crossed the railroad track in front of vehicle No. 1. The coupler of the freight engine forced in the forward
 portion of the door structure, firewall, cowl, and instrument panel structure. Other portions of the front
 structure of the engine - brakcman's steps and brackets-forced  in the doors, floor, and frame left sidcrail to
 a depth of 16 inches. The  passenger vehicle was pushed northward  on  the railroad right of way. It then
 yawed left and came to rest 88 ft from the impact point, parallel to and 7 ft west of the tracks facing the
 crossing. The unrestrained driver was first thrown left against the incavmg side structure of the car. Then she
 was thrown to the right. Vehicle No. 1 stopped 314  ft  from the point of impact.

 Poster ash:  The driver of vehicle No. 2 was not ejected from  the vehicle. She was removed from vehicle
 No. 2 through  the right  front door without complications. She  was taken to the  hospital  by  ambulance
                                               B-39

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approximately 20 nun after the crash. Because the automobile came to rest a considerable distance from
the roadway, there was no appreciable interference with traffic. A wrecker had no complications in picking
up  the vehicle and towing  it away. Since the locomotive was not significantly damaged, it was able to
proceed.  Traffic on Hisenhauer Rd. was estimated  at  IS vehicles/min; on the frontage road, traffic  was
estimated at 5 vehicles/min.

CAUSAL FACTORS. CONCLUSIONS. AND RECOMMENDATIONS
   Matrix Cell
  (• Indicates
Positive Factors)

       I
        I


        I



       2

       3
                                  Explanation
 Driver No. 02 was inattentive and did not observe normal precautions when approach-
 ing the railroad track.

 Driver No. 02 had  her radio on  and  windows up, which  may  have  prevented or
 seriously interfered with her ability to hear the train's signal horn.

 The engineer may  have been speeding, with respect to the  company-imposed limit of
 25 mph, 40 to SO mph. This is the situation if the  train brakes were adequate and if
 the engineer maintained a locked brake mode throughout the stopping sequence.

 Driver No. 02 was not wearing the available seatbelt or shoulder strap.

 Driving in a veil of interior noise (radio, air conditioner, etc.) with the windows closed
 should be discouraged in driver education programs.

 The train should have been capable of stopping within 104 ft from 25 mph. The 314-ft
 stopping distance,  from the point  of impact, suggests that either the driver did not
 fully apply the brakes at some point during the collision sequence or that the brakes
 were not performing adequately.

 Occupant injuries from impact against interior surfaces and protuberances were miti-
gated as a result of adequate padding and interior design.

This site has an extremely high accident rate; however, more adequate traffic control
by a train-approach signal system has not yet been authorized.
                                             B-40

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                                          IH.35 FRONTAGE RD.
                                                    or* -o-
0    2O    4O    60
|  .   I   .   I   .   I
   SCALE    (FEET)
            LEGEND
I ONEWAY            5IK 35 SOUTHBOUND
2. KEEP RIGHT       & YIELD
1 RAILROAD CROSSBUCK 7 REFLECTOR
4 NO PARKING  ANYTIME

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                               ENCLOSURE E




                    Maryland Medical-Legal' Foundation

                  Office of the  Chief Medical Examiner

                            State of Maryland

                          Truck/Train Impact

                           Caae # MMF 72-24

                             (Abridged)
            MULTIDISCIPLINARY ACCIDENT INVESTIGATION SUMMARY

 IDENTIFICATION OF COLLISION

      The highway  is  a  state  road traversing, north and  south in the south-
 east portion of an industrial  section of Baltimore" County.  The accident
 occurred in September  of' 1972  at 0400 hours on a Friday involving a trac-
 tor trailer and a freight train at a  front to side  impact.  The accident
 caused fatal injuries  to  the driver of the tractor  trailer.

 INJURY SEVERITY SCALE:  Driver of Vehicle #1 FATAL-AIS-8

 AMBIENCE

      Night;  no  illumination; misty; 58 degrees F.;  607. relative humidity;
 wind 10  m.p.h.  from  the northwest; visibility of 500 feet; road surface
 was  wet;  coefficient of friction .55  dry (measured) and .45 wet (estimated).

 HIGHWAY

     The highway  on which the  accident occurred is a major arterial state
 road with a  total width of 106 feet consisting of two 12 foot lanes going
 north and two 12  foot  lanes  going south divided by a 48 foot grass median.
 The  roadway  is  of black top macadam with an 8 foot shoulder on the east
 side and a 2 foot shoulder on  the west side.  The roadway is straight and
 level.   There is no artificial lighting and within % mile there are. two in-
 tersections; one being 800 feet south of the railroad crossing and the other
 being 600 feet  north.  There are 9 telephone and transit poles within ^
mile.  The accident history at this point within a year previous is 6 pro-
perty damage and 3 personal  injury accidents with an average daily traffic
 of 22,500 vehicles.
                                  B-42

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TRAFFIC CONTROLS

     The speed limit is posted at 55 m.p.h.  and there are intermittent  lane
lines with solid edge lines painted in the roadway.   There are standard
railroad crossing signs and lights at the right side of the road with over-
head signals actuated by the train

VEHICLES INVOLVED

     Vehicle #1 was a 1969 G.M.C. Tractor, two-door, red in color with  an
odometer reading of 49,760 miles.  There is no inspection data but the
vehicle was well maintained by the company garage.   The vehicle was equipped
with manual steering, manual transmission, air brakes (drum type), seat
belts (being used by the driver when the accident occurred).   There was no
previous damage noted'.  Damage to Vehicle £1 on impacting the train at  an
eleven o'clock principal impact force was to the left front causing a sheet
metal crush of 38 inches.  The bumper, grille, fender and hood deformed
rearward into the engine compartment whereby the engine separated from mounts.
The left front wheel and assembly, moved rearward.  The seats moved forward
and the driver impacted the steering wheel and column with his chest and
his head impacted the left A-Pillar as it was deformed inward and rearward.
After the initial impact a second impact of 06 hours principal force occurred
as the trailer sheared from the fifth wheel and impacted the rear of the cab
with a sheet metal crush of 18 inches compressing the cab interior by 50%
pinning the operator in.

VEHICLE DEFORMATION INDEX:  Principal Impact - 11 FLAW-4
                            Secondary Impact - 06 BDHW-4

     Vehicle #2 was a General Motors E.M.D. type locomotive pulling  47 box
cars and it sustained minor damage to the right front side.

VEHICLE DEFORMATION INDEX:  02 RFMW-1

OCCUPANT DATA

     The driver of Vehicle #1 was a 46 year old white male, 68 inches tall,
weighing 115 pounds having 30 years driving experience at approximately
15,000 miles per year.  At the time of accident he was enroute from his place
of employment with a delivery for a distant city expected to arrive 5 hours
after the accident occurred.  The accident occurred within 5 miles from the
origin.  He was familiar with the vehicle and the area having used both daily
for the past several years.  His- physical condition was normal as was V :.s men-
tal condition.  There was no alcohol or drug involvement and seat belts were
available and in use by the operator.  During the accident the driver sus-
tained the following injuries:  fractures of skullj ribs, pelvis and extremi-

 ties  contusions of lungs with hemothorax,  laceration of heart,  laceration
 of liver and spleen with hemoperitoneum,  rupture of bladder;  and contusions
 of hippocampi and temporal lobe of brain.  (AIS-8)
                                  B-43

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      The  driver  of Vehicle #2  (train) was a 57 year old vhite male, weight
 and height unknown having 40 years driving experience with 15 years as a
 railroad  engineer.  His driving record is good with 10,000 miles per year
 plus rail usage  undetermined.  He is familiar with the engine using same
 three to  four  times weekly.  At the time he was shifting cars along the
 railroad  from  yard to yard.  His engineering ability was taught to him by
 the railroad company.  There were no drugs or alcohol involved.  There were
 no  restraints  available and no injuries.  There were three passengers on
 the train and  they were not injured or restrained.   Passenger #1 was a
 white male, 56 years of age and he was seated in the front center.  Passen-
 ger #2 was a white male, 36 years of age and he was seated in the front right.
 Passenger #3 was a white male, 54 years of age and he was seated in the rear
 left.

 STANDARDS

      1.   FHSPS #9 - Identification and Surveilance of Accident Locations.
         The railroad crossing is well protected with traffic signals ac-
          tuated by the train, but it is so Little used that drivers attempt
          to beat the train.   It is recommended that gates be installed at
          the railroad crossing..

 COLLISION DESCRIPTION

     Pre-Crash

     The driver of Vehicle #1 reported to work at the usual time,  0130 hours,
 and had proceeded from the terminal to deliver a load of hardware to a dis-
 tant city.  He was operating the vehicle northbound oh a state road at an
 estimated speed of 45 to 50 m.p.h. and when he approached the east/west rail-
 road c'rossing he failed to stop for the signals and collided with the right
 front side of a slow moving freight train.   The freight train was proceeding
 eastbound at an approximated speed of 8 to 10 m.p.h.   There is no evidence
 to -show that the driver of Vehicle #1 tried to take any evasive action,  how-
 ever, the operator of the train did apply his air brakes for an emergency
 stop.

     Crash

     Vehicle #1 impacted the right front side of the train with its left front
at an eleven o'clock principal force impact with a secondary impact force  of

 06  o'clock when  the trailer  sheared off the  fifthQwheel and  impacted the
 rear of the truck  cab.  As the vehicle rotated  25  clockwise, and coming
 to  rest 42 feet  east of the  impact, the driver, who was restrained, moved
 forward and to the left impacting the steering wheel and the left A-Pil-
 lar and was impacted from the rear by the cab body and seat.

      Vehicle #2  was impacted at the right side  at front initial impact
 force at  02 o'clock deforming the entrance steps and the hand rail.  The
 unrestrained occupants were well to the rear of the impact point  and suf-
 fered no  effects of the accident.  The driver of  the train applied his  air
 brakes for an  emergency stop and the train remained on the rails  coming to
 a stop 168 feet  east of the  impact.
                                 B-44

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     Post-Crash

     Vehicle #1 came to rest 42 feet east of the impact facing east off the
roadway and Vehicle #2 came to rest' 168'feet east of the impact, on rails.
The operator and passengers of Vehicle #2 were unhurt.  The operator of
Vehicle #1,- due to the compression of the truck cab from the front and rear
impacts, vas pinned in the cab.  Emergency rescue equipment of the Police
and Fire Departments were called, responding within 10 minutes and pro-
ceeded to cut the metal attempting to free-the driver.  Due to severe de-
formation, extrication was difficult and took two hours to free the driver.
He was pronounced dead at the scene and was taken to the Office of the Chief
Medical Examiner.  During the rescue operation, traffic was tied up in both
directions and suitable detours were maintained by the police.  A two com-
pany was contacted to clear the scene of the truck and debris.  The truck
was towed to the terminal and the train was moved under its own power.  The
scene was cleared and open for traffic within four hours.

CAUSAL FACTORS, CONCLUSIONS AND RECOMMENDATIONS
     ACCIDENT CAUSATION

     Matrix Cell
     INJURY CAUSATION

     Matrix Cell

         2
               Explanation
                                   Primary Cause
                                   Driver of Vehicle #1 failed to perceive
                                   the approaching train and danger of going
                                   through signals.   (Definite)

                                   Severity Increasing

                                   Driver of Vehicle #1 made no attempt at
                                   evasive action.   (Definite)

                                   Relevant Conditions

                                   Driver of Vehicle #1 was apparently'pre-
                                   occupied with thoughts  of his  trip.   (Pro-
                                   bable)

                                   The crossing was well protected with ac-
                                   tuate'd signals (at side and overhead)  but
                                   it allows room for passage.   (Probable)
                Explanation

Driver of Vehicle #1 was wearing available
restraints but they were of no use in this
case.  (Probable)

The collapse of Vehicle #1 from front and
rear impacts added to severe injury.  (De-
finite)
                                   B-45

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POST-CRASH FACTORS

Matrix Cell                                   Explanation

    3                         Ambulance and rescue arrival within 10 min-
                              utes, but extrication was difficult taking
                              two hours with metal saws.  (Definite)

    6                         The load of Vehicle #1 shifted after the
                              initial impact.  (Definite)

    9                         There were no fires or explosions,  detours
                              were set and maintained adequately,  and the
                              clean-up operation took four hours.   (Defi-
                              nite)
                                 B-46

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WFOOL- LFG«L
    i
           B-47

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niHffyi.fi/YD  mrooz.-  LFG/U
               I
&RTKK
                                           72-2 V

                                    RCCJDfWr
                      B-48

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                         ENCLOSURE P
                       Durham City Code
                         Durham,  N.C.
Ch. 18 § 9 Locomotive Whistle.
     It shall be unlawful for any person to blow or allow to
be blown any locomotive whistle under his control within the city
limits. (Code 1940, C. 28, § 8.)

                     Knoxville City Code
                      Knoxville; Tenn.
Ch. 33 t 8 Blowing Whistles.
     It shall be unlawful for any person operating or in charge
of a locomotive engine within the corporate limits of the city
to blow the whistle on the same except as may be absolutely
necessary in the use of the signals as laid down by the rules
and regulations of railway companies, or as required by the
laws of the state.  (10-21-04.)

                      Houston City Code
                        Houston, Texas
Sec. '1843 Blowing Whistles; Blowing out Boiler
     All persons are prohibited  from blowing any whistles on
any locomotive, or single blasts therefrom, within the  limits
of the  city, for a longer period of time than five seconds,
except when there is  imminent danger  of  an  accident.  All
persons are prohibited  from blowing off  or  blowing out  a

                              B-49

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boiler when crossing any public street or other thoroughfare
within the limits of the city.  Each and every person violat-
ing any provision of this section shall be fined in any sum,
upon conviction, not less than five dollars and not exceeding
fifty dollars.

                      Mason City, Iowa
26-29 Sounding of Locomotive Whistles
     It shall be unlawful for any person to cause or permit
any locomotive whistle to be sounded within the limits of the
City except for the purpose of making necessary signals
required by law or required for the safe operation of the
railway, and where requisite signals cannot be made by other
means.  (R '16, Sec. 545.)

                      Chicago, Illinois
188-44.  No person owning or operating a railroad shall cause
or allow the whistle of any locomotive engine to be sounded
within the city, except necessary brake signals and such as may
be absolutely necessary to prevent injury to life and property.
     Each locomotive engine shall be equipped with a bell-
ringing device which shall at all times be maintained in
repair and which shall cause the bell of the engine to be rung
automatically.  The bell of each locomotive engine shall be
rung continuously while such locomotive is running within the
city,  excepting bells on locomotives running upon those
railroad tracks enclosed by walls or fences, or enclosed by a

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wall on one side and public waters on the other side,  and
excepting bells on locomotives running upon those portions  of
the railroad track which have been elevated.  In the case of
these exceptions, no bell shall berungor whistle blown except
as signals of danger.

                         Buffalo, New York
Chapter V.  RAILROADS
#4.  It shall not be lawful for any person in the employ of
any railroad company operating within the limits of the city
to permit the whistle of the locomotive under his control to
be blown, except for necessary signal purposes.  Any person
violating the provisions of this section shall pay a penalty
of $25.00 for such offense.
NOTE: This restriction is generally associated with a train
      speed restriction of 6 MPH and the use of flagmen.

                         Lynchburg, Virginia
CITY CODE SUPPLEMENT (Railroad)
Sec. 3809.  Sounding whistles or horns.
     The sounding or blowing of locomotive whistles or horns
within the corporate limits of the city of Lynchburg is hereby
prohibited, except as may be necessary for the transmission
of signals-or in emergency to prevent accidents.
     The provisions of this section shall not apply to the
two crossings of the tracks of the Chesapeake and Ohio Railway

                                  B-51

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Company at Reusens, in the vicinity of the E. J.  Lavino
Company, because of the lack of sight distance and warning
devices at these crossings.
     Any violation of this ordinance shall be punished by a
fine of not less than five dollars nor more than ten dollars
for each offense.  (1931, §704; 6-8-42; 8=28-56;  10-9-56)

                         State of Illinois
     Under authority delegated to it by the State Legislature
(llU-59), the Illinois Commerce Commission adopted General
Order #176 on August 15, 1957, excusing the sounding of horns
and whistles at crossings protected by flashing lights.  This has
now been  incorporated  in General  Order No. 138, Revised, August
22, 1973, Rule  501.
                         State of Florida
§351.03 limits  signals  to  bells only in incorporated  areas, with
an accompanying speed  limit of 12 mph.
                              B-52

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                                     ENCLOSURE G
VCKNON L. OTUROeON, FHIHOINt
WILLIAM SYMONS. J«.
f. r. VOKA8IN, JH.
THOMA< MORAN
P. W. MOLMO
    November 10,  1972
                               Itiltttrs fflomnusstcn
                            STATE  OP  CALIFORNIA
                  APDRCtfi ALL COMMUNICATIONS
                    TO THE COMMISSION

                  CALIFORNIA BTATC BUILDING

                  •AN CHANCIOCO, CALIFOHNIA K4IO1

                  YCLKPMONd <«!•> BB7- 1Q45
                     FILCNO. 1C 79403
    Honorable Arlen Gregorio
    The State Senate
    12th District,  San Mateo County
    State Capitol
    Sacramento, CA  95814

    Dear Senator Gregorio:
^
    Subsequent to receipt of your letter of October 4,  1972,  our representative
    has discussed the use of train whistles approaching railroad grade crossings
    with Mr. John Gilroy and Ms. Charlotte Schultz of your staff.

    As discussed with them, it may be necessary to sound the train whistle
    even at crossings equipped with automatic gates for the following
    reasons :

    1.  Possibility of a malfunction of the automatic grade crossing protection
        due to being struck by vehicles, vandalism or failure of track circuitry
        or  signal apparatus.

    2.  Rail highway crossings are frequently traversed by bicyclists and
        pedestrians after the protective devices have been actuated by an
        approaching train.

    3.  Impatient motorists sometimes ignore crossing signals and have been
        known to drive around protective gate arms in an attempt to avoid
        being delayed by a train.

    4.  Liability on the part of the railroads for failure to use every means
        available to avoid an accident.

    In view of the above, the staff feels that in the interest of safety, the
    railroads should not be prohibited from using the train whistles to warn
    persons that a train is approaching.

    Yours very truly,

    PUBLIC  UTILITIES COMMISSION
     WILLIAM R.  JOHNSON,  Secretary
                                       B-53

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                      Appendix C




OPERATING RAILROAD RETARDER YARDS IN THE UNITED STATES

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OPERATING RAILROAD RETARDER YARDS IN THE UNITED STATES
                   (CLASS I Railroads)

State
Alabama


Arkansas

California





Colorado

Connecticut

Florida
Georgia



Idaho

Yard
Birmingham
Birmingham
Sheffield
N. Little Rock
Pine Bluff
City of Industry
East Los Angeles
Los Angeles
Richmond
Roseville
West Colton
Grand Jet.
Pueblo
Cedar Hill (East)
Cedar Hill (West)
Tampa
Atlanta
Atlanta
Atlanta
Macon
Pocatello

Railroad
L&N
Sou
Sou
M. P.
St. L. S. W.
S. P.
U.P.
S. P.
S.P.
S. P.
S.P..
D&RGW
AT&SF
P.C.
P.C.
S. C. L.
Sou
Sou
L&N
Sou
U.P,
Number of
Tracks
40
56
32
64
30
12
16
40
8
49
56
31
16
45
38
8
12
65
24
50
40
                           C-l

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State
Illinois

















Indiana




Kansas


Kentucky



Louisiana
Maryland

Massachusetts

Yard
Bensenville
Blue Island
Chicago, Clearing
(East)
Chicago, Clearing
(West)
Chicago, Cicero
Chicago, Corwith
Chicago, 59th St.
E. St. Louis
E. St. Louis
Galesburg (East)
Galesburg (West)
Madison
Markam
Markam
Proviso
Silvio
Elkhart
Gary
Gibson (South)
Gibson (North)
Indianapolis
Argentine (East)
Argentine (West)
Armourdale
DeCoursey (North)
DeCoursey (South)
Russell
Stevens
Geismer
Cumberland (West)
Cumberland (East)
Boston

Railroad
C.M.S.P.&P.
I. H. B.
B. R. Chgo

B. R. Chgo

B. N.
AT&SF
P.C.
A. &S.
I. C. G.
B. N.
B. N.
T. R. R. A.
I. C. G.
I. C. G.
C. N. W.
C. R. I. P.
P.C.
E. J. & E.
I. H. B.
I. H. B.
P.C.
AT&SF
AT&SF
C. R. I. P.
L&N
LAN
C&O/B&O
C&O/B&O
I. C. G.
C&O/B&O
C&O/B&O
B&M
Number of
Tracks
70
42
44

36

43
32
42
42
26
49
35
34
64
45
59
50
72
58
30
30
64
48
56
40
20
24
32
15
6
32
16
22
C-2

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State
Michigan

Minnesota

Missouri


Montana
Nebraska


New Jersey

New York



North Carolina
North Dakota
Ohio









Oklahoma

Yard
Detroit
West Detroit
Minneapolis
St. Paul
Kansas City (East)
Kansas City (West)
N. Kansas City
Missoula
Lincoln
N. Platte
N. Platte (West)
Morrisville
Pavonia
Buffalo
Buffalo
DeWitt
Mechanicville
Hamlet
Minot
Bellevue
Columbus
Grandview
Marion
Portsmouth
Portsmouth (West)
Sharonville
Stanley
Walkridge
Willard
Tulsa

Railroad
DT&I
P. C.
B. N.
C.M.S.P.&P.
M. P.
M. P.
B.N.
B. N.
B.N.
U.P.
U. P.
P.C.
P. C.
E. L.
P.C.
P.C
B&M
S. C. L.
B.N.
N&W
P.C.
P.C.
E. L.
N&W
N&W
P.C.
P.C.
C&O/B&O
C&O/B&O
S. L. S. F.
Number of
Tracks
36
31
63
40
42
32
42
9
36
62
42
38
32
56
63
27
36
58
40
42
40
9
24
18
35
35
42
68
52
40
C-3

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State
Oregon
Pennsylvania









Tennessee



Texas


Virginia









Washington


Yard
Eugene
Allentown
Connellsville
Conway (East)
Conway (West)
Enola (East)
Enola (West)
Pittsburgh
Pittsburgh
Rutherford (East)
Rutherford (West)
Chattanooga
Knoxville
Memphis
Nashville
Beaumont
Fort Worth
Houston
Alexandria (North)
Alexandria (South)
Bluefield
Lamperts Point
(empty)
Lamperts Point
(loaded)
Lamperts Point
Newport News
Roan ok e
Pasco
Seattle

Railroad
S. P.
CNJ/LV
C&O/B&O
P. C.
P.C.
P.C.
P.C.
U. R. R.
Mon-Conn.
Reading
Reading
Sou
Sou
S. L. S. F.
L&N
S.P.
M. P./T. P.
S.P.
R. F. P.
R. F. P.
N&W
N&W

N&W

N&W
C&O/B&O
N&W
B.N.
B.N.
Number of
Tracks
32
19
15
54
56
33
36
23
22
33
18
50
46
50
56
12
44
48
49
39
13
36

36

30
15
56
47
16
C-4

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State
Wisconsin
Yard
Milwaukee
Railroad
C.M.S.P.&P.
Number of
Tracks
35
Abbreviations of Railroad Names Used in this Table*
L&N - Louisville and Nashville
Sou - Southern
M.P. - Missouri Pacific
St. L.S.W. - St. Louis Southwestern
S.p, _ Southern Pacific
U.P. - Union Pacific
D&RGW - Denver and Rio Grande
  Western
AT&SF - Atchison, Topeka and
  Santa Fe
P.C. - Penn Central
S.C.L. - Seaboard Coast Line
C.M.S.P.&P. - Chicago, Milwaukee,
   St. Paul and Pacific
I.H.B. - Indiana Harbor Belt Railway
B.R. Chgo - Belt  Railway of Chicago
B.N. - Burlington Northern
I.C.G. - Illinois Central Gulf
A. & S. - Alton and Southern
T.R.R.A. - Terminal Railroad Assoc. of
              St. Louis
C.N.W. - Chicago and North Western
C.R.I.P. - Chicago, Rock Island and Pacific
E.J. & E. - Elgin, Joliet, and Eastern
C&O/B&O - Chesapeake and Ohio
              Baltimore and Ohio
B&M - Boston and Maine
D.T.&I. - Detroit, Toldeo, and Ironton
E.L. — Erie Lackawanna
N&W - Norfolk and Western
S.L.S.F. - St.  Louis San Francisco
CNJ/LV - Central Railroad of New Jersey
              Lehigh Valley
U.R.R. — Union Railroad
Mon-Conn. - Monongahela Connecting
Reading - Reading Company
M.P./T.P. - Missouri Pacific/Texas Pacific
R.F.P. - Richmond, Fredericksburg and
             /Potomac
  *These abbreviations reflect mergers; the abbreviations on the accompanying map frequently
   do not reflect mergers.
                                            C-5

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            Appendix D




SUMMARY OF YARD NOISE IMPACT STUDY

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                      SUMMARY OF YARD NOISE IMPACT STUDY

INTRODUCTION
     The rail yard modeling study of noise impact on people used data collected at the Cicero
Yard of the Burlington Northern near Chicago Illinois. The study included the analysis of eight
railroad yards from a population density and yard layout standpoint which led to the selection of
the Cicero Yard for more detailed analysis. Characteristics of the noise emitted from the Cicero
Yard under a range of operating conditions were studied and a model of the yard was developed.
The model was then used to predict the impact on people (environmental noise levels) of various
noise abatement activities on different aspects of the Cicero Yard operation.

CASE STUDIES OF RAILROAD YARDS
     Eight yards having a wide range of characteristics were selected in order to compare yard
traffic with population densities near them. Such a comparison provides a basis for determining
the number and frequency of exposure of people to noise from railroad yards.  Figures D. 1 - D.8
are maps of the yards that were studied. Although no detailed studies of the zoning around the
yards were attempted, the maps provide some indication of land use. The configuration of the
yards and the traffic through the yards were determined by telephoning the yard superintendents
or the yard masters. Table D. 1 summarizes the population and traffic data for the  yards.
     The population information was taken from the 1970 Census of Housing, Block Statistics for
each city. The total populations for the cities studied were obtained from the 7970 Census of
Population, U.S. Summary. Population densities were derived for strips 250 or 500 ft wide for the
entire length of the yards and/or for a  total of 2000 ft from the retarders. Often, separate popu-
lation density estimates were made for each side of a yard, since people are not evenly distributed
around yards.  Figures D. 1 - D.8 contain graphs of the population distribution for each area.
     The population of the cities in which the yards are located ranges from 67,058 (Cicero) to
1,800 (Roseville). Population cannot be considered an index of urbanization since all of the towns
are in urbanized areas generally outside a larger urban city. No yard located in  a "rural" area was
studied as sufficiently detailed population statistics were not available for a yard located in  other
than urbanized areas.

STATISTICAL ANALYSIS OF NOISE NEAR RAILROAD YARDS
     Many methods of describing community noise have been proposed, studied, and evaluated, but
the most suitable method for describing environmental noise and its effect on people, in EPA's
                                           D-l

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                                                                       N
                                                                       i
                                                                     	 Streets
                                                                     —-~ Railroad Tracks

                                                                     1000    2000 feet
FIG D.I.   MAP  AND POPULATION DENSITY PROFILES FOR  THE  CICERO, ILLINOIS  HUMP YARD.

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       DISTANCE FROM
       YARDJOUNDARY
            (feet)
                             Streets
                             Railroad Tracks
                          1000
2000 feet
                    Both Sides Averaged Together
FIG. D.2.   MAP AND POPULATION DENSITY PROFILES FOR THE ELKHART,

            INDIANA HUMP  YARD.
                                D-3

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    DISTlfcN
    YAR
             1000
Streets

Railroad Tracks

    2000 feet
FIG. D.3.    MAP AND POPULATION DENSITY PROFILES FOR THE CHEYENNE,  WYOMING  FLAT  YARD,

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                  DISTANCE FROM
                                     Streets
                                     Railroad Tracks
                                       2000 feet
FIG. D.4.   MAP AND POPULATION  DENSITY PROFILES  FOR  THE MARKHAM,  ILLINOIS HUMP YARD

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                                                                                   Streets

                                                                                   Railroad Tracks

                                                                                        2000 feet
               NORTWWEB
               SECTlO
DISTANCE FROM  NO.
YARD BOUNDARY  PER
    (feet)
     2000
                                                       HUMP
        Fig. D.5.   MAP  AND POPULATION DENSITY  FOR THE CENTREVILLE,  ILLINOIS HUMP  YARD.

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               Streets
               Railroad Tracks
               1000       2000 feet
FIG. D.6.   MAP  AND POPULATION DENSITY PROFILES FOR THE  MECHANICVILLE, NEW  YORK HUMP YARD,

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                   DISTANCE FROM

                   YARD BOUNDARY
9
00
 .OF PEOPLE

ER SQ.MILE
                                                                                    N
                                                               Streets


                                                               Railroad Tracks
        PIG.  D.7.   MAP AND POPULATION DENSITY PROFILES  FOR  THE WAL&RIDGE., OHIO  HUMP YARD

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     DISTANCE
     YARD BOUN
         (faet)
                                                                   NO. OF PEOPLE
                                                                   PER SO. MILE
9
VO
                            Streets
                            Railroad Tracks
                         1000  2000 (••*
         FIG. D.8
MAP AND  POPULATION DENSITY  PROFILES  FOR THE ROSEVILLE, CALIFORNIA
HUMP  YARD.

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TABLE D-l    POPULATION  DENSITY AND RAILROAD  CAR  TRAFFIC  FOR  VARIOUS
                                 RAILROAD YARDS
City tnd State
Tart Operator
Cicero, 111
Burlington North.
Elkhart, Ind.
Penn. Central
Cheyenne, Wyo.
Union Pacific
Xarkhaa. 111.
111. .Central t Qulf
Centrevllle, 111.
111., Central t Gulf

Meehanlerllle, N.Y.
Boston * Xalne
Walbrldge. Ohio
Baltimore 1 Ohio
Rosevllle. Calif.
Southern Pacific
Total
Population
67,058
13,152
10,152
15.987
11,978

6.217
3.028
17,895
No. of Cars
Per Day
1000
6800
i
•
4000
•
32PJ-3400
3300-tOOO
f

BOO
1500
• 6500
•
i
»
No. of Ptople Per Square Nile Mfthfa:
0-250* ZbO'-SOO' 500 '-1000' 1000'-1500' 1500'-2000*
12,383 16,638 19,105 22,600 18,316
8*038 20,192 16,200 15,276 14,552
* 293 576 \ 510 613 1.381
t
	 1 	
592 1.193 5.098 5,189 1,6*3
151 308 ; 2.280 3,535 *.H6
171 171 337 1,139 1,016
3,156 3,76.1 : 6,771 9,783 8,793
2,892 2,781 ! 5.216 3.689 2,189
391 ! 1,111 1.903 4,201

1,971 3,789 , 10,012 10,232 7,371
1,028 t 5,788 8,583
. 44 * 89 78 78 56
267 711 ! 789 l.*00 867
1,259 1,931 2,178 1,812 2.091
690 1.925 1,960 1,977 2,125
170 " 319 263 642 389
1,276 2,468 3,947 4,053 2.516

North Section
South Section

South Section
north Section
Bast Section
Heat Section
Northeast Section
Northwest Section

South Section
North Section
Western Section
Eastern Section
Southeast Section
(entire yard)
Northwest Section
(entire yard)
Southeast Section
(opposite retainers)
Northwest Section
(opposite retarders)
Come nts
43 tracks
one master t 6 group retardtrs
72 tracks
1200 cars/day bypass ret&rfier;
manual release Inert retarders
Airport nearby
Plat yard; loccr.otives work
entire length of t^.s yard
45 tracXs
two masters, £ Ir.teraediate. 15 gro-jc
retarders ; 400 oars/day bypass
retardsr, no inert retariers
30 tr&shs
one master, 3 group retarders
1200 cars/day through retar"3*r3
nanual or ^utoiratlc rel*?3*- 'rA^~s

one master 4 6 group r^'-ar'i'rrs
36 tracks, 13 In use;
19 inert retariisrs
68 tracks
one master t 8 group retprders;
no inert ret%rders
Airport nearby
49 tracks
two husps, two caster retarders
7 group retarders
49 spring-loaded Inert retarders

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judgment, is the day/night sound level (re: Levels Document).  Ljn may be obtained from an
analysis of statittical records of noise (Schultz, 1972). Details of this procedure are in enclosure A
of section 8 of this document.  "Time records" usually means magnetic tape recordings made at
the measurement site with rugged, portable, high-quality tape recorders. Permanent recordings
permit processing a given noise record in several different ways, freeing the investigator from the
restrictions imposed by the particular analysis that might be suitable in the field.
     Figure D.9 shows portions of a time history of noise measured around 5:00 a.m. near resi-
dences about 400 ft from the boundary of a railroad yard. The record from which Figure D.9 was
constructed was produced by playing a magnetic tape recording of the noise through an A-weighting
network into a graphic level recorder. The figures show  some significant noise events that are not
associated with railroad operations.  Those events must be iliminated from statistical analysis of
the information on the tapes if the results are to be descriptive of railroad noise only.
     An edited tape, from which all non-railroad noises were removed, was prepared by selectively
interrupting a re-recording of the original tape. Both the unedited and the edited tapes of railroad
noise were processed using an electronic statistical analyzer and a digital computer,  to produce
statistical analyses like the one shown in Figure D.lOa. The tape which was generated is shown in
Figure D.9.  Figure D. 1 Ob shows the result of a statistical analysis of the edited version of the tape
that generated Figure D.lOa. The solid lines in Figure D. lOb represent the data from Figure D.lOa.
     Figure D.I Ob shows that editing out extraneous events did not cause large changes in the
statistical properties of the recorded noise, and the effect is typical of cases for which editing was
possible. For times when the community was active, it was impossible to discriminate between
noises due to railroad operations and other noises.
     Figure D. 11 shows the results of a statistical analysis of an edited tape recording of noises at
the boundary of a busy yard. Even though a few diesel trucks traveled along a street adjacent to
the boundary, editing the recorded sounds produced negligible changes in their statistical properties.
     Figures D. 12a and D. 12b demonstrate a contrasting situation.  Figure D. 12a shows the
results of statistical analysis of an unedited tape recording of noises at the boundary of the yard
described above during a period of relative inactivity.  Since much of the noise in the vicinity was
extraneous (mostly diesel trucks), editing changed the statistical properties of the recorded noise.
Figure D. 12b shows the effect of editing this tape. Even though there were few readily noticeable
railroad noises during the period covered by Figure D.I2, the continuous background noise is
higher at the boundary of the yard than in the community, illustrating the contributions of
continuously idling locomotives and other noise! associated with the activities of men and machines
assigned to the yard.
     "Energy Mean Level" is one of the parameters shown in the computer listings in Figures D. 10
through D. 12. That parameter, usually called "Lgq" is the level of the continuous sound that

                                            D-ll

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 N>
< .. .
O
.a
CM
O
o
§
   70
   60
50
~ 40
<
CD
    70
    60
    SO
   40
              _Hump Warning Signal
               torn Loudspeaker
                    V
                             Retarder
        I I I  I  I  I  I  I  I
        UJ
        _l

        O
o
CD
2
Ul
§
             Automobile
             Door Closing
                                             Locomotive
                                             Whistle
                                                                 Automobile
                                                           I  I  I  I  I  I  I  I  I  I  I
                                                             Propeller Airplane
              -Locomotive
                                  Impact of
                                  Railroad Cars
                        LJ  IIIIIIIJILI
Continuous "Background
                                                                   i  i  i  i  i
                           ARBITRARY TIME  (1 SECOND INTERVALS)
  PIG. D.9.      SELECTED EVENTS  FROM A TIME  HISTORY OF  NOISE IN A COMMUNITY 400  FT

                 FROM THE BOUNDARY OF A RAILROAD HUMP YARD.

-------
         OUt^Ut OF STATISTIC*],
CICERO JAED, HAr  17,1973*  5|20 *,«,,  WEST 3PT« SI,
<
99,9



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£ 90
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>0 0K5 050 055 060 065 070 075 080 085 090 005 100 10$ 110 11$ 1;
CCnUUTXYB DISTRIBVTIQH
MAXxnun Koxse lev? i, « 12,5
HXNXHUn KOISE 4IVIL « 31.3
KOISE fOLLUTIQU IZVZL " 71,1

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                                STANDARD DEViAHOS
                                ENEKQY  HEA8 LEVEL
  FIG. D.lOa.STATISTICS OF NO'lSE  IN A COMMUNtTY  400 FT FROM  THE
             BOUNDARY OF A RAILROAD YARD (TOTAL  NOISE; UNEDITED
             TAPE).

-------
  GRAPHICAL OUTPUT Of  STATISTICAL NOISE DATA
  CICERO YARD, HAY  17,1973, 5130 A.M., NEST 30TH ST,
  (EDITED)


      i   I   i    I   . I   (   I    I    •   i   t    l    |
I    l    i
»»» V

99



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1 \
l\ *
1 ^^
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\ X /-TOTAL NOISE
i. \/ (UNEDITED TAPE- -
RAIL YARD *S*\ ' D<10a)
NOISE ONLY / S V
(EDITED TAPE)—7 l1*^ <

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2




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" 1



.2

-3
k
    000 0U5  050 0»5 060 065 070  075 080 085 090 095  100 105 110 115  120

                         CUMVUTIVE DISTRIBUTION
                                  HAXXMUH NOISE  LEVEL   *  80,0
                                  MINIMUM NOISG  LEVEL   *  31,3
                                  NOISE POLLUTION LEVEL «  *U,3
                                  STANDARD DEVIATION    •   3,3
                                  ENERGY MEAN  LEVEL     *  55.S
PIG.  D.lOb.   STATISTICS OF  NOISE IN A  COMMUNITY  400 FT  FROM THE
               BOUNDARY OF A  RAILROAD YARD (COMPARISON OF  EDITED
               AND UNEDITED TAPES).

-------
  GRAPHICAL OUTPUT OF STATISTICAL KOlS'E  DATA
  CICEP.O YARD, KA?  17,1973,  5118 A.M.,  OG&EN AVE,
  (EDITED)
          1   •    1   1
                                       I   I   f    I   I   I    t   I
99.9



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10 045 050 055 060 065 070 075 060 0B5 090 095 100 105 110 115 1
CUMULATIVE DISTRIBUTION
MAXIMUM NOISE LEVEL • 97,5
MINIMUM NOIS£ LEVEL • 65,0
NOISE POLLUTION LEVEL » 82,6
STANDARD DEVIATION « 3,3
ENERGY MEAN LEVEL « 74,0
»3




2




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FIG. D.ll.
STATISTICS  OF NOISE AT  THE BOUNDARY  OF A RAILROAD  YARD
WHILE THE  YARD WAS BUSY (RAILROAD  NOISE ONLY;  EDITED
TAPE).
                   Q-i.5

-------
 GBAfHICAL OUTPUT  F STATISTICAL [!OlSB DATA







 CICERO  YARD, HAy 17,1973,  3130 A.M., OGDBS AVB,
     »    »    '   '   »    i    »    «    i   <    «    <    I    I   t   i   i

 99.9J''11•»•««•»»1111n11M11•it»i 11                               +3
   99
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  .1
     *                             I
                                  I
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                                   t                               :
                                   I                               t
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                                    I                              i s
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                                     t                             +06
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3                                         -:                       *


                                                                  r
                                             "*i                  !
                                                 I
                                                 i


 ..i,	:....	....:
   000 0U5 050  055 062 065 070 075 080  085 U9id 095 100 109 110  115  120


                        CUMULATIVE DISTRIBUTION



                                  MAXXffUn NOISE LEVEL   «  99.8

                                  MINIMUM NOISE LEVEL   •  77.5
                                  NOISE fOLLUTION LEVEL «  90,7'
                                  STANDARD DEVIATION     «   2,7
                                  EKERCX Nb'AN LEVEL     »  83,9
FIG.  D.12*. STATISTICS  OF NOISE  AT THE  BOUNDARY  OF A RAILROAD


             URD WHILE  THE YARD  HAS QUIET (TOTAL  NOISE;  UN-

             EDITED TAPE).

                                 D-16

-------
 GBAPHICU  OUTPUT Of STAlZSTlCAl NOISE DATA
CICEBO IAHD,
(EDITED!
                 17,1973, 3*3B A,H,,  CODES AYE,
99.9
99
p
E 90
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•
1
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I
RAIL YARD ' j
NOISE ONLY /,
(EDITED TAPE \J «
1
',
t
i
                                      TOTAL NOISE
                                      (UNEDITED TAPE-
                                       FIG. D.12a)
                                  "'••
    'BaH'attb'eJa'BSb'pfia'B^'B^a'BH'aBB'aaJ'BSB'^SS'^BB'iSs'

                                   DISTRIBUTION
                                                                 i
                                                                 +3
                                                                 I
                                                                 1
                                                                 I
                                                                 M
                                                                 t
                                                                 :
                                                                 » S
                                                                 t X
                                                                 +03
                                                                 I H
                                                                 I A
                                                                 t
                                                                 •
                                                                 1-1
                                                                 +
                                                                 t
                                                                 t
                                                                 t
                                                                 1-2
                                                                 * '
                                                                 I
                                                             ...*
                                                           »••*•*
                                                           115 1214
                                          NOJSt
                                          NOIS&
                                  NOISE FOLLUTI9N
                                  STRNDAPD DEV1ATXOH
                                  EBEROX tttiXX LEX El,
                                  PERCBNIIIE
                                                    t. 2
                                                   110
                                                 133, 3
                                                   150
                                                   L90
                                                   L99
                                          BOISE xv&ex
                                                        99,8
                                                        62,5
                                                        68,0
                                                          1.6
                                                        6 it, a
                                                        «9.1
                                                        «7.U
                                                        66.5
                                                        63.5
                                                        63.3
                                                         «»7t9
PIG.  D.12b.
              STATISTICS  OF NOISE  AT THE BOUNDARY OF A  RAILROAD
              YARD WHILE  THE YARD  WAS QUIET  (COMPARISON  OF
              EDITED AND  UNEDITED  TAPES).

                               U-17

-------
       75
      70
      65
    3 60
    n
    •o
    o
    UJ
    ._i
   I~~J 55
       50
      1     T

   CICERO YARD
"-  MAY 17,1973
                  OGOEN AVE
                  {AT THE YARD
                  BOUNDARY)
              _L
                 W. 30 TH (ABOUT
                 400 FT, FROM THE
                 YARD BOUNDARY)
                J	1	1	
         2     3     4      56     7     8

          TIME OF DAY (HOURS PAST MIDNIGHT)
FIG  D 13    MEASURED LEQ VS TIME OF  DAY FOR POINTS IN AND  NEAR A
            RAILROAD YARD (20-MIN RECORDINGS, SAMPLED 10 TIMES/

            SEC}".
                             D-18

-------
would be associated with an amount of energy equal to the sum of the energies of a collection of
discontinuous sounds. The discontinuous sounds are analyzed for a specified period of time, and
LgQ is calculated for that same period. Figure D-13 shows plots of the computer-calculated Lgq's
for the observations described above.

MODELING YARD NOISE IMPACT ON PEOPLE
    The two types of railroad switching yards are flat yards and hump yards.  In a flat railroad
yard there are two major sources of noise — locomotives and car impact.  In hump yards the squeal
caused by cars passing through retarders is significant.
    The development of a yard noise model for this Background Document involves the computa-
tion of LDN* for yards which (1) describes the activities of locomotives, (2) determines the
probabilities of occurrence of various levels of retarder squeal and car impact noise, and (3) inte-
grates the cumulative acoustic energy that is developed at a given point in the space surrounding
the yard.
    Figure D. 14a shows calculated Lrjjyj profiles for group retarders in a typical yard - the
Cicero Yard in Chicago. Figure D. 14b shows LFJN profiles for car-car impacts. Figure D. 14c shows
4)N Pr°files f°r locomotive operations in the yard.
    The calculated Lpjyj profiles in Figure D.I4 are based on observed levels and frequencies of
occurrence of various noises. In addition to the usual geometric attenuation, atmospheric
absorption and ground attenuation effects (Beranek, 1971) were included in the construction of
the figure. The levels for the individual noise events at the measurement points shown in
Figure D. 14 were consistent with the points of origin of the events also shown in Figure D. 14.
    The noise levels for retarders and rail car impacts are considerably loyer than those for loco-
motives, so that the total noise levels from all sources is approximately that of locomotives alone,
as shown in Figure D.I4. The noise levels determined from magnetic tape recordings of noise
emissions at the West 30th measurement point are also in good agreement with the total noise
emission levels (approximated by locomotive noise), as noted in Figure D.14c.
    Retarder noise levels' and impact noise levels in Figure D. 14 generally would be dominant at
community observation points if the locomotive noise levels were lowered by 10 dB( A). Thus,
retarder and car impact noise will replace locomotive noise as the most obtrusive noise in the
community near the Cicero Yard, if locomotive exhausts can be muffled sufficiently to lower their
noise by 10 dB(A) (assuming that no other sources of locomotive noise produce levels comparable
to exhaust noise  levels).
* Enclosure A of section 8.
                                            D-19

-------
                                                 RETARDED (MEASUREMENTS
                                                 IMMCT MEASUREMENTS

                                               •8838888
                                                 LOUDSPEAKERS
(a)   Retarder Squeals
PIG. D.14a.
               'ON
PROFILES  FOR BURLINfiTON  NORTHERN'S  CICERO  YARD
                                   D-20

-------
(b)   Impacts




PIG. D.14b.  (CONT.)
                               'D-21

-------
                                                          4 RFOWOER MEASUREMENTS
                                                           WP*CT MEASUREMENTS
                                                                  SOUND LEVEL
        TOTAL LOCOMOTIVE LDM ••», •! TO •• MCA8UHCD
                              (J.OO TO 7>OO A.M.)
O 1500 M^ LOCOMOTIVE IN THROTTLE
  4, SO •/• OF THE TIME

O 1800 HP LOCOMOTIVE.
  CONTINUOUS IDLE
(c)    Locomotives

FIG.  D.l4c.   (CONT.)
                                            D-22

-------
                      60
                           ORIGINAL EQUIPMENT
                           20 dB RETARDER
                           QUIETING
                           10 dB LOCOMOTIVE
                           QUIETING
                           10 dB LOCOMOTIVE
                           QUIETING AND
                           20 dB RETARDER QUIETING
                                    I
 I
9O
FIG. D.15
                70    8O

                LON  [dB(A)]

NUMBER OF PEOPLE EXPOSED  TO  VARIOUS .L

YARD OPERATIONS.

                  D-23
100
       DN
                                                    BY CICERO

-------
      Figure D. 15 shows the number of people exposed to various Ldn around the Cicero Yard.*
      Figure D.I5 indicates that a muffler which quiets locomotive exhaust noise by 10 dB(A) will
 decrease by 400 the number of people exposed to L(jn of 65 or more from the Cicero Yard opera-
 tions (assuming that no other sources of locomotive noise produce levels comparable to exhaust
 noise levels). The figure also shows that barriers providing a 20 dB(A) reduction of retarder noise
 would decrease by 200 the number of people exposed to L^n of 65 or more.
     Analysis in more detail of Figure D. 15 shows that at the time of the study, at the Cicero Yard
 approximately 4,800 people or more were exposed to noise levels higher than the L
-------
                      Appendix E

GENERAL MOTORS CORPORATION LOCOMOTIVE EXHAUST MUFFLER
             RETROFIT COST STUDY REPORTS

-------
                                                  USG 350-74-13
        GENERAL MOTORS CORPORATION






   LOCOMOTIVE EXHAUST MUFFLER RETROFIT






            Cost Study Report No. 1






LOCOMOTIVE MODELS GP49-2, GP40, GP38-2 and GP38
                                 GENERAL MOTORS CORPORATION
                                             NOVEMBER 1, 1974

-------
                                                      USG 350-74-13

                                                      Environmental AcMvtttes Staff
                                                      General Motors Corporation
                                                      General Motors Technical Center
                                                      Warren. Michigan 48090

                                                      November 1, 1974
Dr. AlvJn F. Meyer, Jr.
Deputy Assistant Administrator
  for Noise Control Programs
Environmental Protection Agency
Crystal Mall  Building -  Room 1115
1921 Jefferson Davis Highway
Arlington, Va.  20460

Dear Dr. Meyer:

Attached are five (5) copies of General Motors Locomotive Exhaust Muffler Retrofit •
Cost Study Report No. 1.

This represents the first  installment of a study undertaken by Electro-Motive Division
to estimate the cost of engine exhaust system hardware and associated locomotive
modification deemed necessary to meet the EPA proposed stationary locomotive
sound level limit of 87 dBA at 30 meters at any throttle setting.

The first report covers GM (EMD) locomotive models GP40-2, GP40, GP38-2 and
GP38.  Cost Study Report No. 1 and a series of similar reports to be submitted to
EPA will ultimately cover 14 General Motors model locomotives representing a
total of 14,789 units delivered by EMD or 63.4% of the 23,307 total GM loco-
motives in service on Class 1 and 2  Railroads as of January 1, 1974.  The figures
stated in this initial  report are not necessarily representative of the amounts that
will be submitted for other locomotive  models in subsequent  reports.

If you have any questions regarding this report, please do not hesitate to contact
me.

                                            Sincerely*'
                                            Vehicular Noise Control
 Atts. (5)
                                    E-l

-------
                       GENERAL MOTORS CORPORATION
                   LOCOMOTIVE EXHAUST MUFFLER RETROFIT
                          COST STUDY REPORT NO. 1
 LOCOMOTIVE MODELS GP40-2, GP40,  GP38-2, AND GP38


 This study is undertaken by General Motors in response to a request by the Environmental

 Protection Agency to provide cost information that would aid the EPA in evaluating the

 expense to the railroads of retrofitting in-service locomotives with exhaust muffler hardware

 to meet the EPA proposed stationary locomotive sound level limit of 87 dB(A) at any throttle

 setting measured at 30 meters.

 During a meeting at the Electro-Motive Division (EMD) of GM on September 26, 1974,

 EMD advised EPA representatives that it would undertake a "paper study" of the engine

 exhaust system hardware and associated application modifications of certain EMD locomotive

 models which would be necessary in order to comply with an 87 dBA sound level. EMD also

 stated that  this retrofit work was not being  solicited by General Motors and  that EMD

 locomotive manufacturing facilities were not sufficient to undertake this retrofit work,

 primarily due to the volume of new locomotive production. This work would presumably

 be done by the railroads themselves or by others pursuant  to contracts with railroads.   No

 attempt has been made to determine the cost for retrofit noise  control treatment necessary

 to achieve compliance with the EPA proposed locomotive noise standard of 67 dBA at

 30 meters under stationary  idle conditions.


 This study was confined to the locomotive configurations as delivered to the  railroads by

 EMD.  If there has been subsequent modification, alteration,  addition, accident, damage,

etc., to a specific locomotive which might affect the time and/or materials  necessary to

retrofit that locomotive, the estimate for that locomotive  would have to be adjusted
                                     B-2

-------
Cost Study Report No. 1
Page 2
accordingly. The figures established cover only the effort required to apply the engine

exhaust system hardware modifications.  They do not include any allowances for the

repair of, or added costs resulting from defects, accident damage, etc. which may

have to be repaired before retrofit can be accomplished, e.g., there is no provision

for radiator repair.  Cleaning and painting  are confined to only those areas involved

in the retrofit modifications.


The estimated retrofit major new hardware would be developed and sold by EMD at HMD

Parts Department prices. The miscellaneous hardware are items purchased by EMD from

others.  The amounts shown for these two classifications of hardware  and for EMD labor

are based on known, current costs at EMD as of October 1974. None of the amounts

contain any provision for future economics, and significant adjustments may be necessary

due to inflation and other considerations.  The amounts were established on preliminary

design information and sketches for engine  exhaust system hardware retrofit requirements.

Labor costs and miscellaneous new hardware do not include profit on the amount shown,

whereas,  any contractor that performed retrofit labor services  for the.railroads would

include a mark-up on this labor and on purchased materials.  These figures are also

predicted on the assumption that sufficient  tooling, facilities, and raw materials are

available to manufacture the required parts/ rebuild the engine turbochargers, alter the

locomotive carbodies and perform other operations necessary to retrofit the locomotives

and that this could all be done under normal production conditions.
                                       E-3

-------
Cost Stud/ Report No. 1
Page 3


Production line balancing, an important consideration at HMD,  is not included in this

stud/.  It should be emphasized that the necessary tooling and facilities, and floor space

required  to retrofit locomotives/ manufacture additional quantities of certain piece parts,

and rebuild of increased volume of turbochargers do not exist at this time at  EMD. Any

estimate  of the cost of the requisite tooling and facilities could only be determined

after retrofit cycle times and a schedule by locomotive model type are established.

Once this information is obtained, the amounts stated herein would have to be modified

to include such additional tooling and factilities costs since the amounts presented do not

contain allowance for this significant area of cost.  For example, we estimate that

approximately $300,000 in special tools would be required to retrofit these, four GP

locomotive models at the  rate of two units per five-day week assuming two shifts per day.


                                               /'
The stated costs for labor  are based upon the  labor costs, including burden, presently

existing  at EMO's LaGrange,  Illinois, plant and are not necessarily representative of

such costs at railroad maintenance installations or at other sources where retrofit work

might be done for the railroads.  Furthermore,  other sources may have different job codes,

shift allowances, etc., applicable to their labor force.  Therefore,  the labor costs at

such other sources would, of necessity, reflect other labor-related differences.


This study report No. 1 is the first in a series of several reports which will be submitted to

the EPA to cover ultimately 14 General Motors model locomotives representing a total of

14,789 units delivered by EMD, or 63.4 percent of the 23,307 total GM locomotives

in service on Class 1 and 2 Railroads as of January 1, 1974.   The figures stated in this

Initial report are not necessarily representative of the amounts that will be estimated


for other locomotive models in subsequent reports;


                                      E-4

-------
Cost Study Report No. 1
Page 4
GENERAL MOTORS LOCOMOTIVE MODEL    :

LOCOMOTIVE MODEL PRODUCTION DATES   :

NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY,  1974                         :

PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY, 1974     :

PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS OF JANUARY, 1974        :
GP40-2 (Turbocharged,  3,000 HP)

January, 1972 to present


165


0.7%


0.6%
MAJOR FEATURES AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE
PERCENTAGE OF TOTAL
 MODEL PRODUCTION
A.    Standard Configuration
      (No Dynamic Brakes)

B.    Standard Dynamic Brakes (Optional)

C.    Extended Range Dynamic Brakes (Optional)
      20.0%

      55.2%

      24.8%
                                 B-5

-------
 Cost Study Report No. 1
 Page 5
                            GP40-2 LOCOMOTIVE


VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:


A reactive-type exhaust muffler is installed directly on the turbocharger exhaust outlet

duct. The muffler is of straight-through design to minimize backpressure imposed on the

engine.  The weight of the muffler is supported solely by the turbocharger and, as a

result, a special -einforced turbocharger exhaust duct is required. Any electrical

cabling must be shielded from the exhaust muffler heat radiation.


The turbocharger is considered an inherently effective spark arrester; therefore  the

turbocharged engine requires no additional provision for spark arrestance hardware.
                                     E-6

-------
Cost Study Report No. 1
Page 6
A.  GP40-2 LOCOMOTIVE -  STANDARD CONFIGURATION  (NO DYNAMIC BRAKES)
    DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
    RETROFIT EXHAUST SYSTEM:

    1.   TURBOCHARGER
         The turbocharger must be removed from engine, disassembled,
         inspected, and a new, reinforced exhaust duct applied.  The
         turbocharger is then tested and reapplied to the engine.

    2.   ENGINE MAINTENANCE HATCH
         The engine maintenance hatch must be removed from locomotive.
         The turbocharger removal opening in the hatch must be enlarged
         to accommodate the exhaust muffler.  The hatch is then reapplied
         to the locomotive.

    3.   MUFFLER

         An exhaust muffler is-installed on the new turbocharger exhaust
         duct.

    4.   TURBOCHARGER REMOVAL HATCH COVER

         A new, larger hatch cover must be applied above the exhaust
         muffler to cover the enlarged turbocharger removal opening
         in the engine maintenance hatch.

    5.   OIL SEPARATOR EJECTOR

         An e{ector must be added to the oil separator to overcome the
         additional backpressure created by the exhaust muffler.
                                  E-7

-------
Cost Study Report No. 1
Page?
A.  GP40-2 LOCOMOTIVE - STANDARD CONFIGURATION  (NO DYNAMIC BRAKES)


    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

    1.   Turbocharger disassembly, inspection, machining, and application of
         new, reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.

                    I
    LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

    1.   Steel structural  shapes used to enlarge
         turbocharger removal opening.

TOTAL PRICE OF MAJOR  NEW HARDWARE REQUIRED           :   •   $ 6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :      $   300.

TOTAL COST OF LABOR TO MAKE MODIFICATION            :      $ 7,100.

TOTAL EXHAUST MUFFLER RETROFIT COST                    :      $ 14,200.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME           :      5 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                :      4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY*                 :      $   500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                 :      $ 4,500

TOTAL COST                                            :      $ 18,700
*   Based on information furnished by Burlington Northern, Milwaukee,
    Missouri Pacific, Rock Island, Southern, Southern Pacific, and
    Penn Central Railroads.

-------
Cost Stud/ Report No. 1
Page 8
B.  GP40-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
    ACCOMMODATE RETROFIT EXHAUST SYSTEM:
    1.   TURBOCHARGER

         The turbocharger must be removed from engine/ disassembled/
         inspected/ and a new/ reinforced exhaust duct applied. The
         turbocharger is then tested and reapplted to the engine.

    2.   DYNAMIC BRAKE HATCH
         The dynamic brake hatch must be removed from locomotive.
         The turbocharger removal opening in the hatch must be
         enlarged to accommodate the exhaust muffler.  Insulated
         panels must be installed to protect dynamic brake cabling in
         the vicinity of the muffler.  The dynamic brake hatch is then  '
         reapplied to the locomotive and dynamic brake cabling is
         reconnected.                     '                    •

    3.   MUFFLER

         An exhaust muffler is installed on the new turbocharger exhaust
         duct.

    4.   TURBOCHARGER  REMOVAL HATCH COVER

         A  new, larger hatch cover must be applied above the exhaust
         muffler to cover the enlarged turbocharger removal opening in
         the dynamic brake hatch.

    5.   OIL SEPARATOR EJECTOR

         An ejector must be added to the oil separator to overcome the
         additional backpressure created by the exhaust muffler.
                                 E-9

-------
 Cost Study Report No. 1
 Page 9

 B.  GP40-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

    1.   Turbocharger disassembly, inspection, machining, and application
         of new, reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.


    LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

    1.   Steel  structural shapes used to enlarge turbocharger removal
         opening.

    2.   Insulated panel heat shields.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED

TOTAL COST OF LABOR TO MAKE MODIFICATION

TOTAL EXHAUST MUFFLER RETROFIT COST

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME

LOCOMOTIVE OUT OF SERVICE COST/DAY *

TOTAL LOCOMOTIVE OUT OF SERVICE COST

TOTAL COST
$  6,800.

$    400.

$  7,700.

$ 14,900

6 days

4 days

$    500.

$  5,000.

$ 19,900.
    Based on information furnished by Burlington Northern, Milwaukee,
    Missouri Pacific, Rocli Island, Southern, Southern Pacific, and
    Penn Central Railroads.
                                E-10

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Cbst Study Report No. 1
Page 10
C.     GP40-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
       DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
       ACCOMMODATE RETROFIT EXHAUST SYSTEM:
       1.    TURBOCHARGER

            The turbocharger must be removed from engine/ disassembled, inspected,
            and a new reinforced exhaust duct applied.  The turbocharger is then tested
            and reapplied to the engine.

       2.    EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

            The extended range dynamic brake hatch must  be removed from the
            locomotive.  The hatch structure must be modified to shift the hatch
            assembly seven  inches toward the rear of the locomotive.  The
            turbocharger removal opening must be enlarged to accommodate the
            muffler.  Insulated panels must be installed to protect dynamic brake
            cabling in the vicinity of the exhaust muffler.  Dynamic brake
            cabling, conduit, and control wires, lengthened seven inches over
            the original,  must be applied. The extended range dynamic brake
            hatch is then reapplied to the locomotive and cabling and control
            wires are leconnected.

       3.    MUFFLER

            An exhaust muffler is installed on the new turbocharger exhaust
            duct.

       4.    TURBOCHARGER REMOVAL HATCH COVER

            A new, larger hatch cover must be applied above the exhaust
            muffler to cover the enlarged turbocharger removal opening in
            the dynamic brake hatch.

       5.    OIL SEPARATOR EJECTOR

            An ejector must be added to the oil  separator to overcome the
            additional backpressure created by the exhaust muffler.
                                    E-ll

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 Cost Study Report No. 1
 Page 11
 C.    GP40-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES


       LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

       1.    Turbocharger disassembly, inspection/ machining, and application
            of new, reinforced exhaust duct.

       2.    Exhaust muffler.

       3.    Turbocharger removal hatch cover.

       4.    Oil separator ejector.


       LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

       1.    Steel structure shapes used to enlarge rurbocharger removal
            opening.

       2.    Insulated panel heat shields.

       3.    Steel structural shapes and sheet used to relocate dynamic brake
            hatch structure seven inches rearward on  locomotive.

       4.    Dynamic brake cables/ conduit, and control wires.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED          :        $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :        $   500.

TOTAL COST OF LABOR TO MAKE MODIFICATION            i        $ 10,200

TOTAL EXHAUST MUFFLER RETROFIT COST                    :        $ 17,500

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME           :        7 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                :        4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *                 :        $   500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                 :        $  5,500.

TOTAL COST                                             t        $ 23,000.


*      Based on information furnished by Burlington Northern, Milwaukee, Missouri Pacific
      Rock Island, Southern, Southern Pacific, and Penn Central Railroads.             '

                                   E-12

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Cost Study Report No. 1
Page 12
GENERAL MOTORS LOCOMOTIVE MODEL

LOCOMOTIVE MODEL PRODUCTION DATES

NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY, 1974

PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY, 1974

PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS OF JANUARY, 1974
GP 40 (Turbocharged, 3,000 HP)

January, 1965 - December,  1971


1,202


5.2%


4.0%
MAJOR FEATURES AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE:
 PERCENTAGE OF TOTAL
   MODEL PRODUCTION
A.    Standard Configuration
      (No Dynamic Brakes)

B.    Standard Dynamic Brakes  (Optional)

C.    Extended Range Dynamic Brakes (Optional)
      19.8%

      74.0%

       6.2%  *
* Not considered in this study due to low population in field.
                                E-13

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  Cost Study Report No. 1
  Page 13
                                GP 40 LOCOMOTIVE
VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
A reactive-type exhaust muffler is installed directly on the turbocharger exhaust outlet

duct.  The muffler is of straight-through design to minimize backpressure imposed on the

engine.  The weight of the muffler is supported solely by the turbocharger and, as a

result, a special reinforced turbocharger exhaust duct is required.  Any electrical

cabling must be shielded from the exhaust muffler heat radiation.


The turbocharger is considered an inherently effective spark arrester;  therefore the

turbocharged engine requires no additional provision for spark arrestance hardware.
                                     E-14

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Cost Study Report No. 1
Page 14


A.    GP40 LOCOMOTIVE  -  STANDARD CONFIGURATION  (NO DYNAMIC BRAKES)
       DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
       RETROFIT EXHAUST SYSTEM:
       1.    TURBOCHARGER

            The turbocharger must be removed from engine, disassembled,
            inspected, and a new, reinforced exhaust duct applied.  The
            turbocharger is then tested and reapplied to the engine.

       2.    ENGINE MAINTENANCE HATCH

            The engine maintenance hatch must be removed from locomotive.
            The turbocharger removal  opening in the hatch must be enlarged
            to accommodate the exhaust muffler.  The hatch is then reappiied
            to the locomotive.

       3.    MUFFLER

            An exhaust muffler is installed on the new turbocharger exhaust
            duct.

       4.    TURBOCHARGER REMOVAL HATCH COVER

            A new, larger hatch cover must be applied above the  exhaust
            muffler to cover the enlarged turbocharger removal opening in
            the engine maintenance hatch.

       5.    OIL SEPARATOR EJECTOR

            An ejector must be added to the oil separator to overcome the additional
            backpressure created by the exhaust muffler.
                                    E-15

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 Cost Study Report No. 1
 Page 15
 A.    GP40 LOCOMOTIVE -  STANDARD CONFIGURATION (NO DYNAMIC BRAKES!


       LISTING OF MAJOR NEW HARDWARE'TO BE APPLIED;


       1.   Turbocharger disassembly, inspection, machining, and application
            of new, reinforced exhaust duct.

       2.   Exhaust muffler.
    «

       3.   Turbocharger removal hatch cover.

       4.   Oil separator ejector.


       LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED:


       1.   Steel structural shapes used to enlarge
           turbocharger removal opening.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED          :   $"  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :   $     300.

TOTAL COST OF LABOR TO MAKE MODIFICATION            :   $   7,100.

TOTAL EXHAUST MUFFLER RETROFIT COST                   :   $  14,200.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME           :   5 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                :   4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *                 ;   $     500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                 j   $   4,500.

TOTAL COST                                            :   $  18/700.
  Based on information furnished by Burlington Northern, Milwaukee,
  Missouri Pacific, Rock Island, Southern, Southern Pacific, and
  Penn Central Railroads.
                                 E-16

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-.Cost Study Report No. 1
 Page  16
 B.     GP40 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
        DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
        ACCOMMODATE RETROFIT EXHAUST SYSTEM:
        1.    TURBOCHARGER

             The turbocharger must be removed from engine, disassembled,
             inspected, and a new, reinforced exhaust duct applied.  The
             turbocharger is then tested and reapplied to the engine.

        2.    DYNAMIC BRAKE HATCH
             The dynamic brake hatch must be removed from locomotive.
             The turbocharger removal opening in the hatch must be
             enlarged to accommodate the exhaust muffler. Dynamic
             brake cabling within the hatch must be removed and rerouted
             to provide clearance around the muffler.  Conduits, heat
             shields, and insulated panels must be  installed to protect
             dynamic brake cabling in the vicinity of the muffler.  The
             dynamic brake hatch is then reapplied to the locomotive.

       3.    DYNAMIC BRAKE CABLING

             Dynamic brake cables connecting the electrical control
             cabinet and the dynamic brake hatch  must be removed and
             rerouted to provide clearance for the  muffler.  A closure
             box to protect the cabling near the muffler must be applied.

       4.    MUFFLER

             An exhaust muffler is installed on the new turbocharger exhaust
             duct.

       5.    TURBOCHARGER REMOVAL HATCH  COVER

             A new, larger hatch cover must be applied above the exhaust
             muffler to cover the enlarged turbocharger removal opening
             in the dynamic brake hatch.

       6.    OIL SEPARATOR EJECTOR

             An ejector must be added to the oil separator to overcome the
             additional backoressure created by the exhaust muffler.

                                      E-17

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Gist Study Report No. 1
Page 17
B.   GP40 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES


     LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


     1.  Turbocharger disassembly, inspection, machining, and application
         of new, reinforced exhaust duct.

     2.  Exhaust muffler.

     3.  Turbocharger removal hatch cover.

     4.  Oil separator ejector.


     LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

     1.   Steel structural shapes used to enlarge turbocharger removal
         opening.

     2.  Insulated panels, conduit, and sheet metal heat shields.

     3.  Dynamic brake cabling and associated connectors and cleats.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED           : $    6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  : $      800.

TOTAL COST OF LABOR TO MAKE MODIFICATION            : $   10,500.

TOTAL EXHAUST MUFFLER RETROFIT COST                   : $   18,100.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME           : 7 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                : 4 days

LOCOMOTIVE OUT OF SERVICE/DAY*                       : $      500

TOTAL LOCOMOTIVE  OUT OF SERVICE COST                : $    5,500.

TOTAL COST                                             : $   23,600

*Based on information furnished by Burlington Northern, Milwaukee, Missouri Pacific
Rock Island, Southern,  Southern Pacific,  and Penn Central Railroads.             '

                              E-18

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Cost Study Report No. 1
Page 18
GENERAL MOTORS LOCOMOTIVE MODEL

LOCOMOTIVE MODEL PRODUCTION DATES

NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY,  1974

PERCENTAGE OF TOTAL GM LOCOMOTIVES
|N FIELD SERVICE AS OF JANUARY, 1974

PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS OF JANUARY, 1974
                                         :   GP38-2 (Roots Blown, 2,000 HP)

                                         :   January, 1972 to present


                                         :   538*


                                         :   2.3%


                                         :   1.8%
MAJOR FEATURES AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE
                                         PERCENTAGE OF TOTAL
                                         MODEL PRODUCTION
A.   Standard Configuration
     (No Dynamic Brakes)
B.   Standard Dynamic Brakes (Optional)
C.   Extended Range Dynamic Brakes
     (Optional)
                                                 19.1%


                                                 57.3%



                                                 23.6%
**
      This total includes only those locomotives built since May 31, 1972.
      The remaining 185 GP38-2 locomotives had a different cooling system
      design (longer) and for retrofit of mufflers are considered with GP38
      locomotives.
**
Not considered in this study due to time constraints.  However, modifi-
cations would be similar to those for Standard Dynamic Brakes. Costs
would be slightly higher than for Standard Dynamic Brakes due to more
extensive hatch work required.
                              E-19

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 Cost Study Report No. 1
 Page 19
                        GP38-2 LOCOMOTIVE
VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
The exhaust system consists of a set of engine-mounted spark arresting exhaust

manifolds connected in series and terminating in a common outlet. An exhaust

muffler is mounted in an opening made in the locomotive carbody roof structure

adjacent to the engine cooling system. A flexible connection is applied to

couple the engine-mounted exhaust manifolds to the hood-mounted muffler.

The muffler is a reactive-type and of straight-through design to minimize
                         »
backpressure imposed on the engine.
                                E-20

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Cost Study Report No. 1
Page 20


A.   GP38-2 LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
      DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
      ACCOMMODATE RETROFIT EXHAUST SYSTEM:
      1.    ENGINE MAINTENANCE HATCH
           The engine maintenance hatch must be removed from locomotive.
           The rear section of the hatch is lengthened approximately 24 inches
           and the structure is modified by providing an opening and supports
           to accept an exhaust muffler.

      2.   LOCOMOTIVE CARBODY
           The locomotive carbody to the rear of the air filter compartment must
           be removed from the locomotive. The carbody structure is modified
           adjacent to the radiators to accept the lengthened engine maintenance
           hatch. The carbody is then reapplied and all  piping and wiring dis-
           connected to remove the carbody is reconnected.

      3.   ENGINE EXHAUST MANIFOLDS
           The existing exhaust manifolds are removed from the engine and scrapped.
           A new set of spark arresting exhaust manifolds is applied to the engine
           including interconnecting hardware between the manifolds. The engine
           maintenance hatch is then reapplied.

      4.   MUFFLER

           An exhaust muffler Is installed In the opening made in the engine
           maintenance hatch.  A flexible connection between the muffler and the
           exhaust manifolds is applied.

      5.   COOLING SYSTEM PIPING
           A modified engine water outlet casting is required to provide clearance
           around the exhaust system.  Piping between the engine water outlet and
           the radiators must be altered.

      6.   MUFFLER  HATCH COVER
           A muffler hatch cover must be added to cover the exhaust muffler and
           complete the locomotive carbody roof.
                                   E-21

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Cost Study Report No. 1
Poge 21
A.   GP38-2 LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)


     LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


     1.   Spark arresting exhaust manifolds and interconnecting hardware.

     2.   Exhaust muffler.

     3.   Flexible connection.

     4.   Muffler hatch cover.

     5.   Engine water outlet casting.


     LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED:
     1.   Steel structural shapes and sheet used Jo modify engine maintenance
          hatch and locomotive carbody.

     2.   Engine water piping.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED             :  $  11,300.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED     :  $    500.

TOTAL COST OF LABOR TO MAKE MODIFICATION               :  $  10,800.

TOTAL EXHAUST MUFFLER RETROFIT COST                      :  $  22,600

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME              :  9 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                   :  4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *                   :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                   :  $  6,500.

TOTAL COST                                               :  $  29,100

*Based on information furnished by Burlington Northern, Milwaukee, Missouri Pacific,
Rock Island,  Southern, Southern Pacific, and Penn Central Railroads.
                                E-22

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Cost Study Report No. 1
Page 22
B.    GP38-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
      DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
      ACCOMMODATE RETROFIT EXHAUST SYSTEM:
      1.    DYNAMIC BRAKE HATCH
           The dynamic brake hatch must be removed from the locomotive.
           The rear section of the hatch is lengthened approximately 24 inches
           and the structure is modified by providing an opening and supports
           for an exhaust muffler.

      2.   LOCOMOTIVE CARBODY
           The locomotive carbody to the rear of the air filter compartment must
           be removed from the locomotive. The carbody structure is modified
           adjacent to the radiators to accept the lengthened engine mainten-
           ance hatch.  The carbody is then reapplied and all piping and wiring
           disconnected to remove the carbody is reconnected.

      3.   ENGINE EXHAUST MANIFOLDS
           The existing exhaust-manifolds are removed from the engine and
           scrapped.  A new set of spark arresting exhaust manifolds is applied
           to the engine including interconnecting hardware between the mani-
           folds.  The dynamic brake hatch is then reapplied.

      4.   MUFFLER

           An exhaust muffler is installed in the opening made in the dynamic
           brake hatch.  A flexible connection between the muffler and the
           exhaust manifolds is applied.

      5.   COOLING SYSTEM PI PI NG
           A modified engine water outlet casting is required to provide clearance
           around the exhaust system.  Piping between the engine water outlet
           and the radiators must be altered.

      6.   MUFFLER HATCH COVER

           A muffler hatch cover must be added to cover the exhaust muffler
           and complete the locomotive carbody roof.

                                   E-23

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 Cost Study Report No. 1
 Page 23
 B.    GP38-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES


      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

     •
      1.   Spark arresting exhaust manifolds and interconnecting hardware.

      2.   Exhaust muffler.
  f
      3.   Flexible connection.

      4.   Muffler hatch cover.

      5.   Engine water outlet casting.


      LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED:
     1.   Steel structural shapes and sheet used to modify dynamic brake
          hatch and locomotive carbody.

     2.   Engine water piping.              .       /
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED          :  $  11,300.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :  $     500.

TOTAL COST OF LABOR TO MAKE MODIFICATION            :  $  11,200.

TOTAL EXHAUST MUFFLER RETROFIT COST                   s  $  23,000..

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME           «  9 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME               :  4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *                :  $     500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                :  $   6,500.

TOTAL COST                                            :  $  29,500.


*Bosed on information furnished by Burlington Northern, Milwaukee, Missouri Pacific
Rock Island, Southern, Southern Pacific, and Penn Central Railroads.

                               E-24

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Cost Study Report No. 1
Page 24
 GENERAL MOTORS LOCOMOTIVE MODEL

 LOCOMOTIVE MODEL PRODUCTION DATES

 NO. OF LOCOMOTIVES PRODUCED AS OF
 JANUARY, 1974

 PERCENTAGE OF TOTAL GM LOCOMOTIVES
 IN FIELD SERVICE AS OF JANUARY, 1974

 PERCENTAGE OF TOTAL LOCOMOTIVES IN
 FIELD SERVICE AS OF JANUARY, 1974
:    GP38 (Roots Blown, 2, 000 HP)

:    January,  1966 to December, 1971


:    977*


:    4.2%


:    3.3%
 MAJOR FEATURES AFFECTING AVAILABLE
        EXHAUST MUFFLER SPACE:
PERCENTAGE OF TOTAL
MODEL PRODUCTION
 A.   Standard Configuration
      (No dynamic brakes)
 B.    Standard Dynamic Brakes {Optional)
         15.6%


         54.3%
 C.   Extended Range Dynamic Brakes
      (Optional) and Oil Bath Engine
      Air Filters
         12.9%
 D.   Extended Range Dynamic Brakes
      (Optional) and Paper Engine Air
      Filters
         17.2%
 *Th!s total includes 185 GP38-2 locomotives which were built with cooling systems
 similar to GP38 locomotives.
                                E-25

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Cost Study Report No. 1
Page 25
                      GP38 LOCOMOTIVE
VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK
ARRESTING WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL
FEATURES:
The exhaust system consists of a set of engine-mounted spark arresting

exhaust manifolds connected in series and terminating in a common outlet.

An exhaust muffler is mounted in an opening made in the locomotive

carbody roof structure adjacent to the engine cooling system.  A flexible

connection is applied to couple the engine-mounted exhaust manifolds to

the hood-mounted muffler.  The muffler is a: reactive-type and of straight-

through design to minimize backpressure imposed on the engine.
                           E-26

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Cost Study Report No. 1
Page 26

A.   GP38 LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKE)

     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOM-
     MODATE RETROFIT EXHAUST SYSTEM:
     1.    ENGINE MAINTENANCE HATCH

          The engine maintenance hatch must be removed from locomotive.  The
          rear section of the hatch is lengthened approximately 24 inches and
          the structure is modified by providing an opening and supports to
          accept an exhaust muffler,

     2.    LOCOMOTIVE CARBODY AND COOLING SYSTEM
          The locomotive carbody to the rear of the air filter compartment must
          be removed from the locomotive.  The existing cooling system and
          supporting structure must be removed from the carbody.  This involves
          radiators,  cooling fans, shutters, piping, electrical wiring, and steel
          structure.  The structure must be rebuilt to accept a shortened radiator
          set.  The two cooling fans must be rebuilt with extra blades.  New,
          shorter shutter assemblies must be installed.  The electrical wiring must
          be relocated.  A new fan hatch, and repositioning the fans is required.
          In addition, the carbody structure must be modified to accept the
          increased length engine maintenance hatch. The carbody is then
          reapplied and all piping and wiring disconnected to remove the
          carbody is reconnected.

     3.    ENGINE EXHAUST MANIFOLDS
          The existing exhaust manifolds are removed from the engine and scrapped,
          A new set of spark arresting exhaust manifolds is applied to the engine
          including interconnecting hardware between the manifolds.  The engine
          maintenance hatch is then reapplied.

    4.    MUFFLER

          An exhaust  muffler is installed in the opening made in the engine
          maintenance hatch.  A flexible connection between the muffler and
          the exhaust manifolds is applied.

    5.    COOLING SYSTEM PI PING
          A modified engine water outlet casting is required to provide clearance around
          the exhaust system.  Piping between the engine water outlet and the radiators
          must be altered.

     6.   MUFFLER HATCH COVER

          A muffler hatch cover must be added to cover the exhaust muffler and
          complete the locomotive carbody roof.
                                   E-27

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Cost Study Report No. 1
Page 27
A.   GP38 LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
     LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;
     1.  Spark arresting exhaust manifolds and interconnecting hardware.
     2.  Exhaust muffler.
     3.  Flexible connection.
     4.  Muffler hatch cover.
     5.  Engine water outlet casting.
     6.  Rebuilt cooling fans with extra blades (two).
     7.  Cooling fan hatch.
     8.  Radiator support assembly*
     9.  Radiator shutters.
     LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED;
     1.  Steel structural shapes and sheet used to modify engine maintenance hatch.
     2.  Steel structural shapes and sheet used to modify cooling system and locomotive carl
     3.  Engine water piping.
     4.  Conduit and wiring.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED                :   $ 15,000.
TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED       :   $    800.
TOTAL COST OF LABOR TO MAKE MODIFICATION                 :   $ 18,100.
TOTAL EXHAUST MUFFLER RETROFIT COST                         :   $ 33,900.
LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME                :   12 days
LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                     :   4 days
LOCOMOTIVE OUT OF SERVICE COST/DAY*                      :        500.
TOTAL LOCOMOTIVE OUT OF SERVICE COST                      .      8,000.
TOTAL COST                                                  :   $ 41,900.
*Basedon Information furnished by Burlington Northern,  Milwaukee, Missouri Pacific,
Rock Island, Southern, Southern Pacific, and Penn Central Railroads.
                                E-28

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hjdy Report No. 1
8

GP38 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES

DESCRIPTION OF MODIFICATIONS NECESSARY TO ACCOMMODATE
RETROFIT EXHAUST SYSTEM:

1.  DYNAMIC BRAKE HATCH
    The dynamic brake hatch most be removed from locomotive. The rear
    section of the hatch is lengthened approximately 24 inches and the
    structure is modified by providing an opening and supports for an
    exhaust  muffler.

2.  LOCOMOTIVE CARBODY AND COOLING SYSTEM

    The locomotive carbody to the rear of the air filter compartment must
    be removed from the locomotive.  The existing cooling system and
    supporting structure must be removed from the carbody.  This involves
    radiators, cooling fans, shutters, piping, electrical wiring, and steel
    structure. The structure must be rebuilt to accept a shortened radiator
    set.  The two cooling fans must be rebuilt with extra blades.  New,
    shorter shutter assemblies must be installed.  The electrical wiring must be
    relocated.  A new fan hatch and repositioning the fans is required.
    In addition,  the carbody structure must be modified to accept  the in-
    creased  length dynamic brake hatch.  The carbody is then reapplied
    and all piping and wiring disconnected to remove the carbody is reconnected.

3.  ENGINE EXHAUST'MANIFOLDS
    The existing exhaust manifolds are removed from the engine and scrapped.
    A new set of spark arresting exhaust manifolds is applied to the engine
    including interconnecting hardware between the manifolds. The
    dynamic brake hatch is then reapplied.

4.  MUFFLER

    An exhaust muffler is installed in the opening made in the dynamic brake
    hatch.  A flexible connection between the muffler and the exhaust mani-
    folds is  applied.

5.  COOLING SYSTEM PI PING
     A modified engine water outlet casting is required to provide clearance
     around the exhaust system. Piping between the engine water outlet and
     the radiators must be altered.

 3.   MUFFLER HATCH COVER

     A muffler hatch cover must be added to cover the exhaust muffler and
     complete the locomotive carbody roof.
                            E-29

-------
 Cost Study Report No. 1

 Page 29




 B.   GP38 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES



      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;



      1.   Spark arresting exhaust manifolds and interconnecting hardware.


      2.   Exhaust muffler.


      3.   Flexible connection.


      4.   Muffler hatch cover.



      5.   Engine water outlet casting.


      6.   Rebuilt cooling fans with extra blades (two).


      7.   Cooling fan hatch.



      8.   Radiator support assembly.



     9.   Radiator shutters.


     LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED:


     1.   Steel structural shapes and sheet used to modify dynamic brake hatch.


     2.   Steel structural shapes and sheet used to modify cooling system and locomotive carbody,



     3.   Engine water piping.


     4.   Conduit and wiring.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED             :  $  15,000.


TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED     :  $     800.



TOTAL COST OF LABOR TO MAKE MODIFICATION               s  $  18,700.


TOTAL EXHAUST MUFFLER RETROFIT COST                      :  $  34,500.


LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME              :  12 days


LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                   :  4 days


LOCOMOTIVE OUT OF SERVICE COST/DAY *                   :  $    500.


TOTAL LOCOMOTIVE OUT OF SERVICE COST                   t  $   8,000.



TOTAL COST                                                .  $  42,500.


'Based on information furnished by Burlington Northern, Milwaukee, Missouri Pacific,

and Penn Central Railroads.
                                 E-30

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Cost Study Report No. 1
Page 30
C.    GP38 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
      AND OIL BATH ENGINE AIR FILTERS	

      DESCRIPTION OF MODIFICATIONS NECESSARY TO ACCOMMODATE
      RETROFIT EXHAUST SYSTEM:
      1.   EXTENDED RANGE DYNAMIC BRAKE HATCH

          The extended range dynamic brake hatch must be removed from locomotive.
          The rear section of the hatch is lengthened approximately 24 inches and the
          structure is modified by providing an opening and supports for an exhaust muffler.

      2.   LOCOMOTIVE CARBODY AND COOLING SYSTEM

          The locomotive carbody to the rear of the air filter compartment must be
          removed from the locomotive. The existing cooling system and supporting
          structure must be removed from the carbody. This involves radiators,
          cooling fans, shutters, piping, electrical wiring, and steel structure.  The
          structure must be rebuilt to accept a shortened radiator set.  The two cooling
          fans must be rebuilt with extra blades. New, shorter shutter assemblies must
          be installed. The electrical wiring must be relocated.  A new fan hatch
          and repositioning the fans is required.  In addition, the carbody structure
          must be modified to accept the increased length dynamic brake hatch.
          The carbody is then reapplied and all piping and wiring disconnected to
          remove the carbody is reconnected.

      3.   ENGINE EXHAUST MANIFOLDS
          The existing exhaust manifolds are removed from the engine and scrapped.
          A new set of spark arresting exhaust manifolds is applied to the engine
          including interconnecting hardware between the manifolds.  The dynamic
          brake hatch is then reapplied.

      4.  MUFFLER

          An exhaust muffler is installed in the opening made in the dynamic brake
          hatch.  A flexible connection between the muffler and the exhaust
          manifolds is applied.

      5.  COOLING  SYSTEM PIPING
          A modified engine water outlet casting is required to provide clearance around
          the exhaust system.  Piping between the engine water outlet and the radiators
          must be altered.

      6.  MUFFLER HATCH COVER

          A muffler hatch cover must be added to cover the exhaust muffler and complete
          the locomotive carbody roof.
                                    E-31

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Cost Study Report No. 1
 Page 31

 C.   GP38 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
      AND OIL BATH ENGINE AIR FILTERS _ . _ _

      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

      1 .  Spark arresting exhaust manifolds and interconnecting hardware.

      2.  Exhaust muffler.

      3.  Flexible connection.

      4.  Muffler hatch cover,

      5.  Engine wafer outlet casting.

      6.  Rebuilt cooling fans with extra blades (two).

      7.  Cooling fan hatch.
                      i
      8.  Radiator support assembly.

      9 .  Radi ator shu tters .

      LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED;

      1 .  Steel structural shapes and sheet used to modify extended range dynamic brake hatch.

      2.  Steel structural shapes and sheet used to modify cooling system and locomotive carbody.

      3.  Engine water piping.

      4.  Conduit and wiring.

TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED

TOTAL COST OF LABOR TO MAKE MODIFICATION

TOTAL EXHAUST MUFFLER RETROFIT COST

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME

LOCOMOTIVE OUT OF SERVICE COST/DAY *

TOTAL LOCOMOTIVE OUT OF SERVICE COST

TOTAL COST


                   ^

                                  E-32
  $  15,000.

  $     800.

  $  18,900.

  $  34,700.

  12 days

  4 days

  $     500.

  $   8,000.

:  $  42,700.

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Cost Study Report No. 1
Page 32
D.   GP38 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     AND PAPER ENGINE AIR FILTERS	

     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:

     1.   EXTENDED RANGE DYNAMIC BRAKE HATCH

          The extended range dynamic brake hatch must be removed from locomotive.
          Approximately 23 inches is removed from the front of the hatch to effectively
          move the hatch forward on the locomotive.  The rear section of the hatch is
          then lengthened about 47 inches and the structure is modified by providing
          an opening and supports for an exhaust muffler.  Dynamic brake cables,
          conduit, and control wires must be removed and rerouted.

     2.   LOCOMOTIVE CARBODY AND COOLING SYSTEM

          The locomotive carbody to the rear of the air filtsr compartment must be
          removed from the locomotive. The existing cooling system and supporting
          structure must be removed from the carbody. This involves radiators, cooling
          fans, shutters, piping, electrical wiring,  and steel structure. The structure
          must be rebuilt to accept a shortened radiator set.  The two cooling fans
          must be rebuilt with extra blades.  New,  snorter shutter assemblies must be
          installed.  The electrical wiring must  be relocated.  A new fan hatch and
          repositioning the fans is required.  In  addition, the carbody structure must
          be modified to accept the increased length dynamic brake hatch.  The
          carbody is then reapplied and all piping and wiring disconnected to remove
          the carbody is reconnected.

     3.   ENGINE  EXHAUST MANIFOLDS

          The existing exhaust manifolds are removed from the engine and scrapped.
          A new set of spark arresting exhaust manifolds is applied to the engine
          including interconnecting hardware between the manifolds.  The dynamic
          brake hatch is then reapplied.

     4.   MUFFLER

          An exhaust muffler is installed in the  opening made in the dynamic brake
          hatch.  A flexible connection between the muffler and the exhaust manifolds
          is applied.

      5.   COOLING SYSTEM PIPING
          A modified engine water outlet casting is required to provide clearance around
          the exhaust system.  Piping between the engine water outlet and the radiators
          must be altered.
      6.  MUFFLER HATCH COVER

          A muffler hatch cover must be added to cover the exhaust muffler and complete
          the locomotive carbody roof.
                                     E-33

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Cost Study Report No. 1
Page 33

D.   GP38 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     AND PAPER ENGINE AIR FILTERS	

     LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

     1.   Spark arresting exhaust manifolds and interconnecting hardware.

     2.   Exhaust muffler.

     3.   Flexible connection.

     4.   Muffler hatch cover.

     5*   Engine water outlet casting.
                        i
     6.   Rebuilt cooling fans with extra blades (two).

     7.   Cooling fan hatch.

     8.   Radiator support assembly.

     9.   Radiator shutters.

     LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED:

     1.   Steel structural shapes and sheet used to modify extended range
         dynamic brake hatch.

     2.  Steel structural shapes and sheet used to modify cooling system
         and locomotive cat-body.

     3.  Engine water piping.

     4.  Conduit and wiring.

     5.  Dynamic brake cabling.
                                  E-34

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Cost Study Report No, 1
Page  34
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED             :    $  15,000.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED     :    $     800.

TOTAL COST OF LABOR TO MAKE MODIFICATION              i    $  20,500.

TOTAL EXHAUST MUFFLER RETROFIT COST                     :    $  36,300.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME             :    13 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME                  :    4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *                   :    $     500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST    .               :    $   8,500.

TOTAL COST                                              :    $  44,800.
*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Rock Island, Southern, Southern Pacific,
   and Penn Central Railroads
                                E-35

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                                            USG 350-74-16
    GENERAL MOTORS CORPORATION
LOCOMOTIVE EXHAUST MUFFLER RETROFIT
       COST STUDY REPORT NO. 2
   LOCOMOTIVE MODELS GP7, GP9, GP18
                            GENERAL MOTORS CORPORATION
                                       NOVEMBER 15, 1974
              E-36

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                                                  USG 350-74-16
                                                  Environmental Activities Stan
                                                  General Motors Corporation
                                                  General Motors Technical Center
                                                  Warren, Michigan 48090

                                                  November  15,  1974
Dr. Alvin F. Meyer, Jr.
Deputy Assistant Administrator
  for Noise Control Programs
Environmental Protection Agency
Crystal Mall Building - Room 1115
1921 Jefferson Davis Highway
Arlington, Virginia  20460

Dear Dr. Meyer:

In response to your request for Locomotive Exhaust Muffler Retrofit-Cost Study,
we are attaching five (5) copies of Report No. 2.

This represents the second installment of a study undertaken by Electro-Motive
Division to estimate the cost of engine exhaust system hardware and associated
locomotive modification deemed necessary to meet the EPA proposed stationary
locomotive sound level  limit of 87 dBA at 30 meters at any throttle setting.

The second report covers GM (EMD)  locomotive models GP7, GP9, and GP18.
It should be pointed out that the proposed exhaust system hardware for these
three GP locomotive models is not available and would require further design and
performance evaluation with subsequent structural durability testing prior to pro-
duction usage.

Cost Study Report  No. 2 and a series of similar reports to be submitted to EPA  s
will ultimately cover 14 General Motors model locomotives representing a total
of 14,789 units delivered by EMD, or 63.4% of the 23,307 fotql GM locomotives
in service on Class 1 and 2 Railroads as of January 1, 1974.  The figures stated
In this report are not necessarily representative of the amounts that will be sub-
mitted for other locomotive models in subsequent reports.

If you have  any questions regarding this report, please do not hesitate to contact me.
                                         Sinc
                                         E.'G~. Ratering,
                                         Vehicular Noise Control
 Attachments (5)
                                E-37

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                      GENERAL MOTORS CORPORATION

                    LOCOMOTIVE EXHAUST MUFFLER REPORT

                         COST STUDY REPORT NO. 2
LOCOMOTIVE MODELS GP7,  GP9, and GP18





This study was undertaken by General Motors in response to a request by the Environ-



mental Protection Agency to provide cost information on the expense to the railroads of



retrofitting in-service locomotives with exhaust muffler hardware. Such retrofit would



enable a diesel locomotive to meet the EPA proposed stationary locomotive sound  level



limit of 87 dB (A) at any throttle setting measured at 30 meters.





During a meeting at the Electro-Motive Division (EMD) of GM on September 26,  1974,



EMD advised EPA representatives that It would undertake a "paper study" of the engine
                                               *


exhaust system hardware and associated application modifications of certain EMD



locomotive models which would be necessary in order to comply with an 87 dB (A) sound



level.






EMD also stated that this retrofit work was not being solicited by General Motors  and



that EMD locomotive manufacturing facilities were not sufficient to undertake this retrofit



work, primarily due to the volume of hew locomotive production.  This work would



presumably be done by the railroads themselves or by others pursuant to contracts with



railroads.
                                    E-38

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Cost Study Report No. 2
Page 2
No attempt has been made to determine the cost for retrofit noise control treatment

necessary to achieve compliance with the EPA proposed locomotive noise standard

of 67 dB (A) at 30 meters under stationary idle condition.


It should be pointed out that the  proposed exhaust system hardware for the three GP

locomotive models covered in this second cost study Is not available and would

require  further design and performance evaluation with subsequent structural durability

testing prior to production usage.


This study was confined to the locomotive configuration as delivered to the .railroads

by EMD.  If there has been subsequent modification, alteration, addition, accident,

damage, etc., to a specific locomotive which might affect the time and/or materials

necessary to retrofit that locomotive,  the estimate for that  locomotive would have to be

adjusted accordingly.  These data cover only the effort required to apply  the engine

exhaust system hardware modifications.  They do not include any allowances for the

repair of, or added costs resulting from defects, accident damage, etc. which  may

have to be repaired before  retrofit can be accomplished, e.g., there is no provision

for radiator repair.  Cleaning and painting are confined to  only those areas involved

in the retrofit modifications.


The estimated retrofit mafor new hardware would have to be developed and sold by

EMD at EMD Parts Department prices. The miscellaneous hardware are items which
                                     E-39

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Cost Study Report No. 2

Pa0e3




would be purchased by EMD from others.  The amounts shown for these two classi-


fications of hardware and for EMD labor are based on known, current costs at  EMD


as of October 1974. None of the amounts contain any provision for future economics,


and significant adjustments may be necessary due to inflation and other consideration's.


The amounts were established on preliminary design information and sketches for

  *

engine exhaust system hardware retrofit requirements.




Labor costs and miscellaneous new hardware do not include profit on the amount shown,
                                                    ii

whereas, any contractor that performed retrofit labor services for  the railroads would


Include a mark-up on this labor and on purchased materials.  These figures are also


predicated on the assumption that sufficient tooling, facilities, and raw materials are


available to manufacture the required parts, alter the locomotive carbodies, and perform


other operations necessary to retrofit the locomotives.  Moreover, it is presumed that


this could all be done under normal production conditions.
                                 .»


Production line balancing (the utilization of  labor in the most equitable and efficient


manner) is an important consideration at EMD, but is not included in this study.  It


should be emphasized that the necessary tooling and facilities, and  floor space re-


quired to retrofit locomotives and manufacture additional quantities of certain piece


parts, do not exist at this time at EMD.  Any estimate of the cost of the requisite tool-


Ing and facilities could only be determined after retrofit cycle times and a schedule by


by locomotive model type are established. Once this information is obtained, the


amounts stated herein would have to be modified to include such  additional tooling and


facilities costs since the amounts presented do not contain allowance for this significant



area of cost,

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Cost Study Report No.  2
Page 4
GENERAL MOTORS LOCOMOTIVE MODEL

LOCOMOTIVE MODEL  PRODUCTION  DATES

NO.  OF LOCOMOTIVES PRODUCED^AS OP
JANUARY, 1974

PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE  AS OF JANUARY, 1974

PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS  OF JANUARY,  1974
                                         GP7  (Roots Blown,  1,500 HP)

                                         1949  - 1954


                                         2,619


                                         11.2%


                                          8.7%
MAJOR FEATURES  AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE
                                         PERCENTAGE OF  TOTAL
                                         MODEL PRODUCTION
A.     Standard  Configuration
       (No Dynamic Brakes)
B.
Standard  Dynamic Brakes  (Optional)
C.     Winterization (Optional) *
85.9%


14.1%


24.6%
     Costs developed with regard to this optional feature are in addition to those established
     for features A and B listed above.  The winterization feature involves the addition of a
     duct which takes warm air from the radiator and recirculares it to the engine room to melt
     any snow which has accumulated there. Used on those locomotives which are regularly
     operated In cold climates.
                                  E-41

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Cost Study Report No.  2
Page 5
GENERAL MOTORS LOCOMOTIVE MODEL

LOCOMOTIVE MODEL PRODUCTION DATES

NO. OF  LOCOMOTIVES  PRODUCED AS  OF
JANUARY,  1974

PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY,  1974

PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS OF JANUARY, 1974
GP9  (Roots Blown,  1,750  HP)

1954  - 1959


3,480


14.9%


11.6%
MAJOR  FEATURES AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE
PERCENTAGE OF TOTAL
MODEL  PRODUCTION
A.     Standard Configuration
       (No Dynamic Brakes)

B.     Standard Dynamic Brakes  (Optional)

C.     Winterization  (Optional)  *
      40.2%


      59.8%

      22.8%
      Costs developed with regard to this optional feature are in addition to those established
      for features A and B listed above. The winterization feature involves the addition of a
      duct which takes warm air from the radiator and recirculates it to the engine room to melt
      any snow which has accumulated there.  Used on those locomotives which are regularly
      operated in cold climates.
                                  E-42

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Cost Study Report No.  2
Page 6
GENERAL MOTORS LOCOMOTIVE MODEL

LOCOMOTIVE MODEL  PRODUCTION  DATES

NO. OF LOCOMOTIVES PRODUCED  AS OF
JANUARY, 1974
     *
PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE  AS OF JANUARY, 1974

PERCENTAGE OF TOTAL LOCOMOTIVES
IN FIELD SERVICE  AS OF JANUARY, 1974
GP18  (Roots blown,  1,800  HP)

1959  -  1963


343


1.5%                    :


1.1%
MAJOR FEATURES AFFECTING AVAILABLE
       EXHAUST MUFFLER SPACE
PERCENTAGE OF  TOTAL
MODEL PRODUCTION
A.     Standard  Configuration
       (No Dynamic Brakes)

B.     Standard  Dynamic Brakes (Optional)

C.     Winterization (Optional)  *
      74.0%


      26.0%

       7.2%
      Costs developed with regard to this optional feature are in addition to those established
      for features A and B listed above.  The winterization feature involves the addition of a
      duct which takes warm air from the radiator and recirculates it to the engine room to melt
      any snow which has accumulated there. Used on those locomotives which are regularly
      operated in cold climates.                               .   -

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Cost Study Report No. 2
Page 7
                   GP7, GP9, and GP18 LOCOMOTIVES


       DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
The exhaust system consists of a set of four engine-mounted spark

arresting exhaust manifolds connected in pairs and terminating in

two flanged outlets.  Two exhaust mufflers are mounted directly on

the exhaust manifold flanged outlets and protrude through openings

made in the roof structure.  The weight of the mufflers is sup-
                                        »
ported by the exhaust manifolds which are reinforced to accept the

added loads.  The muffler is a reactive-type of straight-through
                             ft
design to minimize backpressure imposed on the engine.
                              E-44

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Cost Study Report No. 2
Page 8
A.    GP7, GP9, and GP18 LOCOMOTIVES - STANDARD CONFIGURATION
      (NO DYNAMIC BRAKES)
      DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
      ACCOMMODATE RETROFIT EXHAUST SYSTEM:
      1.   LOCOMOTIVE CARHOPY

           The locomotive carbody to the rear of the cab
           must be removed from the locomotive.  The
           existing exhaust stack openings in the carbody
           roof must be enlarged and the adjacent structure
           modified to allow the muffler to protrude through
           the locomotive roof.

      2 •   ENGIISia EXHAUST MANIFOLDS

           The existing exhaust manifolds are removed from
           the engine and scrapped.  A new set of spark
           arresting manifolds and interconnecting hardware  t
           is applied to the engine.  The locomotive carbody
           is then reapplied and all piping and wiring dis-
           connected to remove the carbody is reconnected.

      3.   MUFFLER

           Two exhaust mufflers are applied to the new
           engine exhaust manifolds through the openings
           made in the carbody roof.

      4.   MUFFLER COVER

           A roof-mounted cover is applied over each muffler
           to protect the muffler and minimize rain intrusion
           into the locomotive.
                               E-45

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Cost Study Report No. 2
Page 9
A.    GP7, GP9, and GP18 LOCOMOTIVES - STANDARD CONFIGURATION
       (NO DYNAMIC BRAKES)

      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

      1.   Four spark arresting exhaust manifolds and inter-
           connecting hardware.

      2.   Two exhaust mufflers.

      3.   Two muffler covers.


      LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED;

      1.   Steel structural shapes used to modify locomotive
           carbody.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED        :  $  4,400.
                     b

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED :  $    300.

TOTAL COST OF LABOR TO MAKE MODIFICATION*          :  $  6,600.

TOTAL EXHAUST MUFFLER RETROFIT COST               :  $ 11,300.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME        :  6 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME            :  4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *              ;  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST              :  $  5,000.

TOTAL COST                                        :  $ 16,300.

*Based on information furnished by Burlington Northern, Milwaukee,
 Missouri Pacific, Penn Central,Rock Island, Southern, and Southern
 Pacific Railroads.
                               E-46

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Cost Study Report No.  2
Page K>
B.    GP7, GP9, and GP18 LOCOMOTIVES EQUIPPED WITH STANDARD DYNAMIC BRAKES


      DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
      RETROFIT EXHAUST SYSTEM:


     ' 1.   DYNAMIC BRAKE HATCH

           The dynamic brake hatch must be removed from the
           locomotive.  The existing exhaust stack openings
           in the hatch must be enlarged and the structure
           modified to allow the muffler to protrude through
           the locomotive roof.
                                               o
      2.   ENGINE EXHAUST MANIFOLDS

           The existing exhaust manifolds are removed from
           the engine and scrapped.  A new set of spark
           arresting manifolds and interconnecting hardware
           is applied to the engine.  The dynamic brake hatch
           is then reapplied and all piping and wiring dis-
           connected to remove the hatch is reconnected.

      3.   MUFFLER

           Two exhaust mufflers are applied to the new engine
           exhaust manifolds through the openings made in the
           dynamic brake hatch.

      4.   MUFFLER COVER

           A roof-mounted cover is applied over each muffler
           to protect the muffler and minimize rain intrusion
           into the locomotive.
                               E-47

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Cost Report Study No. 2
Page 11
B.    GP7, GP9, and GP18 LOCOMOTIVES EQUIPPED WITH STANDARD DYNAMIC  BRAKES


      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

     - 1.   Four spark arresting exhaust manifolds and inter-
           connecting hardware.

      2.   Two exhaust mufflers.

      3.   Two muffler covers.


      LISTING OF MISCELLANEOUS NEW HARDWARE TO BE APPLIED:
      1.   Steel structural shapes used to modify dynamic brake
           hatch.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED        :  $  4,400.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED :  $    300.

TOTAL COST OF LABOR TO MAKE MODIFICATION          :  $  5,800.

TOTAL EXHAUST MUFFLER RETROFIT COST               :  $ 10,500.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME        :  5 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME            :  4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *              :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST              :  $  4,500.

TOTAL COST                                        :  $ 15,000.


*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Penn Central, Rock Island, Southern, and
   Southern Pacific Railroads.
                               E-48

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C.    GP7, GP9, and GP18 LOCOMOTIVES EQUIPPED WITH WINTERIZATION FEATURE


      DESCRIPTION OF MODIFICATIONS NECESSARY TO ACCOMMODATE
      RETROFIT EXHAUST SYSTEM:



      1.   LOCOMOTIVE CARBQDY OR DYNAMIC BRAKE HATCH

           A five inch wide section of the winterization
           opening in the carbody roof or dynamic brake
           hatch must be altered to allow the rear ex-
           haust muffler to be installed.

      2.   WINTERIZATION DUCT

           The winterization duct must be removed from
           the locomotive.  The duct must be altered by
           shortening the length of the duct five inches.
           The duct must then be reapplied to the modified
           carbody roof or dynamic brake hatch.
                                 E49

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C.    GP7, GP9f and GP18 LOCOMOTIVES EQUIPPED WITH WINTERIZATION FEATURE


     ' LISTING OF ADDITIONAL MISCELLANEOUS NEW HARDWARE TO BE APPLIED;

      1.   Steel structural shapes and sheet used to modify carbody
           roof or dynamic brake hatch.

      2.   Steel structural shapes and sheet used to modify
           winterization duct.
TOTAL COST OF ADDITIONAL MISCELLANEOUS NEW
   HARDWARE REQUIRED                              :  $ — 0 -

TOTAL COST OF ADDITIONAL LABOR TO MAKE
   MODIFICATION                                   :  $  1,100.

TOTAL ADDITIONAL EXHAUST MUFFLER RETROFIT COST    :  $  1,100.

ADDITIONAL LOCOMOTIVE OUT OF SERVICE PLANT
   CYCLE TIME                -                     :  1 day

LOCOMOTIVE OUT OF SERVICE COST/DAY *              :  $    500.

TOTAL ADDITIONAL LOCOMOTIVE OUT OF SERVICE COST   :  $    500.

TOTAL ADDITIONAL COST                             :  $  1,600.


*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific,  Penn Central, Rock Island, Southern, and
   Southern Pacific Railroads.

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                                             USG 350-74-17
     GENERAL MOTORS CORPORATION






 LOCOMOTIVE EXHAUST MUFFLER RETROFIT






        COST STUDY REPORT NO. 3






LOCOMOTIVE MODELS SD40, SD40-2, SD45, SD45-2
                              GENERAL MOTORS CORPORATION
                                           DECEMBER 4, 1974






                E-51

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                                                     USG 350-74-17
                                                     Environmental Activities Staff
                                                     General Motors Corporation
                                                     General Motors Technical Center
                                                     Warren, Michigan 48090

                                                     December 5, 1974
 Dr. Alvin F. Meyer, Jr.
 Deputy Assistant Administrator
  for Noise Control Programs
 Environmental  Protection Agency
 Crystal Mall Building -  Room 1115
 1921 Jefferson Davis Highway
 Arlington, Virginia  20460

 Dear Dr. Meyer:

 In response to your request for Locomotive Exhaust Muffler Retrofit-Cost Study,
 we are attaching five (5) copies of Report No. 3.

 This represents the third  installment of a study undertaken by Electro-Motive
 Division to estimate the  cost of engine exhaust system hardware and associated
 locomotive modification deemed necessary to meet the EPA proposed stationary
 locomotive sound  level  limit of 87 dBA at 30 meters at any throttle setting.

 The third report covers GM (EMD) locomotive models SD40-2, SD40, SD45-2,
 and SD45.

 Cost Study Report No. 3 and a series of similar reports to be submitted to EPA will
 ultimately cover 14 General Motors model locomotives representing a total of
 14,789 units delivered by EMD, or 63.4% of the 23,307 total GM locomotives
 in service on Class 1  and 2 Railroads as of January 1, 1974.  The figures stated
 in this report are not  necessarily representative of the amounts that will be sub-
 mitted for other locomotive models  in subsequent  reports.

 If you have any questions regarding this report, please do not hesitate to contact
me.
                                      Sincerely yours,
                                      E. G. Ratering, Dhycfor
                                      Vehicular Noise^CoWrol
Attachments (5)
                                 E-52

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                        GENERAL MOTORS CORPORATION
                    LOCOMOTIVE EXHAUST MUFFLER RETROFIT
                        COST STUDY REPORT NO. 3	



LOCOMOTIVE MODELS SD40-2, SD40, SD45-2, and SD45


This study is undertaken by General Motors in response to a request

by the Environmental Protection Agency (EPA).  Its purpose is to provide

cost information that would aid the EPA in evaluating the expense to the

railroads of retrofitting in-service locomotives with certain exhaust

muffler hardware.  This hardware would permit the locomotive to meet the

EPA proposed stationary locomotive sound level limit of 87 db(A) at any
 •                 »>
throttle setting measured at 30 meters.


During a meeting at the Electro-Motive Division  (EMD) of GM on September

26, 1974, EMD advised EPA representatives that it would undertake a

"paper study" of the nature described above.


EMD also stated that this retrofit work was not being solicited by General

Motors and that EMD locomotive manufacturing facilities were not sufficient

to undertake this retrofit work, primarily due to the volume of new locomo-

tive production.  This work would presumably be done by the railroads

themselves or by others pursuant to contracts with railroads.


This study does not purport to determine the cost for retrofit noise control

treatment necessary to achieve compliance with the EPA proposed locomotive

noise standard of 67 db(A) at 30 meters under'stationary idle conditions.


The EMD study was confined to the locomotive configurations as delivered by

them to the  railroads.  If there has been subsequent modification, alteration.
                                   B-53

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 Cost Study Report No.  3
 Page 2
 addition,  accident,  damage, etc.,  to a specific locomotive which might
 affect the time and/or materials necessary to retrofit that locomotive,
 the estimate for that locomotive would have to be adjusted accordingly.
. The figures established cover only the effort required to apply the
 engine exhaust system hardware modifications.  They do not include any
 allowances for the repair of, or added costs resulting from defects,
 accident damage, etc. which may have to be repaired before retrofit
 can be accomplished, e.g., there is no provision for radiator repair.
 Cleaning and painting are confined to only those areas involved in the
 retrofit modifications.

 The estimated retrofit major new hardware would be developed and sold
 by EMD at EMD Parts Department prices.  The miscellaneous hardware are
 items purchased by EMD from others.  The amounts shown for these two
 classifications of hardware and for EMD labor are based on known, current
 costs at EMD as of October 1974.  None of the amounts contain any pro-
 vision for future economics, and significant adjustments may be necessary
 due to inflation and other considerations.  The amounts were established
 on preliminary design information and sketches for engine exhaust system
 hardware retrofit requirements.

 Labor costs and miscellaneous new hardware do not include profit on the
 amount shown, whereas, any contractor that performed retrofit labor ser-
 vices for the railroads would include a mark-up on this labor and on
 purchased materials.  These figures are also predicated on the assumption
 that sufficient tooling, facilities, and raw materials are available to
 manufacture the required parts, rebuild the engine turbochargers, alter

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Cost study Report NO.
Page 3
the locomotive carbodies and perform other operations necessary to
retrofit the locomotives and that this could all be done under normal
production conditions.
Production line balancing  (the utilization of labor in the most equitable
and efficient manner), an important consideration at EMD, is not included
in this study.  It should be emphasized that the necessary tooling and
facilities, and floor space required to retrofit locomotives, manufacture
additional quantities of certain piece parts, and rebuild of increased
volume of turbochargers do not exist at this time at EMD.  Any estimate
of the cost of the requisite tooling and facilities could only be de-
termined after retrofit cycle times and a schedule by locomotive model
type are established.  Once this information is obtained, the amounts
stated herein would have to be modified to include such additional
tooling and facilities costs since the amounts presented do not contain
allowance for this significant area of cost.      »

The stated costs for  labor are based upon the labor costs, including
burden, presently existing at EMD's LaGrange, Illinois, plant and are
not necessarily representative of such costs at railroad maintenance
installations or at other sources where retrofit work might be done
for the railroads.  Furthermore, other sources may have different job
codes, shift allowances, etc., applicable to their labor force.  There-
fore, the labor costs at such other source? would, of necessity, reflect
other labor-related differences.

This study report No. 3 is the third in a series of several reports which
will be submitted to the EPA to cover ultimately 14 General Motors model
locomotives representing a total of 14,789 units delivered by EMD, or
63.4 percent of the 23,307 total GM locomotives in service on Class 1
                                E-55

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Cost Study Report No. 3
Page 4
and 2 Railroads as of January 1, 1974.  The figures stated in this

third report are not necessarily representative of the amounts that

will be estimated for other locomotive models in subsequent reports.
                               E-56

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Cost Study Report No. 3
Page 5
GENERAL MOTORS LOCOMOTIVE MODEL
:   SD45-2 (Turbocharged,  3,600 HP)
LOCOMOTIVE MODEL PRODUCTION DATES     :  January, 1972 to present
NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY, 1974
   260
PERCENTAGE OP TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY, 1974  :  1.1%
PERCENTAGE OF TOTAL LOCOMOTIVES  IN
FIELD SERVICE AS OF JANUARY,  1974     :   0.9%
MAJOR FEATURES AFFECTING AVAILABLE
	EXHAUST MUFFLER SPACE
A.   Standard Configuration
      (No Dynamic Brakes)
B.   Standard Dynamic Brakes  (Optional)
        PERCENTAGE OF TOTAL
        MODEL PRODUCTION
             0%
           5.0% *
C.   Extended Range Dynamic Brakes  (Optional)

     1.   Welded on hatch                      46.5%

     2.   Bolted on hatch                      48.5%



*   Not considered in study due to  low population in field.
                                E-57

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Cost study Keport wo
Page 6
                          SD45-2  LOCOMOTIVE
     VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
     WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
     A reactive-type exhaust muffler is installed directly on the
     turbocharger exhaust outlet duct.  The muffler is of straight-
     through design -to minimize backpressure imposed on the engine.
     The weight of the muffler is supported solely by the turbocharger
     and, as a result, a special reinforced turbocharger exhaust duct
     is required.  Any electrical cabling must be shielded from the
     exhaust muffler heat radiation.

     The turbocharger is considered an inherently effective spark
     arrester and thereby the turbocharged engine requires no ad-
     ditional provision for spark arrestance hardware.
                                E-58

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C,l   SD^S-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
                        (WELDED ON HATCH)


    DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
    RETROFIT EXHAUST SYSTEM:


    1.    TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.


    2.    EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

          The extended range dynamic brake hatch must be
          removed from the locomotive by burning off the
          welds holding the hatch to the carbody.  The hatch
          structure must be modified to shift the hatch assembly
          21 inches toward the rear of the locomotive.  The
          turbocharger removal opening must be enlarged to ac-
          commodate the muffler.  Insulated panels must be
          installed to protect dynamic brake cabling in the
          vicinity of the exhaust muffler.  Dynamic brake
          cabling, conduit, and control wires, lengthened
          21 inches over the original, must be applied.  The
          extended range dynamic brake hatch is then reapplied
          to the locomotive and cabling and control wires are
          reconnected.


    3.    MUFFLER

          An exhaust muffler is installed on the new turbocharger
          exhaust duct.


    4.    TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.


    5.    OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by the
          exhaust muffler.


                               E-59

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 Cost Study Report No. 3
 Page 8
 C,l  SD45-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
                     (WELDED ON HATCH)
      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

      1.   Turbocharger disassembly, inspection, machining,
           and application of new, reinforced exhaust duct.

      2.   Exhaust muffler.

      3.   Turbocharger removal hatch cover.

      4.   Oil separator ejector.


      LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

      1.   Steel structure shapes  used to enlarge turbocharger
           removal opening.

      2.   Insulated panel heat shields.

      3.   Steel structural shapes and sheet  used to relocate
           dynamic brake hatch structure  21 inches rearward
           on locomotive.

      4.   Dynamic brake cables, conduit,  and control  wires.
                              •»

 TOTAL PRICE  OF MAJOR NEW HARDWARE REQUIRED        ?  $  6,800.

 TOTAL COST OP MISCELLANEOUS  NEW HARDWARE  REQUIRED :  $    600.

 TOTAL COST OF LABOR TO MAKE  MODIFICATION           :  $ 13,500.

 TOTAL EXHAUST MUFFLER RETROFIT COST               :  $ 20,900.

 LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME        :    10 days

 LOCOMOTIVE OUT OF SERVICE TRANSIT TIME             s     4 aays

 LOCOMOTIVE OUT OF SERVICE COST/DAY *       '        :  $    500.

 TOTAL LOCOMOTIVE  OUT OF SERVICE COST               •  $  7,000.

TOTAL COST                                        .  $ 27,900.


*  Based on information furnished by Burlington Northern, Milwaukee
   Missouri Pacific, Penn Central, Rock Island, Southern, and
   Pacific Railroads.

                               E-60

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Cost Study Report No. 3
Page 9
C,2  SM5-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
                      (BOLTED ON HATCH)
                                       \

     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:


     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.


     2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

          The extended range dynamic brake hatch must be
          removed from the locomotive.  The hatch structure
          must be modified to shift the hatch assembly 21
          inches toward the rear of the locomotive.  The
          turbocharger removal opening must be enlarged to
          accommodate the muffler.  Insulated panels must
          be installed to protect dynamic brake cabling in
          the vicinity of the exhaust muffler.  Dynamic brake
          cabling, conduit, and control wires, lengthened 21
          inches over the original, must be applied.  The ex-
          tended range dynamic brake hatch is then reapplied
          to the locomotive and cabling and control wires are
          reconnected.
     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
          TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.
          OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by the
          exhaust muffler.
                               E-61

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Cost Study Report No.  3
Page 10
C,2  SD45-2  LOCOMOTIVE  EQUIPPED  WITH  EXTENDED  RANGE  DYNAMIC BRAKES
                      (BOLTED  ON  HATCH)

     LISTING OF MAJOR NEW  HARDWARE  TO BE APPLIED:
     1.   Turbocharger disassembly,  inspection, machining,
          and application of new, reinforced exhaust duct.

     2.   Exhaust muffler.

     3.   Turbocharger removal hatch cover.

     4.   Oil separator ejector.


     LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;

     1.   Steel structure shapes used to enlarge turbo-
          charger removal opening.
                                                              >
     2.   Insulated panel heat shields.

     3.   Steel structural shapes and sheet used to relocate
          dynamic brake hatch structure 21 inches rearward
          on locomotive.

     4.   Dynamic brake cables, conduit, and control wires.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED         :  $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :  $    600.

TOTAL COST OF LABOR TO MAKE MODIFICATION           :  $ 10,200.

TOTAL EXHAUST MUFFLER RETROFIT COST                :  $ 17,600.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME         :    8 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME             ;    4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY *      '        r  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST               :  $  6,000.

TOTAL COST                                         .  $ 23,600.

*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Penn Central,  Rock Island, Southern, and Southern
   Pacific Railroad.
                                E-62

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Cost Study Report No. 3
Page 11
     GENERAL MOTORS LOCOMOTIVE MODEL       :   SD45  (Turbocharged,  3,600 HP)


     LOCOMOTIVE MODEL PRODUCTION DATES     :   1966  -  1971


     NO. OF LOCOMOTIVES  PRODUCED AS OF
     JANUARY,  1974           '              :   1,267


     PERCENTAGE OF TOTAL GM LOCOMOTIVES
     IN FIELD  SERVICE AS OF JANUARY,  1974  :   5.4%


     PERCENTAGE OF TOTAL LOCOMOTIVES  IN
     FIELD SERV.ICE AS OF JANUARY,  1974     :   4.2%
      MAJOR FEATURES AFFECTING AVAILABLE      PERCENTAGE OF TOTAL
            EXHAUST MUFFLER SPACE             MODEL PRODUCTION
      A.    Standard Configuration                     4.8%
           (No Dynamic Brakes)
      B.    Standard Dynamic Brakes (Optional)        35.3%


      C.    Extended Range Dynamic Brakes (Optional)  59.9%
                                 E-63

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Cost Study Report No. 3
Page 12
                         SDU5  LOCOMOTIVE
     VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
     WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
     A reactive-type exhaust muffler is installed directly on the
     turbocharger exhaust outlet duct.  The muffler is of straight-
     through design to minimize backpressure imposed on the engine.
     The weight of the muffler is supported solely by the turbocharger
     and, as a result, a special reinforced turbocharger exhaust duct
     is required.  Any electrical cabling must be shielded from the
     exhaust muffler heat radiation.

     The turbocharger is considered an inherently effective spark
     arrester and thereby the turbocharged engine requires no ad-
     ditional provision for spark arrestance hardware.
                               E-64

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Cost Study Report No. 3
Page 13
A,  SMS LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new, reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   ENGINE MAINTENANCE HATCH

          The engine maintenance hatch must be removed from
          locomotive.  The turbocharger removal opening in
          the hatch must be enlarged to accommodate the ex-
          haust muffler.  The hatch is then reapplied to the
          locomotive.
      3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.


      4.   TURBOCHARGER REMOVAL HATCH COVER
          A new,  larger  hatch cover must be applied above  the
          exhaust muffler  to cover the enlarged turbocharger
          removal opening  in the engine maintenance hatch.
          OIL SEPARATOR EJECTOR

          An ejector must be  added  to  the  oil  separator  to
          overcome  the  additional backpressure created by
          the exhaust muffler.
                                Er65

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 Cost Study Report No. 3
 Page 14
 A,   SMS LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC  BRAKES)


      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


      1.    Turbocharger disassembly, inspection,  machining,
           and application of new,  reinforced exhaust duct.

      2.    Exhaust muffler.

      3.    Turbocharger removal hatch cover.

      4.    Oil separator ejector.
     LISTING  OF MISCELLANEOUS NEW HARDWARE REQUIRED;

     1.
Steel structural shapes used to enlarge
turbocharger removal opening.
TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED

TOTAL COST OF LABOR TO MAKE MODIFICATION '

TOTAL EXHAUST MUFFLER RETROFIT COST


LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME

LOCOMOTIVE OUT OF SERVICE COST/DAY **

TOTAL LOCOMOTIVE OUT OF SERVICE COST.

TOTAL COST
                                            $   6,800.

                                            $     300.

                                            $   7,100.

                                            $ 14,200.

                                             5 days

                                             4 days

                                            $     500.

                                            $  4,500.

                                         :   $ 18,700.
*   Modification considered to be the same for costing as GP40-2
    locomotive - Standard Configuration (no dynamic brakes).

**  S?86* °? information furnished by Burlington Northern, Milwaukee,
    Missouri Pacific, Penn Central, Rock Island, Southern, and
    Southern Pacific Railroads.
                               E-66

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Cost Study Report No. 3
Page 15
B,   SD45 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.


     2.   DYNAMIC BRAKE HATCH

          The dynamic brake hatch must be removed from the
          locomotive.  The hatch structure must be modified
          to shift the hatch assembly 21 inches toward the
          rear of the locomotive.  The turbocharger removal
          opening must be enlarged to accommodate the muffler.
          Insulated panels must be installed to protect dy-
          namic brake cabling in the vicinity of the exhaust
          muffler.  Dynamic brake cabling and conduit, len-
          gthened 21 inches over the original, must be applied.
          The dynamic brake hatch is then reapplied to the loco-
          motive and cabling and control wires are reconnected.


     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.


     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                               E-67

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Cost Study  Report No.  3
Page 16
B,   SD*i5   LOCOMOTIVE' EQUIPPED  WITH  STANDARD DYNAMIC" BRAKES


     LISTING  OF MAJOR NEW HARDWARE TO BE APPLIED;

     1.    Turbocharger disassembly,  inspection, machining,
           and application of  new,  reinforced exhaust duct.

     2.    Exhaust muffler.

     3.    Turbocharger removal  hatch cover.

     4.    Oil separator ejector.


     LISTING  OF MISCELLANEOUS NEW  HARDWARE REQUIRED;

     1.    Steel structure shapes used to enlarge turbo-
           charger removal opening.

     2.    Insulated panel heat  shields.
                      v
     3.    Steel structural shapes  and sheet used to  relocate
           dynamic brake hatch structure  21 inches rearward
           on  locomotives.

     4.    Dynamic brake cables.and conduit.


TOTAL PRICE OP  MAJOR  NEW HARDWARE  REQUIRED          :  $  6,800.

TOTAL COST OP MISCELLANEOUS NEW HARDWARE REQUIRED   :  $    800'.

TOTAL COST OP LABOR TO MAKE MODIFICATION           :  $ 11,900.

TOTAL EXHAUST MUFFLER RETROFIT  COST  •               s  $ 19,500

LOCOMOTIVE OUT  OF SERVICE PLANT CYCLE TIME          :    8 days

LOCOMOTIVE OUT  OF SERVICE TRANSIT  TIME              :    4 days

LOCOMOTIVE OUT  OF SERVICE COST/DAY *                s  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                :  $  6,000.

TOTAL COST                                         ,  $ 25,500.

*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Penn Central, Rock  Island, Southern, and Southern
   Pacific Railroads.
                                E-68

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Cost Study Report No. 3
Page 17
C,  SMS LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.             •


     2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

          The extended range dynamic brake hatch must be
          removed from the locomotive.  The hatch structure
          must be modified to shift the hatch assembly 21
          inches toward the rear of the locomotive.  The
          turbocharger removal opening must be enlarged to
          accommodate the muffler.  Insulated panels must be
          installed to protect dynamic brake cabling in the
          vicinity of the exhaust muffler.  Dynamic brake
          cabling, conduit, and control wires, lengthened
          21 inches over the original, must be applied.
          The extended range dynamic brake hatch is then
          reapplied to the locomotive and cabling and control
          wires are reconnected.
     3.   MUFFLER
          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                               E-69

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Cost Study Report No.  3
Page 18
C,   SMS "LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     LISTING OF MAJOR NEW HARDWARETO BE APPLIED!
     I.
     Turbocharger disassembly, inspection, machining,
     and application of new, reinforced exhaust duct.
2.   Exhaust muffler.
3.   Turbocharger removal hatch cover.
4.   Oil separator ejector.

LISTIMG OF MISCELLANEOUS NEW HARDWARE REQUIRED:
1.
          Steel structure shapes used to enlarge turbo-
          charger removal opening.
     2.   Insulated panel heat shields.
     3.   Steel structural shapes and sheet used to relocate
          dynamic brake hatch structure 21 inches rearward
          on locomotive.
     4,   Dynamic brake cables, conduit, and control wires.
TOTAL PRICE OP MAJOR NEW HARDWARE REQUIRED         :
TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED
TOTAL COST OF LABOR TO MAKE MODIFICATION
TOTAL EXHAUST MUFFLER RETROFIT COST
LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME
LOCOMOTIVE OUT OF SERVICE TRANSIT TIME
LOCOMOTIVE OUT OF SERVICE COST/DAY *
TOTAL LOCOMOTIVE OUT OF SERVICE COST
TOTAL COST
                                                 $  6,800.
                                                 $    900.
                                                 $ 11,400.
                                                 $ 19,200.
                                                   8 days
                                                   4 days
                                                 $    500.
                                                 $  6,000.
                                                 $ 25,200.
*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Penn Central, Rock Island, Southern, and
   Southern Pacific Railroads.
                                E-70

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Cost Study Report No. 3
Page 19
GENERAL- MOTORS LOCOMOTIVE MODEL
:    SD40-2  (Turbocharged,  3,000 HP)
LOCOMOTIVE MODEL PRODUCTION DATES
    January, 1972 to present
NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY, 1974
    427
PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY,  1974   :   1.8%
PERCENTAGE OF TOTAL LOCOMOTIVES  IN
FIELD SERVICE AS OF JANUARY, 1974
    1.4%
MAJOR FEATURES AFFECTING AVAILABLE
      EXHAUST MUFFLER  SPACE
       PERCENTAGE OF TOTAL
       MODEL PRODUCTION
A.    Standard  Configuration
      (No Dynamic  Brakes)
            19.1%
B.    Standard  Dynamic  Brakes  (Optional)            38.0%
C.   Extended  Range  Dynamic  Brakes  (Optional)      42.9%
                                E-71

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Cost Study Report No. 3

Page 20
                         SD4Q-2 LOCOMOTIVE
VERBAL DESCRIPTION OF MUFFLER SYSTEM, INCLUDING SPARK ARRESTING
WHERE NECESSARY; TAKING INTO ACCOUNT OPTIONAL FEATURES:
A reactive-type exhaust muffler is installed directly on the


turbocharger exhaust outlet duct.  The muffler is of straight-


through design to minimize backpressure imposed on the engine.


The weight of the muffler is supported solely by the turbocharger


and, as a result, a special reinforced turbocharger exhaust duct



is required.  Any electrical cabling must be shielded from the


exhaust muffler heat radiation.


                              -V



The turbocharger is considered an inherently effective spark ar-


rester and thereby the turbocharged engine requires no additional



provision for spark arrestance hardware.
                                E-72

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Cost Study Report No. 3
Page 21
A,   SD40-2 LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
     DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new, reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   ENGINE MAINTENANCE HATCH

          The engine maintenance hatch must be removed from
          locomotive.  The turbocharger removal opening in
          the hatch must be enlarged to accommodate the ex-
          haust muffler.  The hatch is then reapplied to the
          locomotive.
     3.   MUFFLER
          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
                              .j

     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the engine maintenance hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator  to
          overcome the additional backpressure created by
          the exhaust muffler.
                                E-73

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  Cost Study Report No.  3
  Page 22
  A,    SMO-2  LOCOMOTIVE - STANDARD  CONFIGURATION  (NO  DYNAMIC  BRAKES)


      LISTING  OF  MAJOR NEW HARDWARE  TO BE APPLIED;


      1.    Turbocharger disassembly,  inspection, machining,
           and application of  new, reinforced exhaust  duct.

      2.    Exhaust muffler.

      3'.    Turbocharger removal hatch cover.

      4.    Oil separator ejector.


      LISTING  OF  MISCELLANEOUS NEW HARDWARE REQUIRED;

      1.    Steel  structural shapes used to enlarge
           turbocharger removal opening.



TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED          :  $  6,800.

TOTAL COST OP MISCELLANEOUS NEW HARDWARE REQUIRED   :  $    300.

TOTAL COST OP LABOR TO MAKE MODIFICATION            :  $  7,100.

TOTAL EXHAUST MUFFLER  RETROFIT COST                 i  $ 14,200.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME          ;    5 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME              :    4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY **               :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                :  $  4,500.

TOTAL COST                                          .  $ 18,700.


*   Modification considered to be the same for costing as GP40-2
    locomotive - Standard Configuration (no dynamic brakes).

**  Based on information furnished by Burlington Northern,  Milwaukee,
    Missouri Pacific,  Penn Central,  Rock Island, Southern,  and
    Southern Pacific Railroads.
                               E-74

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Cost Study Report No. 3
Page 23
B,   SD40-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
     DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGERS

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   DYNAMIC BRAKE HATCH

          The dynamic brake hatch must be removed from the
          locomotive.  The hatch structure must be modified
          to shift the hatch assembly nine inches toward the
          rear of the locomotive.  The turbocharger removal
          opening must be enlarged to accommodate the muffler.
          Insulated panels must be installed to protect dynamic
          brake cabling in the vicinity of the exhaust muffler.
          Dynamic brake cabling and conduit, lengthened nine
          inches over the original, must be applied.  The
          dynamic brake hatch is then reapplied to the loco-
          motive and cabling is reconnected.


     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.


     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new,larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                                E-75.

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 Cost Study Report No. 3
 Page 24
 B,  '  SMO-2 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES


      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;

      1.    Turbocharger disassembly, inspection,  machining,
           and application of new,  reinforced exhaust duct.

      2.    Exhaust muffler.

      3.    Turbocharger removal hatch cover.

      4.    Oil separator ejector.


      LISTING OF MISCELLANEOUS NEW  HARDWARE REQUIRED;

      1.    Steel structure shapes used to enlarge turbo-
           charger removal opening.

      2.    Insulated  panel heat shields.

      3.    Steel structural shapes  and sheet  used to relocate
           dynamic brake hatch structure  nine inches rearward
           on locomotive.
      4.    Dynamic brake cables and conduit.


TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED

TOTAL COST OF LABOR TO MAKE MODIFICATION

TOTAL EXHAUST MUFFLER RETROFIT COST

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME

LOCOMOTIVE OUT OF SERVICE COST/DAY *

TOTAL LOCOMOTIVE OUT OF SERVICE COST
                                                      $  6,800.

                                                      $    600.

                                                      $ 10,900.

                                                      $ 18,300.

                                                        8 days

                                                        4 days

                                                      $    500.

                                                      $  6,000.

      COST                                         :  $ 24,300.


*  Based on information furnished by Burlington Northern,  Milwaukee,
   Missouri Pacific, Penn Central, Rock Island, Southern,  and
   Southern Pacific Railroads.
                               E-76

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Cost Study Report No. 3
Page 25
C, •  SMO-2 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

          The extended range dynamic brake hatch must be
          removed from the locomotive.  The hatch structure
          must be modified to shift the hatch assembly 12
          inches toward the rear of the locomotive.  The
          turbocharger removal opening must be enlarged to
          accommodate the muffler.  Insulated panels must
          be installed to protect dynamic brake cabling in
          the vicinity of the exhaust muffler.  Dynamic
          brake cabling, conduit, and control wires, len-
          gthened 12 inches over the original, must be
          applied.  The extended range dynamic brake hatch
          is then reapplied to the locomotive and cabling
          and control wires are reconnected.
     3.   MUFFLER

          An exhaust muffler  is  installed on  the new turbo-
          charger  exhaust duct.
     4.    TURBOCHARGER  REMOVAL  HATCH COVER

           A new,  larger hatch cover must be applied  above  the
           exhaust muffler  to cover the enlarged  turbocharger
           removal opening  in the dynamic brake hatch.
           OIL SEPARATOR EJECTOR

           An  ejector must  be  added  to  the oil  separator  to
           overcome  the  additional backpressure created by
           the exhaust muffler.
                                  EX77

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  Cost Study Report No.  3
  Page 26
  C,    SD40-2  LOCOMOTIVE  EQUIPPED  WITH  EXTENDED  RANGE  DYNAMIC  BRAKES
     LISTING  OF MAJOR NEW HARDWARE TO BE APPLIED;


     1.    Turbocharger disassembly,  inspection, machining,
           and application of  new,  reinforced  exhaust  duct.

     2.    Exhaust muffler.

     3.    Turbocharger removal  hatch cover.

     4.    Oil separator  ejector.


     LISTING  OF. MISCELLANEOUS NEW  HARDWARE REQUIRED;


     1.    Steel structure shapes used to enlatge turbo-
           charger removal opening.

     2.    Insulated panel heat  shields.

     3.    Steel structural shapes  and sheet used to relocate
           dynamic brake  hatch structure  12 inches rearward
           on  locomotive.

     4.    Dynamic brake  cables, conduit, and  control  wires.

TOTAL PRICE OF MAJOR NEW HARDWARE  REQUIRED         :  $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED  :  $    500.

TOTAL COST OF LABOR TO MAKE MODIFICATION           :  $ 11,400.

TOTAL EXHAUST MUFFLER RETROFIT COST                :  $ 18,700.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME         :    9 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME             :    4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY. *      '        :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST               :  $  6,500.

TOTAL COST                                         .  $ 25,200.

*  Based on information furnished by Burlington Northern, Milwaukee,
   Missouri Pacific, Penn Central,  Rock Island, Southern, and
   Southern Pacific Railroads.
                                E-78

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Cost Study Report No. 3
Page 27
GENERAL MOTORS LOCOMOTIVE MODEL      j  SP4Q .(Turbocharged, 3,000 HP)


LOCOMOTIVE MODEL PRODUCTION DATES    :  1966 - 1971


NO. OF LOCOMOTIVES PRODUCED AS OF
JANUARY, 1974               .         :  877


PERCENTAGE OF TOTAL GM LOCOMOTIVES
IN FIELD SERVICE AS OF JANUARY, 1974 :  3.8%


PERCENTAGE OF TOTAL LOCOMOTIVES IN
FIELD SERVICE AS OF JANUARY, 1974    :  2.9%
MAJOR FEATURES AFFECTING AVAILABLE     '      PERCENTAGE OF TOTAL
      EXHAUST MUFFLER SPACE                  MODEL PRODUCTION
A.   Standard Configuration                       10.2%
      (No Dynamic Brakes)


B.   Standard Dynamic Brakes  (Optional)           23.5%


C.   Extended Range Dynamic Brakes  (Optional)     66.3%,


D.   Winterization  (Optional)                      1.1%  *


* Not considered in this study due  to low population  in  field.
                                E-79

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Cost  Study  Report  No.  3
Page  28
                        SD4Q LOCOMOTIVE
VERBAL DESCRIPTION OF MUFFLER SYSTEM,  INCLUDING SPARK ARRESTING
WHERE NECESSARY, TAKING  INTO ACCOUNT OPTIONAL FEATURES:
A reactive-type exhaust muffler is installed directly on the
turbocharger exhaust outlet duct.  The muffler is of straight-
through design to minimize backpressure imposed on the engine.
The weight of the muffler is supported solely 'by the turbocharger
and, as a result, a special reinforced turbocharger exhaust duct
is required.  Any electrical cabling must be shielded from the
exhaust muffler heat radiation.

The turbocharger is considered an inherently effective spark
arrester and thereby the turbocharged engine requires no ad-
ditional provision for spark arrestance hardware.
                               E-80

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  Cost Study Report No.  3
 Page 29
A,  SMQ LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new, reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   ENGINE MAINTENANCE HATCH

          The engine maintenance hatch must be removed from
          locomotive.  The turbocharger removal opening in
          the hatch must be enlarged to accommodate the ex-
          haust muffler.  The hatch is then reapplied to the
          locomotive.
     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
          TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the engine maintenance hatch.
     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                                E-81

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  Cost  Study  Report  No.  3
  Page  30
 A,   SD40  LOCOMOTIVE  -  STANDARD CONFIGURATION  (NO DYNAMIC BRAKES)
     LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


     1.    Turbocharger disassembly, inspection, machining,
           and  application of new, reinforced exhaust duct.

     2.    Exhaust muffler.

     3.    Turbocharger removal hatch cover.

     4.    Oil  separator ejector.


     LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;


     1.    Steel structural shapes used to enlarge
           turbocharger removal opening.


TOTAL PRICE OP MAJOR NEW  HARDWARE REQUIRED          :  $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE REQUIRED   :  $    300.

TOTAL COST OF LABOR TO MAKE MODIFICATION            :  $  7,100.

TOTAL EXHAUST MUFFLER RETROFIT COST                 ;  $ 14,200.

LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME          :    5 days

LOCOMOTIVE OUT OF SERVICE TRANSIT TIME              :    4 days

LOCOMOTIVE OUT OF SERVICE COST/DAY **               :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                :  $  4,500.

TOTAL COST                                          :  $ 18,700.

*   Modification considered to be the same .for costing as GP40-2
    locomotive - Standard Configuration (No Dynamic Brakes).

**  Based on information furnished by Burlington Northern,  Milwaukee.
    Missouri Pacific,  Penn Central,  Rock Island, Southern,  and
    Southern Pacific Railroads.
                                E-82

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Cost Study Report No. 3
Page 31
B,   SD40 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.


     2.   DYNAMIC BRAKE HATCH

          The dynamic brake hatch must be removed from the
          locomotive.  The hatch structure must be modified
          to shift the hatch assembly nine inches toward the
          rear of the locomotive.  The turbocharger removal
          opening must be enlarged to accommodate the muffler.
          Insulated panels must be installed to protect dy-
          namic brake cabling in the vicinity of the exhaust
          muffler.  Dynamic brake cabling" and conduit, len-
          gthened nine inches over the original,must be applied.
          The dynamic brake hatch is then reapplied to the loco-
          motive and cabling is reconnected.
     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover the enlarged turbocharger
          removal opening in the dynamic brake hatch.
          OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                                E-83

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  Cost Study Report No. 3
  Page 32
  B,   SMO LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED:


      1.    Turbocharger disassembly, inspection,  machining,
           and application of new,  reinforced exhaust duct.

      2.    Exhaust muffler.

      3.    Turbocharger removal hatch cover.

      4.    Oil separator ejector.


      LISTING OF MISCELLANEOUS NEW  HARDWARE REQUIRED;

      1.    Steel structure shapes used to enlarge turbo-
           charger removal opening.

      2.    Insulated  panel heat shields.

      3.    Steel structural shapes  and sheet  used to relocate
           dynamic brake hatch structure  nine inches rearward
           on locomotive.

      4.    Dynamic brake cables and  conduit.


TOTAL PRICE  OF  MAJOR NEW HARDWARE REQUIRED         :  $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE  REQUIRED  :  $    900.

TOTAL COST OF LABOR  TO  MAKE MODIFICATION           :  $ 12,500.

TOTAL EXHAUST MUFFLER RETROFIT COST                :  $ 20,200.

LOCOMOTIVE OUT  OF  SERVICE  PLANT CYCLE TIME         :    8 days

LOCOMOTIVE OUT  OF  SERVICE  TRANSIT TIME             :    4 days

LOCOMOTIVE OUT  OF  SERVICE  COST/DAY *       .        :  $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST               :  $  6,000.

TOTAL COST                                         :   $ 26,200.


*  5*sed °? information furnished by Burlington Northern, Milwaukee
   Missouri Pacific,  Penn Central,  Rock Island, Southern, and Southern
   Pacific Railroads.
                                 E-84

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Cost Study Report No. 3
Page 33
C,  SMO LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
     DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO
     ACCOMMODATE RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine,
          disassembled, inspected, and a new reinforced
          exhaust duct applied.  The turbocharger is then
          tested and reapplied to the engine.
     2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

          The extended range dynamic brake hatch must be
          removed from the locomotive;  The hatch structure
          must be modified to. shift the hatch assembly nine
          inches toward the rear of the locomotive.  The
          turbocharger removal opening must be enlarged to
          accommodate the muffler.  Insulated panels must be
          installed to protect dynamic brake cabling in the
          vicinity of the exhaust muffler.  Dynamic brake
          cabling, conduit, and control wires, lengthened
          nine inches over the original, must be applied.
          The extended range dynamic brake hatch is then
          reapplied to the locomotive and cabling and control
          wires are reconnected.
     3.   MUFFLER

          An exhaust muffler is installed on the new turbo-
          charger exhaust duct.
     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the
          exhaust muffler to cover, the enlarged turbocharger
          removal opening in the dynamic brake hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to
          overcome the additional backpressure created by
          the exhaust muffler.
                                EdB.5

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 Cost Study Report No.  3
 Page 34
 C,    SWO LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
      LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


      1.    Turbocharger disassembly, inspection,  machining,
           and application of  new,  reinforced  exhaust duct.

      2.    Exhaust muffler.

      3.    Turbocharger removal  hatch cover.

      4.    Oil separator ejector.


      LISTING OF MISCELLANEOUS NEW  HARDWARE. REQUIRED;


      1.    Steel structure shapes used to  enlarge turbo-
           charger removal opening.

      2.    Insulated panel heat  shields.

      3.    Steel structural shapes  and sheet used to relocate
           dynamic brake hatch structure nine  inches  rearward
           on locomotive.

      4.    Dynamic brake cables, conduit,  and control  wires.


TOTAL PRICE  OF  MAJOR NEW HARDWARE  REQUIRED         :  $  6,800.

TOTAL COST OF MISCELLANEOUS NEW HARDWARE  REQUIRED  :  $    900.

TOTAL COST OP LABOR TO  MAKE MODIFICATION           :  $ 13,300.

TOTAL EXHAUST MUFFLER RETROFIT COST                :  $ 21,000.

LOCOMOTIVE OUT  OF  SERVICE PLANT CYCLE TIME         :    8 days

LOCOMOTIVE OUT  OF  SERVICE TRANSIT TIME             :    4 days

LOCOMOTIVE OUT  OF  SERVICE COST/DAY *               -  $    5QO.

TOTAL LOCOMOTIVE OUT OF SERVICE COST               :  $  6,000.

TOTAL COST                                         .  $ 27,000.

*  Based on information furnished by Burlington Northern, Milwaukee
   Missouri Pacific, Penn Central,  Rock Island,  Southern, and
   Southern Pacific Railroads.
                                E-86

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                                            USQ 350-74-18
    GENERAL MOTORS CORPORATION






LOCOMOTIVE EXHAUST MUFFLER RETROFIT






       COST STUDY REPORT NO. 4






  LOCOMOTIVE MODELS GP30, QP35, SD36
                            GENERAL MOTORS CORPORATION
                                        DECEMBER 11, 1074





              E-87

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                                                     USG 350-74-18
                                                       *
                                                     Environmental Activities Stan
                                                     General Motors Corporation
                                                     General Motors Technical Center
                                                     Warren. Michigan 48090

                                                     December IT, 1974
 Dr. Alvln F. Meyer, Jr.
 Deputy Assistant Administrator
  for Noise Control Programs
 Environmental Protection Agency
 Crystal Mall Building - Room 1115
 1921 Jefferson Davis Highway
 Arlington, Virginia  20460

 Dear Dr. Meyer:

 In response to your request for Locomotive Exhaust Muffler Retrofit-Cost Study,
 we are attaching five (5) copies of Report No. 4. Also attached is one (1) copy
 of General Motors Corporation Locomotive Exhaust Muffler .Retrofit Application
 Illustrations.

 This represents the fourth and final installment of a study undertaken by Electro-
 Motive Division to estimate the cost of engine exhaust system hardware and associated
 locomotive modification deemed necessary to meet the EPA proposed stationary
 locomotive sound level  limit of 87 dBA at 30 meters at any throttle setting.

 The fourth report covers GM (EMD) locomotive models GP30, GP35, and SD35.

 Cost Study Report No. 4 and a series of similar reports submitted to EPA cover 14
 General Motors model locomotives representing a total of 14,789 units delivered
 by EMD, or 63.4% of the 23,307  total GM locomotives in service on Class 1 and 2
 Railroads as of January 1, 1974.  The figures stated in this final report are not
 necessarily representative of the amounts that  have been submitted for other locomotive
 models in previous reports.

 If you  have any questions regarding this report, please do not hesitate to contact me.

                                          SincerelyVours,
                                                 Ratering, JM/ector
                                          Vehicular Noise Control
fr
Attachments (6)
                                    E-88,

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                        GENERAL MOTORS  CORPORATION

                     LOCOMOTIVE EXHAUST MUFFLER RETROFIT

                         COST STUDY REPORT NO.  4
LOCOMOTIVE MODELS GP30,  GP35,  and SD35
 This  study is undertaken by General Motors in response to a request  by


 the Environmental Protection Agency  (EPA) to provide cost information that


 would aid the EPA in evaluating the expense to the railroads of  retrofitting


 in-service locomotives with exhaust muffler hardware.  This hardware would


 permit the locomotive to meet the EPA proposed stationary locomotive sound
                    /»

 level limit of  87 dB(A) at any throttle setting measured at 30 meters.


                                                                   j
 During a meeting at the Electro-Motive Division  (EMD) of GM on September 26,


 1974, EMD advised EPA representatives that it would undertake a  "paper  study"


 of the nature described above.





 EMD also stated that this retrofit work was not being solicited by General


 Motors and that EMD locomotive manufacturing facilities were not sufficient


 to undertake this retrofit work,  primarily due to the volume of new  locomo-


 tive  production.  This work would presumably be done by the railroads them-


 selves or by others pursuant to contracts with railroads.




 No attempt has been made to determine the cost for retrofit noise control


 treatment necessary to achieve compliance with the EPA proposed locomotive


 noise standard of 67 dB(A) at 30 meters under stationary idle conditions.




 This  study was confined to the locomotive configurations as delivered to


 the railroads by EMD.  If there has been subsequent modification, alteration,
                                     E-89

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 Cost  Study Report No. 4
 Page  2

                                m
 addition, accident, damage, etc., to a specific locomotive which might

 affect the time and/or materials necessary to retrofit that locomotive,

 the estimate for that locomotive would have to be adjusted accordingly.

 The figures established cover only the effort required to apply the

 engine exhaust system hardware modifications.  They do not include any

 allowances for the repair of, or added costs resulting from defects,

 accident damage, etc. which may have to be repaired before retrofit Can

 be accomplished, e.g., there is no provision for radiator repair.  Cleaning

 and painting are confined to only those areas involved in the retrofit

 modifications.                                                             "


 The estimated retrofit major new hardware would be developed and sold by

 EMD at EMD Parts Department prices.  The'miscellaneous hardware are items

 purchased by EMD from others.  The amounts shown for these two classifica-

 tions of hardware and for EMD labor are based on known, current costs at

 EMD as of October 1974.  None of the amounts contain any provision for

 future economics, and significant adjustments may be necessary due to in-

 flation and other considerations.   The amounts were established on prelim-

 inary design information and sketches for engine exhaust system hardware

 retrofit requirements.


 Labor costs and miscellaneous new hardware do not include profit on the

 amount shown, whereas, any contractor that performed retrofit labor ser-

 vices for the railroads would include a mark-up on this labor and on pur-

 chased materials.  These prices are also predicated on the assumption that

 sufficient tooling, facilities, and raw materials are available to manufacture

 the required parts, rebuild the engine turbochargers, alter the locomotive

carbodies and perform other operations necessary to retrofit the locomotives

and that this could all be done under normal production conditions.

-------
Cost Study Report No. 4
Page 3
Production line balancing (the utilization of labor in the most equitable

and efficient manner), an important consideration at EMD, is not included

in this study.  It should be emphasized that the necessary tooling and

facilities, and floor space required to retrofit locomotives, manufacture

additional quantities of certain piece parts, and rebuild of increased

volume of ,turbochargers do not exist at this time at EMD.  Any estimate

of the cost of the requisite tooling and facilities could only be deter-

mined after retrofit cycle times and a schedule by locomotive model type

are established.  Once this information is obtained, the amounts stated

herein would have to be modified to include such additional tooling and

facilities costs since the amounts presented do not contain allowance for

this significant,area of cost.           •


The stated costs for labor are based upon the.labor costs, including burden,

presently existing at EMD's LaGrange, Illinois, plant and are not neces-
                                                                         •
sarily representative of such costs at railroad maintenance installations

or at other sources where retrofit work might be done for the railroads.

Furthermore, other sources may have different job codes, shift allowances,

etc., applicable to their labor force.  Therefore, the labor costs at such

other sources would, of necessity, reflect other labor-related differences.


This study report No. 4 is the last in a series of four reports which have

been submitted to the EPA to cover ultimately 14 General Motors model

locomotives representing a total of 14,789 units delivered by EMD, or

63.4 percent of the 23,307 total GM locomotives in service on Class 1 and

2 Railroads as of January 1, 1974.  The figures stated in this final report

are not necessarily representative of the amounts that have been estimated

for other locomotive models in previous reports.
                                     E-91

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Cost Study Report No. 4
Page 4
At the end of this report is a locomotive exhaust muffler retrofit cost
study summary table which is included along with observations made as a
result of this study and related Electro-Motive experience.
                                    E-92

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Cost Study Report No. 4
Page 5
    GENERAL MOTORS LOCOMOTIVE MODEL
:   GP30 (Turbocharged, 2,250 HP)
    LOCOMOTIVE MODEL PRODUCTION DATES
:   1962  - 1963
    NO. OF LOCOMOTIVES PRODUCED AS OP
    JANUARY; 1974                        :  946
    PERCENTAGE OF TOTAL GM LOCOMOTIVES
    IN FIELD SERVICE AS OF JANUARY, 1974 :  4.1%
    PERCENTAGE OF TOTAL LOCOMOTIVES IN
    FIELD SERVICE AS OF JANUARY, 1974    :  3.2%
    MAJOR FEATURES AFFECTING AVAILABLE
          EXHAUST MUFFLER SPACE
        PERCENTAGE OF TOTAL
        MODEL PRODUCTION
    A.   Standard Configuration
         (No Dynamic Brakes)
               0.0%
    B.   Standard Dynamic Brakes (Optional)
    C.   Extended Range Dynamic Brakes (Optional)
              87.8%


              12.2%
                                    B-93

-------
»ost  Study  Report  No.  4
?age  6
                             GP30   LOCOMOTIVE
    VERBAL DESCRIPTION  OF MUFFLER  SYSTEM,  INCLUDING  SPARK ARRESTING
    WHERE NECESSARY,  TAKING  INTO ACCOUNT OPTIONAL FEATURES:
    A reactive  type  exhaust muffler  is  installed directly  on  the
    turbocharger  exhaust outlet duct.   The muffler  is of straight-
    through design to minimize backpressure  imposed on  the engine.
                                           .
    The weight  of the muffler is supported solely by the turbocharger
    and,  as a result, a special reinforced turbocharger exhaust  duct
    is required.  Any electrical cabling must be shielded  from the
    exhaust muffler  heat radiation.  -

    The turbocharger is considered an inherently effective spark ar-
    rester  and  thereby the turbocharged engine requires no additional
    provision for spark arrestance hardware.
                                      E-94

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Cost Study Report No.  4
Page 7
     B,   GP30 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
     DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine, dis-
          assembled, inspected, and a new reinforced exhaust
          duct applied.  The turbocharger is then tested and
          reapplied to the engine.


     2.   DYNAMIC BRAKE HATCH

          The locomotive carbody, containing the dynamic brake
          hatch (welded on), must be removed from the locomotive.
          The turbocharger removal opening in the carbody must be
          enlarged to accommodate the exhaust muffler.  Dynamic
          brake cabling must be removed and rerouted to provide
          clearance around the muffler.  Heat shields and insulated
          panels must be installed to protect dynamic brake cabling
          in the vicinity of the muffler.  The locomotive carbody is
          then reapplied to the locomotive.


     3.   MUFFLER

          An exhaust muffler is installed on the new turbocharger
          exhaust duct.


     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above the exhaust
          muffler to cover the enlarged turbocharger removal opening in
          the dynamic brake hatch.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator to overcome
          the additional backpressure created by the exhaust muffler.
                                       E-95

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Cost Study Report No.  4
Page 8
    B,    GP30 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    L'ISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


    1.   Turbocharger disassembly, inspection, machining/ and
         application of new, reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.


    LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;


    1.   Steel structure shapes  used to enlarge turbocharger
         removal opening.

    2.   Insulated panel heat shields.


    TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED         :  $  6,700.
                                                        *

    TOTAL COST OP MISCELLANEOUS  NEW HARDWARE REQUIRED  :  $    300.

    TOTAL COST OP LABOR TO MAKE  MODIFICATION           :  $  9,200.

    TOTAL EXHAUST MUFFLER RETROFIT COST                :  $ 16,200.

    LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME         :    7 days

    LOCOMOTIVE OUT OF SERVICE TRANSIT TIME             :    4 days

    LOCOMOTIVE OUT OF SERVICE COST/DAY *               :  $    500.

    TOTAL LOCOMOTIVE OUT OF SERVICE COST               :  $  5,500.

    TOTAL COST                                         :  $ 21,700.


    *  Based on information furnished by Burlington Northern, Milwaukee,
       Missouri Pacific, Penn Central,  Rock Island, Southern, and Southern
       Pacific Railroads.
                                     E-96

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Cost Study Report No.  4
Page 9
   C,   GP30 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
   DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
   RETROFIT EXHAUST SYSTEM:
   1.   TURBOCHARGER

        The turbocharger must be removed from engine, disassembled,
        inspected, and a new reinforced exhaust duct applied.  The
        turbocharger is then tested and reapplied to the engine.


   2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

        The locomotive carbody, containing tho dynamic brake hatch
        (welded on), must be removed from the locomotive.  The
        extended range dynamic brake contactors must be relocated
        within the dynamic brake hatch.  This involves structural
        modifications and-recabling.  The turbocharger removal
        opening must be enlarged to accommodate the muffler.
        Insulated panels must be installed to protect dynamic
        brake cabling in the vicinity of the exhaust muffler.
        The locomotive carbody is then reapplied to the locomotive.
       •

   3.   MUFFLER

        An exhaust muffler is installed on the new turbocharger
        exhaust duct.


   4.   TURBOCHARGER REMOVAL HATCH COVER

        A new, larger hatch cover must be applied above the exhaust
        muffler to cover the enlarged turbocharger removal opening
        in the dynamic brake hatch.


   5.   OIL SEPARATOR EJECTOR

        An ejector must be added to the oil separator to overcome
        the additional backpressure created by the exhaust muffler.
                                  E-97

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Cost Study Report No.  4
Page 10
    C,    GP30 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED:
    1.    Turbocharger  disassembly,  inspection,  machining, and
         application of  new,  reinforced exhaust duct.

    2.    Exhaust muffler.
                                          i
    3.    Turbocharger  removal hatch cover.

    4.    Oil  separator ejector.


    LISTING OF  MISCELLANEOUS  NEW HARDWARE  REQUIRED;  ,


    1.    Steel  structure shapes  used to enlarge turbocharger
         removal opening.                 ,

    2.    Insulated panel heat shields.

    3.    Steel  structural shapes and sheet used to relocate
         dynamic brake contactors.

    4.    Dynamic brake cables, conduit,  and  control  wire's.


    TOTAL PRICE OF MAJOR NEW  HARDWARE REQUIRED          :   $  6,700.

    TOTAL COST  OF MISCELLANEOUS  NEW HARDWARE REQUIRED   :   $    500.

    TOTAL COST  OF LABOR  TO MAKE  MODIFICATION           :   $ 11,000.

    TOTAL EXHAUST MUFFLER RETROFIT  COST                 :   $ 18,200.

    LOCOMOTIVE  OUT OF  SERVICE PLANT  CYCLE TIME          :     9  days

    LOCOMOTIVE  OUT OF  SERVICE TRANSIT TIME              :     4  days

    LOCOMOTIVE  OUT OF  SERVICE COST/DAY *                :   $    500.

    TOTAL LOCOMOTIVE OUT OF SERVICE  COST                :   $ 6,500.

    TOTAL COST                                          s   $ 24,700.

    * Based on information furnished by Burlington Northern, Milwaukee,
     Missouri Pacific, Penn Central, Rock Island, Southern, and Southern
     Pacific.
                                   E-98

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Cost Study Report No.  4
Page 11
    GENERAL MOTORS LOCOMOTIVE MODEL
:   GP35 (Turbocharged, 2,500 HP)
    LOCOMOTIVE MODEL PRODUCTION DATES
:   1963 - 1965
    NO. OF LOCOMOTIVES PRODUCED AS OP
    JANUARY, 1974                        :  1,308
    PERCENTAGE OF TOTAL GM LOCOMOTIVES
    IN FIELD SERVICE AS OF JANUARY, 1974 :   5.6%
    PERCENTAGE OF TOTAL LOCOMOTIVES IN
    FIELD SERVICE AS OF JANUARY, 1974    :   4.4%
    MAJOR FEATURES AFFECTING AVAILABLE
         EXHAUST MUFFLER SPACE
        PERCENTAGE OF TOTAL
        MODEL PRODUCTION
    A.   Standard Configuration
         (No Dynamic Brakes)

    B.   Standard Dynamic Brakes (Optional)
             18.1%


             57.7%
    C.   Extended Range Dynamic Brakes (Optional)

         1.  Welded on hatch                          18.6% *

         2.  Bolted on hatch                           5.6% **


    *  Not considered in study due to time constraints; however, mod-
       ifications would be similar to those required for GP30 locomotive
       equipped with Extended Range Dynamic Brakes.  Costs would be slightly
       higher due to more extensive hatch modifications and cable alterations.

    ** Not considered in study due to low population in field.  However,
       modifications would be similar to those required for GP40-2
       locomotive equipped with extended range dynamic brakes.
                                   E-99

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Cost Study Report No. 4
Page 12
                             GP35  LOCOMOTIVE
    VERBAL DESCRIPTION OF MUFFLER SYSTEM/ INCLUDING SPARK ARRESTING
    WHERE NECESSARY, TAKING INTO ACCOUNT OPTIONAL FEATURES:
    A reactive-type exhaust muffler is installed directly on the

    turbocharger exhaust outlet duct.   The muffler is of straight-

    through design to minimize backpressure imposed on the engine.

    The weight of the muffler is supported1solely by the turbocharger

    and, as a result, a special reinforced turbocharger exhaust duct

    is required.  Any electrical cabling must be shielded from the

    exhaust muffler heat radiation.


    The turbocharger is considered an  inherently effective spark ar-

    rester and thereby the  turbocharged engine requires no additional

    provision for spark arrestance hardware.
                                   E-100

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Cost Study Report No.  4
Page 13
     A,   GP35 LOCOMOTIVE-STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
     DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
     RETROFIT EXHAUST SYSTEM:
     1.   TURBOCHARGER

          The turbocharger must be removed from engine, disassembled,
          inspected, and a new, reinforced exhaust duct applied.  The
          turbocharger is then tested and reapplied to the engine.


     2.   LOCOMOTIVE CARBODY

          The locomotive carbody to the rear of the cab must be re-
          moved from locomotive.  The turbocharger removal opening
          in the carbody must be enlarged to accommodate the exhaust
          muffler.  The carbody is then reapplied to" the locomotive.


     3.   MUFFLER

          An exhaust muffler is installed on the new turbocharger
          exhaust duct.
     4.   TURBOCHARGER REMOVAL HATCH COVER

          A new, larger hatch cover must be applied above  the  exhaust
          muffler to cover the enlarged turbocharger removal opening
          in the locomotive carbody.


     5.   OIL SEPARATOR EJECTOR

          An ejector must be added to the oil separator  to overcome
          the additional backpressure created by the exhaust muffler.
                                     E-101

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Cost Study Report No. 4
Page 14
    A,   GP35"LOCOMOTIVE - STANDARD CONFIGURATION (NO DYNAMIC BRAKES)
    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED:
    1.   Turbocharger disassembly, inspection, machining, and
         application of new,  reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.


    LISTING OF MISCELLANEOUS  NEW HARDWARE REQUIRED:
    1.    Steel structural shapes used to enlarge turbocharger
         removal opening.
    TOTAL PRICE OF MAJOR NEW HARDWARE REQUIRED

    TOTAL COST OF MISCELLANEOUS  NEW HARDWARE REQUIRED

    TOTAL COST OF LABOR TO  MAKE  MODIFICATION

    TOTAL EXHAUST MUFFLER RETROFIT  COST

    LOCOMOTIVE OUT OF  SERVICE PLANT CYCLE  TIME

    LOCOMOTIVE OUT OF  SERVICE TRANSIT TIME

    LOCOMOTIVE OUT OF  SERVICE COST/DAY *

    TOTAL LOCOMOTIVE OUT OF SERVICE COST
$  6,800.

$    300.

$  8,400.

$ 15,500.

  7 days

  4 days

$    500.

$  5,500.
    TOTAL COST                                          :   $ 21,000.


    *  Based on information furnished by Burlington Northern,  Milwaukee,
      Missouri Pacific, Penn Central, Rock  Island, Southern,  and
      Southern Pacific Railroads.
                                  E-102

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Cost Study Report No.  4
Page I5
    B,   GP35 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    DESCRIPTION OP LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
    RETROFIT EXHAUST SYSTEM:
    1.   TURBOCHARGER

         The turbocharger must be removed from engine, disassembled,
         inspected,  and a new, reinforced exhaust duct applied.  The
         turbocharger is then tested and reapplied to the engine.


    2.   LOCOMOTIVE  CARBODY

         The locomotive carbody containing the dynamic brake hatch
         (welded on), must be removed from locomotive.  The turbo-
         charger removal opening in the hatch must be enlarged to
         accommodate the exhaust muffler.  Dynamic brake cabling
         within the  hatch must be removed and rerouted to provide
         clearance around the muffler.   Conduits,'heat shields,
         and insulated panels must be installed to protect dynamic
         brake cabling in the vicinity of the muffler.  The loco-
         motive carbody is then reapplied to the locomotive.


    3.   DYNAMIC BRAKE CABLING

         Dynamic brake cables connecting the electrical control
         cabinet and the dynamic brake hatch in the carbody must
         be removed  and rerouted to provide clearance for the
         muffler. A closure box to protect the cabling near the
         muffler must be applied.


    4.   MUFFLER

         An exhaust  muffler is installed on the new turbocharger
         exhaust duct.
    5.   TURBOCHARGER REMOVAL HATCH COVER

         A new,  larger hatch cover must be applied above the exhaust
         muffler to cover the enlarged turbocharger removal opening
         in the  dynamic brake hatch.


    6.   OIL SEPARATOR EJECTOR

         An ejector must be added to the oil separator to overcome
         the additional backpressure created by the exhaust muffler.

                                  E-103

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Cost Study Report No.  4
Page 16
    B,   6P35 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES



    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


    1.   Turbocharger disassembly, inspection,  machining,  and
         application of  new,  reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.


    LISTING OF MISCELLANEOUS  NEW HARDWARE REQUIRED;


    1.   Steel structural  shapes used to enlarge turbocharger
         removal opening.

    2.   Insulated panels, conduit,  and sheet metal  heat shields.

    3.   Dynamic brake cabling and associated connectors and cleats.


    TOTAL PRICE OF MAJOR NEW  HARDWARE REQUIRED          :   $   6,800.

    TOTAL COST OF MISCELLANEOUS  NEW HARDWARE REQUIRED   :   $     700.

    TOTAL COST OF LABOR  TO MAKE  MODIFICATION            t   $  12,700.

    TOTAL EXHAUST MUFFLER RETROFIT COST                :   $  20,200.

    LOCOMOTIVE OUT OF  SERVICE PLANT  CYCLE TIME          :     10  days

    LOCOMOTIVE OUT OF  SERVICE TRANSIT TIME              :      4  days

    LOCOMOTIVE OUT OF  SERVICE COST/DAY *                :   $     500.

    TOTAL  LOCOMOTIVE OUT OF SERVICE  COST                :   $   7,000.

    TOTAL  COST                                         .   $  27,200.

    *  Based on  information furnished  by Burlington Northern, Milwaukee
      Missouri Pacific,  Rock Island,  Penn Central, Southern, and       '
      Southern Pacific Railroads.
                                  E-104

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ost Study Report No.  4
age 17
   GENERAL MOTORS LOCOMOTIVE MODEL      :   SD35 (Turbocharged, 2,500 HP)


   LOCOMOTIVE MODEL PRODUCTION DATES    :   1964 - 1966


   NO. OP LOCOMOTIVES PRODUCED AS OF
   JANUARY, 1974                        :   380
                                   v

   PERCENTAGE OF TOTAL GM LOCOMOTIVES
   IN FIELD SERVICE AS OF JANUARY, 1974 :   1.6%


   PERCENTAGE OF TOTAL LOCOMOTIVES IN
   FIELD SERVICE AS OF JANUARY, 1974    :   1.3%
   MAJOR FEATURES AFFECTIVE AVAILABLE           PERCENTAGE OF TOTAL '
        EXHAUST MUFFLER SPACE	      '     MODEL PRODUCTION


   A.   Standard Configuration                         3.1% *
        (No Dynamic Brakes)


   B.   Standard Dynamic Brakes (Optional)            40.6%


   C.   Extended Range Dynamic Brakes (Optional)      56.3%


   * Not considered in study due to low population in field.  However,
     modifications would be similar to those required for GP35 loco-
     motive - Standard Configuration (no dynamic brakes).
                                    E-105

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Cost Study Report No.  4
Pago 18
                             SD35  LOCOMOTIVE
    VERBAL DESCRIPTION OF MUFFLER SYSTEM,  INCLUDING SPARK .ARRESTING
    WHERE NECESSARY,  TAKING INTO ACCOUNT OPTIONAL FEATURES:
    A reactive-type exhaust muffler is  installed directly on the

    turbocharger exhaust outlet duct.   The muffler is of straight-
                            tt
    through design to  minimize  backpressure imposed on the engine.

    The weight of the  muffler is supported solely by the turbocharger
                                              *

    and, as a result,  a  special reinforced turbocharger exhaust duct

    is required.   Any  electrical cabling  must  be shielded from the

    exhaust muffler heat radiation.


    The turbocharger is  considered  an inherently effective spark ar-

    rester and thereby the  turbocharged engine requires no additional

    provision for spark  arrestance  hardware.
                                    E-106

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Cost Study Report No.  4
Page 19
    B,   SD35 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
    RETROFIT EXHAUST SYSTEM:
    1.   TURBOCHARGER

        - The turbocharger must be removed from engine, disassembled,
         inspected, and a new reinforced exhaust duct applied.  The
         turbocharger is then tested and reapplied to the engine.

    2.   DYNAMIC BRAKE HATCH

         The locomotive carbody, containing the dynamic brake hatch
         (welded on), must be removed from the locomotive.  The
         dynamic brake hatch must be removed from the locomotive
         by burning off the welds holding the hatch to the carbody.
         The hatch structure must be modified to shift the hatch
         assembly nine inches toward the rear of the locomotive.'
         The turbocharger removal openi'ng must be enlarged to
         accommodate the muffler.  Insulated panels must be
         installed to protect dynamic brake cabling in the
         vicinity of the exhaust muffler.  Dynamic brake cabling
         and conduits lengthened nine inches over the original,
         must be applied.  The dynamic brake hatch is then re-
         applied to the locomotive and cabling is reconnected.

    3.   MUFFLER

         An exhaust muffler is installed on the new turbocharger
         exhaust duct.

    4.   TURBOCHARGER REMOVAL HATCH COVER

         A new, larger hatch cover must be applied above the
         exhaust muffler to cover the enlarged turbocharger
         removal opening in the dynamic brake hatch.

    5.   OIL SEPARATOR EJECTOR

         An ejector must be added to the oil separator to overcome
         the additional backpressure created by the exhaust muffler.
                                 E-107

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Cost Study Report No. 4
Page 20
    B,   SD55 LOCOMOTIVE EQUIPPED WITH STANDARD DYNAMIC BRAKES
    LISTING OF MAJOR NEW HARDWARE TO BE APPLIED:


    1.   Turbocharger disassembly, inspection, machining, and
         application of new, reinforced exhaust duct.

    2.   Exhaust muffler.

    3.   Turbocharger removal hatch cover.

    4.   Oil separator ejector.


    LISTING OF MISCELLANEOUS NEW HARDWARE REQUIRED;


    1.   Steel structure shapes  used to enlarge turbocharger
         removal opening;              '

    2.   Insulated panel heat shields.

    3. ^  Steel structural shapes and sheet used to relocate
         dynamic brake hatch structure  nine inches rearward
         on locomotive.

    4.   Dynamic brake cables and conduits.


    TOTAL PRICE OP MAJOR NEW HARDWARE REQUIRED         :   $  6,800.

    TOTAL COST OF MISCELLANEOUS  NEW HARDWARE REQUIRED  :   $    900.

    TOTAL COST OP LABOR TO MAKE  MODIFICATION           :   $ 15,800.

    TOTAL EXHAUST MUFFLER RETROFIT COST                :   $ 23,500.

    LOCOMOTIVE OUT OF SERVICE PLANT CYCLE TIME         •:.    10 days

    LOCOMOTIVE OUT OF SERVICE TRANSIT TIME .            :      4 days

    LOCOMOTIVE OUT OF SERVICE COST/DAY  *               :   $    5QO.

    TOTAL LOCOMOTIVE OUT OF SERVICE COST               :   $  7,000.

    TOTAL COST                                         :   $ 30,500.

    *  Based  on information furnished by Burlington Northern, Milwaukee,
      Missouri Pacific,  Penn Central, Rock Island,  Southern, and
      Southern Pacific Railroads.
                                 E-108

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C,   SD35 LOCOMOTIVE EQUIPPED WITH EXTENDED MNGE DYNAMIC BRAKES
DESCRIPTION OF LOCOMOTIVE MODIFICATIONS NECESSARY TO ACCOMMODATE
RETROFIT EXHAUST SYSTEM:
1.   TURBOCHARGER

    _ The turbocharger must be removed from engine, disassembled,
     inspected,  and a new reinforced exhaust duct applied.  The
     turbocharger is then tested and reapplied to the engine.


2.   EXTENDED RANGE DYNAMIC BRAKE HATCH STRUCTURE

     The locomotive carbody, containing the dynamic brake hatch
     (welded on), must be removed from the locomotive.  The ex-
     tended range dynamic brake hatch must be removed from the
     locomotive  carbody by burning off the welds holding the
     hatch to the carbody.  The hatch structure must be modified
     to shift the hatch assembly nine inches, toward the rear of
     the locomotive.  The turbocharger removal opening must be
     enlarged to accommodate the muffler.  Insulated panels must
     be installed to protect dynamic brake cabling in the vicinity
     of the exhaust muffler.  Dynamic brake cabling, conduit, and
     control wires, lengthened nine inches over the original, must
     be applied.   The extended range dynamic brake hatch is then
     reapplied to the locomotive and cabling and control wires
     are reconnected.


3.   MUFFLER

     An exhaust  muffler is installed on the new turbocharger
     exhaust duct.


4.   TURBOCHARGER REMOVAL HATCH COVER

     A new, larger hatch cover must be applied above the exhaust
     muffler to  cover the enlarged turbocharger removal opening
     in the dynamic brake hatch.


5.   OIL SEPARATOR EJECTOR

     An ejector  must be added to the oil separator to overcome
     the additional backpressure created by the exhaust muffler.


                             E-109

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  Cost Study Report No.  4
  Page 22

 C,    SD35 LOCOMOTIVE EQUIPPED WITH EXTENDED RANGE DYNAMIC BRAKES
 LISTING OF MAJOR NEW HARDWARE TO BE APPLIED;


 1.    Turbocharger disassembly,  inspection,  machining, and
     ' application of  new,  reinforced exhaust duct.

 2.    Exhaust muffler.

 3.    Turbocharger removal hatch cover.

 4.    Oil separator ejector.
              .•••

 LISTING OF MISCELLANEOUS  NEW  HARDWARE REQUIRED;


 1.    Steel structure shapes used to' enlarge turbocharger
      removal opening.

 2.    Insulated panel heat shields.

 3.    Steel structural shapes  and sheet  used to relocate
      dynamic brake hatch  structure  nine inches rearward
      on locomotive.

 4.    Dynamic brake cables, conduit,  and control  wires.


 TOTAL PRICE OF MAJOR NEW  HARDWARE REQUIRED          :   $  6,800.

 TOTAL COST OF MISCELLANEOUS NEW  HARDWARE REQUIRED   :   $    900.

 TOTAL COST OF LABOR  TO MAKE MODIFICATION           :   $ 16,500.

 TOTAL EXHAUST MUFFLER RETROFIT COST                 :   $ 24,200.

 LOCOMOTIVE  OUT OF  SERVICE PLANT CYCLE TIME          :     10  days

 LOCOMOTIVE  OUT OF  SERVICE TRANSIT TIME              :      4  days

 LOCOMOTIVE  OUT OF  SERVICE COST/DAY *                :   $    500.

TOTAL LOCOMOTIVE OUT OF SERVICE COST                :   $  7,000.

TOTAL COST                                          :   $ 31,200.

* Based on  information furnished by Burlington Northern,  Milwaukee,
  Missouri Pacific, PennCentral, Rock Island, Southern,  and
  Southern Pacific Railroads.

                              E-110

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   GENERAL  MOTORS  CORPORATION
LOCOMOTIVE EXHAUST MUFFLER RETROFIT
     COST STUDY SUMMARY TABLE

              AND '
OBSERVATIONS MADE AS A RESULT OF THIS
STUDY AND RELATED ELECTRO-MOTIVE EXPERIENCE
             E-lll

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                                                        GgNEHAL  MOTORS	CORPORATION
                                            LOCOMOTIVE EXHAUST MUFFLER RETfiOFIT COST STUDY SUMMARY
Locomotive
Models
GP7    OP9
GP18
GP30    GP35
SD35
GP40
GP40-2
                                                                 SD40
                                                   SD40-2
SD45
SD45-2    GP38    GF38-2
No. of Loco.
Produced A8
of January
1974
Percentage
Of Total GM
Units in Fieia
Service As of
Jan. 1974
Percentage
of Total
Locomotives
In Field
Service As
of January
197*1 »
Total
Exhaust
Muffler
Retrofit
Cost
(Millions)
Total
Cost
Including
Muffler
Retrofit
Plus Out
of Service
Cost (Millions)
2619
11. 2*
8.7*
30.01
43.24
3480
14.9*
11.6*
38.53
55.29
343
1.5*
1.1*
3.83
5.52
946
4.1*
3.2*
15.56
20.8?
1308
5.6*
4.4*
24.63
33-19
380
1.6*
1.3*
8.98
11.63
1202
5.2*
4.0*
20.83
•27.20
165
0.7*
0..6*
2.54
3-37
877
3.8*
2.9*
17-65
22.78
427
1.8*
1.4*
7.55
10.08
1267
5.4*
4.2*
24.16
31.67
260
1.1*
0.9*
4.75
6.35
977
4.2*
3-3*
33.94
41.84
538
2.3*
1.8*
12.33
15.83
 Total overall muffler retrofit  and  out of service cost covering 14 General Motors model locomotives representing a  total  of  14,789
units delivered by 04D,  or  63.4  percent of the total 23,307 total GM loconotlves In service on Class 1 and 2 railroads as  of
January 1, 1974:   $328.86  million
* Posed on
                  l<>rvirrot:i VT,

-------
OBSERVATIONS MADE AS A RESULT OF THIS STUDY ARD RELATED ELECTRO-MOTIVE
EXPERIENCE:
1.   The magnitude of costs established in this study to retrofit in-
     service locomotives with exhaust muffler hardware is indicative
     of the modification complexity involved to not only meet EPA
     proposed 87 dB(A) sound level limit but to insure retention of
     satisfactory overall locomotive performance, reliability, and
     maintainability as well as exhaust spark afrestance control
     where necessary.


2.   The length of locomotive "out of service plant cycle" time
     established in this study to retrofit in-service locomotives
     with exhaust muffler hardware raises a serious question as to
     the practicability of the EPA proposed four year time period
     for the railroads to obtain proven exhaust muffler hardware
     and retrofit all of their in-service locomotives to meet
     87 dB(A) sound level limit compliance.


3.     The length of  field  service evaluation i's normally  two  years.
     Electro-Motive's  experience in the design and development  of
     locomotive exhaust  system hardware has proven that the impor-
     tance  of adequate field  test time to  insure prototype muffler
     design structural integrity cannot be over-emphasized.   The
     ultimate realistic  determination of muffler structural re-
     liability must  take place on the intended locomotive model
     involved with sufficient field service time experience under
     actual revenue  operating conditions.


4.   It should be emphasized that the costs developed in  this study
     do not include additional tooling and facility costs necessary
     to implement the locomotive exhaust muffler retrofit.  This
     additional significant area of cost can only be determined
     after retrofit cycle times and a schedule by locomotive model
     types  have been  established.


5.   In view of this study covering 63.4 percent or 14,789 units out
     of a total of 23,307 General Motors locomotives in service as of
     January 1, 1974, the following projection of the costs established
     in this study is suggested to estimate total retrofit cost for the
     remaining 36.6 percent or 8518 locomotives:
                                 E-113

-------
A.      30 percent or 6992 units -

        use GP7 model cost of $15,000/unit. a

B.      3.6 percent or 839 units -

        use average SD40 model cost of $25/970/unit.

C.      3.0 percent or 687 units -

        use average GP7/9/18 model cost of $16,150/unit. c
a.      The majority of these units are of the switcher
        or lower horsepower type such that modifications
        to the exhaust system of these units would be
        similar to those needed for the GP7 model.

b.      These units are turbocharged road locomotives and
        would require modifications similar to those needed
        on the SD40 units.

c.      These units are the remaining lower horsepower units
        not individually studied and would require modifications
        similar to those on the GP7 GP9 and GP18 units.
                          E-114

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                                 Exhaust    Muffler
                                                                                          Cables
1. Sand Box
2. Battery
3. Control Stand
4. No. 1 Electrical Cabinet
5. Inertial Air Filter
6. Traction Motor Blower
7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator
11. Engine Cranking Motors
12. Engine 20-645E3
13. Dynamic Brake Fans
14. Equipment Rack
15. Air Compressor
16. Radiators
17. Radiator Cooling Fans
18. No. 2 Electrical Cabinet
19. Trucks
20. Fuel Tank
21. Electrical Cabinet Air Filter
                         General Arrangement — SD45  Locomotive

                                       SO   45/45-2
                                       MODIFIED

-------
         1_
                                      0 •  •
                                         20
                                       ".J j    r    j  p;
                   12
                                              • 19 •  *  •  •   •
                                     O) ''«) '- ?) C^/
1. Sand Box
2. Battery
3. Control Stand
4. No. 1 Electrical Cabinet
5. Inertial Air Filter
6. Traction Motor Blower
7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator
11. Engine Cranking Motors
12. Engine 20-645E3
13. Dynamic Brake Fans
14. Equipment Rack
15. Air Compressor
16. Radiators
17. Radiator Cooling Fans
18. No. 2 Electrical Cabinet
19. Trucks
20. Fuel Tank
21. Electrical Cabinet Air Filter
                          General Arrangement — SD45 Locomotive

                                 SD 45/45-2  STANDARD

-------
                            Exhaust   Muffler
                          Extended  Range Dynamic Brakes
 1. Sand Box
 2. Battery
 3. Locomotive Controls
 4. Electrical Cabinet
 5. Carbody Air Filter
 6. Traction Motor Blower
 7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator
11. Engine 16-645
12. Exhaust Manifold
13. Dynamic Brake Fan
14. Engine Governor
15. Lube Oil Strainer
16. Engine Water Tank
17. Fuel Pump
18. Lube Oil Filters
19. Lube Oil Cooler
20. Radiators
21. Radiator Fans
22. Fuel Filter
23. Air Compressor
24. AC And Compressor
   Control Cabinet
   (Back Of Equipment Rack)
25. Truck
26, Fuel Tank
                          Locomotive General Arrangement
                                   GP 40/40-2
                                        MODIFIED

-------
00
 1. Sand Box
 2. Battery
 3. Locomotive Controls
 4. Electrical Cabinet
 5. Carbody Air Filter
 6. Traction Motor Blower
 7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator
11. Engine 16-645
12. Exhaust Manifold
13. Dynamic Brake Fan
14. Engine Governor
15. Lube Oil Strainer
16. Engine Water Tank
17. Fuel Pump
18. Lube Oil Filters
19. Lube Oil Cooler
20. Radiators
21. Radiator Fans
22. Fuel Filter
23. Air Compressor
24. AC And Compressor
   Control Cabinet
   (Back Of Equipment Rack)
25. Truck
26. Fuel Tank
                                               Locomotive General Arrangement
                                                    GP 40/40-2  STANDARD

-------
                 Exhaust   Muffler
Spark Arresting Exhaust Manifold
                                      Extcided  Range Dynamic  Brakes
                      GP 38-2
                        MODIFIED

-------
NJ
O
                                                    GP 38-2 STANDARD

-------
to
                                                   Exhaust   Muffler
                                Spark Arresting Exhaust Manifold
                     Extended  Range Dynamic Brakes
                        |0il lath dine Air filters)
                          Extended Range  Dynamic Brakes
                              |Ptp«r li|iit An filters]
                     «
                           1. Sand Box
                           2. Battery
                           3. Locomotive Controls
                           4. Electrical Cabinet
                           5. Carbody Air Filter
                           6. Traction Motor Blower
                           7. Generator Blower
    8. Auxiliary Generator
    9. Engine Air Filter
   10. Engine Blowers
   11. DC Main Generator
      And AC Alternator
   12. Engine 16-645E
   13. Exhaust Manifolds
   14. Dynamic Brake Fan
15. Engine Governor
16. Accessory Rack
17. Air Compressor
18. Radiators
19. Radiator Fans
20. Trucks
21. Fuel Tank
                           MODIFIED
Locomotive General Arrangement
              fiP  38

-------
Ni
                             1. Sand Box
                             2. Battery
                             3. Locomotive Controls
                             4. Electrical Cabinet
                             5. Carbody Air Filter
                             6. Traction Motor Blower
                             7. Generator Blower
 8. Auxiliary Generator
 9. Engine Air Filter
10. Engine Blowers
11. DC Main Generator
   And AC Alternator
12. Engine 16-645E
13. Exhaust Manifolds
14. Dynamic Brake Fan
15. Engine Governor
16. Accessory Rack
17. Air Compressor
18. Radiators
19. Radiator Fans
20. Trucks
21. Fuel Tank
                                                   GP-38 STANDARD
                                                   Locomotive General Arrangement

-------
                                               Exhaust    Muffler
                                                       Standard  Dynamic Brake Hatch Structure  art Cables
                                                            Extended  Range  Dynamic Brakes
10
u>
 1. Sand Box
 2. Battery
 3. Control Stand
 4. No. 1 Electrical Cabinet
 5. Inertia! Air Filter
 6. Traction Motor Blower
 7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator
11. Engine Cranking Motors
12. Engine 16-645E3
13. Dynamic Brake Fans
14. Equipment Rack
15. Air Compressor
16. Radiators
17. Radiator Cooling Fans
18. Trucks
19. Fuel Tank
20. Electrical Cabinet Air Filter
                                     General Arrangement — SD40 Locomotive
                                                SO 35/40/40-2
                                                       MODIFIED

-------
                                                           WOOD
                                                           'L jL ™ <^^^^^^i^"T^T^l
10
                                     LSand Box
                                     2. Battery
                                     3. Control Stand
                                     4. No. 1 Electrical Cabinet
                                     5. Inertial Air Filter
                                     6. Traction Motor Blower
                                     7. Generator Blower
                                     8. Auxiliary Generator
                                     9. Turbocharger
                                    10. Main Generator
11. Engine Cranking Motors
12. Engine 16-645E3
13. Dynamic Brake Fans
14. Equipment Rack
15. Air Compressor
16. Radiators
17. Radiator Cooling Fans
18. Trucks
19. Fuel Tank
20. Electrical Cabinet Air Filter
                                             General Arrangement - SD40  Locomotive
                                                     SD 35/40/40-2   STANDARD

-------
                                                Exhaust Muffler
to
Ln
                                                              Extended Range Dynamic  Brakes
                                                                                   5£
                                                    ?'j ^/ QL- •&  v '^ (T (5
         1. Sand Box
         2. Battery
         3. Loco. Controls
         4. Electrical Cabinet
         5. Inertial Separator
         6. Traction Motor
           Blower
         7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator and
   Alternator
11. Engine 16-567 D3A
12. Exhaust Manifold
13. Dyn. Brake Fan
14. Governor
15. Lube Oil Strainer
   Housing
16. Eng. Water Tank
17. Fuel Pump
18. Lube Oil Filter
19. Lube Oil Cooler
20. Radiator
21. 48" Fan and Motor
22. 36" Fan and Motor
23. Fuel Pressure
    Filter
24. Air Compressor
25. Trucks
26. Traction Motors
27. Main Air Reservoir
28. Fuel Tank
                                          General Arrangement
                                                GP  35

-------

to
             1. Sand Box
             2. Battery
             3. Loco. Controls
             4. Electrical Cabinet
             5. Inertial Separator
             6. Traction Motor
               Blower
             7. Generator Blower
 8. Auxiliary Generator
 9. Turbocharger
10. Main Generator and
   Alternator
11. Engine 16-567 D3A
12. Exhaust Manifold
13. Dyn. Brake Fan
14. Governor
15. Lube Oil Strainer
   Housing
16. Eng. Water Tank
17. Fuel Pump
18. Lube Oil Filter
19. Lube Oil Cooler
20. Radiator
21. 48" Fan and Motor
22. 36" Fan and Motor
23. Fuel Pressure
   Filter
24. Air Compressor
25. Trucks
26. Traction Motors
27. Main Air Reservoir
28. Fuel Tank
                                               General Arrangement
                                             GP 35  STANDARD

-------
                                              Exhaust   Muffler
                                                 'Standard  Dynamic  Brake  Hatch  Structure and Cables
                                                         Extended Range  Dri&mc Brakes
                                                  •   •  -no)   •  •  •
1. Sand Box
2. Loco. Controls
3. Electrical Cabinet
4. Dust Filter & Blower Motor
5. Traction Motor Blower
6. Generator Blower
7. Auxiliary Generator
 8. Turbocharger
 9. Grid Blower Motor
10. D3 Diesel Engine
11. Exhaust Manifold
12. Governor
13. Engine Water Tank
15. Radiators
16. Lube Oil Cooler
17. Lube Oil Filter
18. Fuel Filter
19. Air Compressor
20. Fuel Pump
14. Engine Cooling Fans  21. Traction Motors  28. Batteries

         General Arrangement

                 GP  30
22. Truck
23. Lube Oil Strainer
24. Fuel Tank
25. Air Reservoir
26. Main Generator & Alternator
27. Traction Motor Air Duct
                                             I.DDIFIED

-------
ro
oo
                                                           ©©©© ©©©€
                                                           ©00©  ©0©
           1. Sand Box
           2. Loco. Controls
           3. Electrical Cabinet
           4. Dust Filter & Blower Motor
           5. Traction Motor Blower
           6. Generator Blower
           7. Auxiliary Generator
 8. Turbocharger
 9. Grid Blower Motor
10. D3 Diesel Engine
11. Exhaust Manifold
12. Governor
13. Engine Water Tank
15. Radiators
16. Lube Oil Cooler
17. Lube Oil Filter
18. Fuel Filter
19. Air Compressor
20. Fuel Pump
22. Truck
23. Lube Oil Strainer
24. Fuel Tank
25. Air Reservoir
26. Main Generator ft Alternator
27. Traction Motor Air Duct
14. Engine Cooling Fans 21. Traction Motors  28. Batteries
                                                General Arrangement
                                             GP-30 STANDARD

-------
                                         GP9 DIESEL ROAD SWITCHING LOCOMOTIVE
                                                                                     EXHAUST MUFFLER
-
 j
 c
                                                         • Standard Dynamic Brake Hatch  Structure
     i  STEAM GENERATOR
     2  TRACTION MOTOR BLOWERS
     3  BATTERIES
     4  ENGINEER'S CONTROLS
5 ELECTRICAL CABINET
6 TRACTION MOTORS
7 FUEL AND WATER TANKS
8 DC GENERATOR
9 AC GENERATOR
O AUX GENERATOR
'I COOLING FANS
12 DIESEL ENGINE
'3 PG GOVERNOR
A ENGINE WATER TANK
i5 LUBE OIL COOLER
16 LUBE OIL FILTER
                                                    »«NSMDSION tNO CONTIOI
                                                 General Arrangement

                                                         GP  7/9/18
17  LUBE OIL STRAINERS
18  MAIN AIR RESERVOIR
19  LOAD REGULATOR
20  AIR COMPRESSOR
                                                         MODIFIED

-------
                                     GP9 DIESEL ROAD SWITCHING LOCOMOTIVE
-•'
u>
-
     STEAM GENERATOR
   2 TRACTION MOTOR BLOWERS
   3 BATTERIES
   4 ENGINEER'S CONTROLS
                                                        'OOOO QOOO
                                                        oooo  oooo
"  ELECTRICAL CABINET
6 TRACTION MOTORS
7 PUEL AND WATER TANKS
8 DC GENERATOR
9 AC GENERATOR
iO AUX GENERATOR
il COOLING FANS
i2 DIESEL ENGINE
>3 PG GOVERNOR
A ENGINE WATER TANK
6 LUBE OIL COOLER
16 LUBE OIL FILTER
17 LUBE OIL STRAiNEF-
18 MAIN AIR RESERVO:^
19 LOAD REGULATOR
20 AIR COMPRESSOR
                                             General  Arrangement
                                            GP 7/9/18  STANDARD

-------
                     Appendix F

 GENERAL MOTORS CORPORATION ADDITIONAL COMMENTS ON THE
ENVIRONMENTAL PROTECTION AGENCY PROPOSED RAILROAD NOISE
                  EMISSION STANDARDS

-------
                        GENERAL MOTORS CORPORATION
                        ADDITIONAL COMMENTS TO THE
                    ENVIRONMENTAL PROTECTION AGENCY
                PROPOSED RAILROAD NOISE EMISSION  STANDARDS
                        DOCKET NUMBER ONAC 7201002
DESCRIPTION

The Environmental Protection Agency, Office of Noise Abatement and Control (ONAC),
has published proposed standards for sound levels resulting from the operation of locomotives
and railroad cars of surface carriers engaged In interstate commerce by railroads.  The
ONAC has also published a Background Document which explains the basis of,  purposes for,
and environmental effects of the proposed standards.

To further support General Motors Corporation's response to the Environmental  Protection
Agency's Proposed Railroad Noise Emission Standards,  the following comments  are offered
as an addendum to the August 15, 1974 Comments of General Motors Corporation With
Respect to Proposed Railroad Noise  Emission Standards, Docket No. ONAC 7201002.
GENERAL COMMENTARY

General Motors believes that stationary locomotive sound level limits of 93 dBA at any
throttle setting and 83 dBA at idle measured at 30 meters effective 270 days from the date
of promulgation of the regulations, are reasonable requirements.

General Motors believes that a stationary locomotive sound level limit of 87 dBA at any
throttle setting measured at 30 meters and effective four years from the date of promulgation
of the regulations,  is a technically feasible requirement.  It can be achieved on future
production locomotives by the application of mufflers and necessary structural changes
to accommodate the muffler.

The following is a summary of General  Motors additional comments to the proposed standards:

1.  Exhaust noise is not  the major contributor to overall locomotive idle noise measured
    at 100 feet; and therefore, the addition of a locomotive exhaust muffler will not
    reduce idle locomotive noise by 6  dBA from 73 dBA to 67 dBA as the EPA proposed
    railroad noise emission regulation requires.

2.  General Motors does agree that  full power locomotive noise is exhaust noise
    dominant and the addition of exhaust mufflers will permit the achievement of
    the proposed regulation of 87 dBA  at 100 feet effective four years from the
    date of promulgation.
                                        F-l

-------
                                        -3-
1.  FULL POWER OVERALL LOCOMOTIVE EXHAUST NOISE AT 100 FEET

    To demonstrate that full power overall locomotive noise at 100 feet is controlled
    by the exhaust noise level, consider Figures 1, 2, and 3.  The graphs compare
    A-weighfed octave band  sound  levels measured  at 3 feet from the exhaust
    outlet and at 100 feet fro.Ti the side of the locomotive during full power (eighth
    throttle) operation   (radiator cooling fans not operating to eliminate their
    influence) for three present production road locomotives, SD40-2, GP39-2, and
    GP38-2,  respectively.  Inspection of these plots shows that a good correlation for
    al( three  locomotives can be made between the full power exhaust noise spectrum
    at three feet and the overall locomotive noise spectrum measured at 100 feet when
    a 30 dB attenuation factor for hemispherical sound spreading is used to correct for
    the  increased distance.  For most points, the measured octave band level at 100 feet
    is less than that predicted using the 30 dB attenuation factor indicating excess
    attenuation not accounted for. When the measured octave band level is greater
    than that  predicted, structurally-radiate'd locomotive noise is  contributing to the
    overall locomotive  noise*
    Extending this correlation to analyze idle locomotive overall noise demonstrates that
    exhaus* noise is not the major contributor at idle.  Figures 4, 5, and 6 correspond
    to figures 1, 2, and 3 respectively,  but compare idle exhaust noise level at three
    feet with idle overall locomotive noise at 100 feet for the same three  locomotives.
    It becomes immediately apparent upon applying the 30 dB attenuation factor to the
    idle exhaust noise spectrum that the  correlation observed between exhaust and
    overall noise at full power does not exist at idle.  For all three locomotives, which
    include both turbocharged and roots  blown engines, the  octave bands controlling
    the overall A-weighfed locomotive sound levef at 100 feet are not exhaust notse
    dominated and are,  in fact,  controlled by structurally-radiated noise.  Therefore,
    it ts technically not possible to reduce idle overall locomotive noise with the
   application of an  exhaust muffler.
                                         F-2

-------
                                       -4-


2.   STATIONARY LOCOMOTIVE IDLE NOISE EMISSION DATA -
     TABLE 4-2 IN THE BACKGROUND DOCUMENT

     General Motors evaluation of the stationary locomotive idle noise emission data presented
     in Table 4-2 in the Background Document is as follows:
     Considering only General  Motors locomotives and only those measurements actually
     taken at 100 feet, * the mean value of the locomotive idle noise level measurements
     is 68.4 dBA and the standard deviation is  1.9 dBA.  These values agree well with
     General Motors data which indicates a mean of 68.2 dBA and standard deviation
     of 1.7 dBA for present production locomotive models tested.  Based on these means
     and standard deviations, approximately 74% of all General Motors locomotives
     exceed the proposed level  of 67 dBA at 100 feet at idle.
      *Refer to COMMENTS, Page 5, Item 2,
                                      F-3

-------
                                        -5-


CONCLUSIONS

In summary, it has been demonstrated that application of exhaust mufflers will not allow
locomotives to meet the proposed idle noise level requirement of 67 dBA at 100 feet.
Further, 74% of all GM locomotives, which account for approximately 75% of all
locomotives presently in service, currently exceed the proposed noise level of 67 dBA.
Therefore, taking into consideration available technology, cost of compliance and the
intent of the proposed regulation to insure 100% idle noise level compliance, it  is
General Motors opinion that the idle noise level requirement should be maintained at
73 dBA.
                                   F-4

-------
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                         FIGURE 1
                              F-5

-------
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                        TURBOCHARGED - 2,300  HP
                              OCTAVE PASS BANDS IN HERTZ
                           110  —  35S — 710  	  1400 —  JMO
                                                       — MOO  — MMO
                     100
                                         1000
                               FREQUENCY IN HERTZ
                                                              10000
                           STH THROTTLE; FULL  LOAD
                3  FEET FROM EXHAUST OUTLET
              100  FEET FROM.SIDE.OF.LOCOMOTIVE,
                                 , OF LQCQMOI]
                                 IS OPERATING
                                FIGURE 2
                                  F-6

-------
                               GP38-2
             ROOTS BLOWN - 2,000  HP LOCOMOTIVE
             EQUIPPED WITH PRODUCTION SPARK ARRESTER EXHAUST MANIFOLDS
              45  —  W —
                              OCTAVE PASS BANDS IN HERTZ

                          1(0  -  35J  - 710  - UOO  -  MOO
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FREQUENCY IN  HERTZ
                                                         51

                                                             10000
                            STK THROTTLE; FULL LOAD
         °—o   3 FEET  FROM EXHAUST OUTLET
               100 EELFRQSD  OF
                                FIGURE 3
                                   F-7

-------
                               SD40-2 LOCOMOTIVE
                45  —
                                OCTAVE PASS BANDS IN HERTZ

                             tW  —  3J3 — 710  	 1«0 — ?MO  	
                                                                —  na»
 
-------
                            GP39-2 LOCOMOTIVE
        45  —  90 —
                                OCTAVE PASS BANDS IN HERTZ
                                —  JSi  	  7)0 — UOO  —  2MO
                                                          — MOO  —  HMO
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                       100
                                    1000
                          FREQUENCY IN HERTZ
10000
                           IDLE
           3 FEEJ FROM EXHAUST OUTLET
        100 FEET FROM.SIDE OF LOCOMOTIVE,'
                                 IDE
                              NG FANS  OP
                                FIGURE 5
                                   F-9

-------
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         90
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        70
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                                GP38-2  LOCOMOTIVE


              PRODUCTION SPARK ARRESTER  EXHAUST  MANIFOLDS

                                 OCTAVE PASS BANDS IN HERTZ
                   —  <0  —  190  —  3ii — 710  —  1400 — J»00  —  MOO
                                                                 — 11MO

                 s .
                       100
                                    1000

                          FREQUENCY  IN HERTZ
                              IDLE

                  3 FEET FROM  EXHAUST OUTLET

                100 FEET
                    NO  CO
                                 FIGURE 6
                                  F-IO

-------
           Appendix G




MUFFLER DESIGN FOR LOCOMOTIVES

-------
                3.   MUFFLER DESIGN FOR LOCOMOTIVES

     This section outlines the results of a study undertaken to
design mufflers for several types of diesel-electric locomotives.
The design process takes into account
   • noise control requirements,
   • maximum allowed backpressures,
   • chemically contaminated exhaust flow, and
   • maximum available space.
     Conceptual designs are presented for four locomotives which
represent all of the types in service.  The models analyzed are
   • EMD GP-35 (turbocharged),
   • EMD GP-40 (turbocharged),
   • EMD GP-38 (Roots-blown),
   • GE U-serles (turbocharged).

Design Goals and Techniques

     The aim of the project was to design mufflers which would
reduce locomotive exhaust noise levels by 10 dBA, yet fit within
the presently available space.  Muffler-induced backpressure was
constrained to be within 5-in. H 0 for turbocharged engines and
21-in. H20 for nonturbocharged engines.   In addition, sound
absorptive treatments, such as steel wool packing or porous
plates, were excluded from consideration because it is not known
how they would be affected by dirty exhaust gases.
     Given these constraints, it was determined that best perform-
ance could probably be achieved using mufflers of the reactive
type.  Reactive mufflers obtain their effectiveness from abrupt
changes in the cross-sectional area of the exhaust pipe, which

-------
tend to reflect sound back toward the source.  Unfortunately,
these discontinuities also tend to generate areas of flow separa-
tion, which increase the flow resistance through the muffler and,
hence, the backpressure.
     A compromise between attenuation performance and backpressure
was therefore obtained by smoothing the sharp corners at the
transition regions.  This smoothing tended to decrease attenuation
and backpressure, bringing the latter, within allowable limits
while still providing 10-dBA or more noise reduction.  In addi-
tion, the exit pipe was shaped into a Venturi tube, a configura-
tion which Improves attenuation via a reduction in pipe cross-
sectional area.  A schematic of the resulting design, designated
Type A, is shown in figure 3-1-  Figure 3-2 shows two alternate
configurations that were also studied.  Types B and C lack the
Venturi tube; Type C, however, contains an internal baffle.  A
fourth alternative studied was to increase the volume of the ex-
haust manifold; this design is discussed below in the case of
the Roots-blown locomotive.
     The effectiveness of a muffler in reducing noise depends on
how well the muffler's insertion loss spectrum (which^represents
noise reduction as a function of frequency) is matched to the
noise spectrum of the source.  If the muffler's effectiveness is
concentrated in frequencies where little noise is being generated,
little benefit will result.   Part of the design process there-
fore consists of varying the muffler's shape and volume to ob-
tain optimum noise reduction in the frequencies where the most
noise is being generated.  In this study, the exhaust noise
spectrum shown in figure 3-3 was -used as a reference for muffler
design.  The spectrum shown is that of a 12-cylinder, 2000-hp
engine on an Alco 250 locomotive.  Spectra for other engines may
have higher or lower overall levels, and some of the details of
the spectral shape may vary from unit to unit, but the overall
shape will be fairly constant for most engines.
                               G-2

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    Intake
     Pipe
Tailpipe
   Flow
                                Venturl Tube
     FIGURE 3-1.   SCHEMATIC VIEW OF TYPE A MUFFLER.
                       Type  B
                       Type C
FIGURE 3-2.   SCHEMATIC VIEW OF TYPES B AND C MUFFLERS,
                            G-3

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   UJ
       120
Ul
cr^.
co o
co-9
ui :i
£N
       100
 u
   00
   uj   80
   1
   o
   ro
FIGURE 3-3.
           i—r
i—r
           31.5   63   125  250  500 1000 2000 4000 8000 16,000 32,000
                OCTAVE BAND CENTER FREQUENCY(Hz)
          TYPICAL LOCOMOTIVE  EXH'AUST  NOISE  SPECTRUM  MEASURED
          AT 2.5 FT FROM OUTLET.
     The muffler design procedure was to select, from among the
four described, a general muffler type having dimensions  somewhat
smaller than the known volume available inside the locomotives.
The specific dimensions and the details of inlet and outlet de-
sign were then systematically varied, and backpressure and over-
all attenuation were computed for each trial configuration.  This
process was continued until a configuration was found that satis-
fied both noise reduction and backpressure constraints.   Perform-
ance was explicitly computed at throttle 8 only; performance at
idle is discussed later.
     Backpressure and attenuation performance were computed using
a proprietary BBN computer model.  To demonstrate the'validity of
this model, we predicted the attenuation performance of the EMD-
designed Universal Silencer muffler and compared its actual per-
formance, as obtained from EMD measurements.  The EMD data for
exhaust noise levels with, and without the Universal Silencer
                               G-4'i

-------
muffler are shown In figure 3-**.  Subtracting the two curves
gives the muffler insertion loss, as shown, by the dashed line
in figure 3-5-  The BBN-predicted insertion loss is shown by the
solid curve in figure 3-5.  The correspondence between the pre-
diction and the measurement is good except in the 200-Hz and
250-Hz bands.  These discrepancies are probably caused by some
approximations that were made in entering the dimensions of the
muffler into the computer.  It is clear, however, that the pro-
gram provides a reasonable indication of a muffler's performance.

Results

     We now describe the final muffler designs and their predicted
performance for the four locomotives listed at the beginning of
this section.
                                                   •
 EMD GP-35.  The space available on an EMD GP-35 equipped with
standard dynamic brakes is a volume 68 in. long (parallel to the
axis of the locomotive) by 48 in. wide by 21 in. high.  The di-
mensions of the turbocharger outlet are 7 in. by 30 in.  (Source:
Measurement by M. Rudd at Morrison-Knudsen Co., Inc., Boise,
Idaho, 26 September 197^.)  The muffler designed to fit this space
(figure 3-6) is a Type A muffler with an inlet cross section
of 7 in. by 30 in., a smoothed transition region into an expan-
sion chamber having a cross section of 68 in. by U8 in., and a
Venturi-tube outlet with a minimum cross section of b.b in. by
30 in.  The detailed dimensions are given in Appendix A.  The
GP-35 muffler is estimated to provide 10 dB of exhaust noise
attenuation while imposing an additional 4.5-in. H20 of back-
pressure.
 EMD GP-^0.  The space presently available in a GP-40 with  stan-
dard dynamic brakes* is a volume above the turbocharger of
•This feature was present on 71* percent of the 1202 GP-^Os pro-
 duced; see EMD statement of 1 November 197*1.
                                G-S

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         I  I  I  I  I  I  I  I  I  t  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I
               100                 1000                 10000

          —ONE-THIRD OCTAVE BAND CENTER FREQUENCY (HZ)

   Production Model
   With Universal Silencer Exhaust Muffler Measurements at 3 ft
   from Exhaust Outlet, Locomotive Stationary Under Rated Engine
   Speed and Load Conditions.
FIGURE 3-4.
MEASUREMENTS OF EXHAUST NOISE OF AN EMD SD45-2, WITH
AND WITHOUT UNIVERSAL SILENCER E.XHAUST MUFFLER
(Source:  EMD, 1973).

-------
   20
   10
CD
CO

CO
o

fe
IJLl
CO
z
   -10
        T   I  I   I  I   J  I   I  \
            MEASURED INSERTION LOSS FOR UNIVERSAL SILENCER

            BBN PREDICTED INSERTION LOSS FOR UNIVERSAL SILENCER
        i  i  I   I  i   ». t   i  I   i  i   »	I  I   I  1   I  I   I  I   I  I   I  I
     16
31.5     63     125    250     500    1000    2000    4000   8000


         ONE-THIRD OCTAVE BAND CENTER FREQUENCY tHz)


      	Measured  Insertion Loss- for Universal  Silencer

      	 BBN Predicted Insertion Loss for Universal  Silencer.
lepoo
  FIGURE 3-5.  COMPARISON OF MEASURED ATTENUATION  FOR UNIVERSAL  SILENCER

               MUFFLER WITH BBN PREDICTION.

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9
oo
                             —7"-*
^
7
                                   •68"
                    VIEW PERPENDICULAR TO ENGINE AXIS
                                                                        '
 f T
   8"

  _L

 21"



-i_
                                                           -48"
                                                                               VIEW ALONG AXIS OF ENGINE
                                                       •AVAILABLE SPACE

                                                       •BBN MUFFLER DESIGN
             FIGURE 3-6.   AVAILABLE  SPACE  (SOLID LINE) AND  MUFFLER PROFILE  (DASHED  LINE)
                            FOR  GP-35.

-------
approximately 65 in. by *J6 in. by 20 in.   (Source:   EMD presenta-
tion to AAR, 8 August 1973.)  The muffler designed  to fit this
space is shown in figure 3-7.  It is a Type A muffler having an
inlet cross section of 7 in. by 30 In., an expansion chamber
with a cross section of 35 in. by 65 in., and a Venturi-tube
outlet with a minimum cross section of 5.3 in.  The detailed
dimensions are given in Appendix A.  The GP-40 muffler is
estimated to provide 12 dBA of exhaust noise reduction, while
imposing an additional 3-in. H20 of backpressure.
     Figure 3-7 also shows the profile of the EMD-designed Univer-
sal Silencer muffler.  We see that this muffler is  higher than
the allowable volume, and the stack outlet is displaced from its
original position.  The Universal Silencer design therefore re-
quires numerous modifications to the turbocharger removal hatch
(AAR, R013).  These modifications are avoided in .the BBN design.
                                                   *
 EMD GP-38.  The above engines were turbocharged, so that the
exhaust stream was collected into a single pipe to which a single
muffler could be applied.  This is not the case with the GP-38,
which is Roots-blown; the exhaust manifold consists of four in-
line cylindrical collectors, each receiving gas from four cyl-
inders.  The collectors are connected to form two groups of two;
each group then has one exhaust pipe of approximately 5-in. by
15-in. cross section exiting through.the roof.  To install a
single muffler, as in the above cases, would entail grouping the
four collectors into a single manifold/exhaust line and placing a
muffler on the exhaust line.  Figure 3-8 is a sketch of such an
arrangement.  (Source:  EMt> presentation to AAR, 8 August 1973.)
In general, little room is available for a muffler, especially
in those engines having three cooling fans; the third fan gener-
ally takes up the space shown for the muffler in figure 3-7.
     An alternate approach is to retain the existing exhaust
manifold design, but to enlarge the collectors so as to provide
additional attenuation.  The existing collectors are approximately
                                G-9

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£
o
                                                                  REMOUAL HATCH DESIGNED
                                                                   TO ACOOMOOATE MUFFLER

                                                                 ORIONALTOPOF UXXIMOTIVE-—
VIEW ALONG ENGINE AXIS
                                                                 TURBOCHARGER OUTLET
                                                             EMODESKN	
                                                             BBN DESIGN	
                                                       EXISTING LOCOMOTIVE	
                                                             STRUCTURE
   rti
VIEW PERPENDICULAR TO ENGINE AXIS
                    FIGURE 3-7.   AVAILABLE  SPACE  AND MUFFLER  DESIGNS  FOR EMP  GP-40

-------
ranr
  FIGURE  3-8.
EMD CONCEPT FOR  INSTALLING  EXHAUST MUFFLER
ON A ROOTS-BLOWN LOCOMOTIVE.
                                G-ll

-------
 15 in.  in diameter;  there are roughly an additional 12 in.  of
•space available between the tops of the  collectors  and the  bottom
 of the  resistor grid fan.  (Sources:   Drawings  in END presentation
 to AAR, 8 August 1973.)  The BBN-designed manifold  replaces each
 pair of 15-in.  diameter collectors  with  a single  expansion  cham-
 ber having an elliptical cross section,  the  minor (vertical)  axis
 of which is 26  in. and the major (horizontal) axis,  30 in.   A
 sketch  of the two arrangements is shown  in figure 3-9.  The new
 manifold is estimated to give 5-dB  attenuation  more  than  the  old
 one, with an additional backpressure  penalty of about 0.5-in.  H,0.
 Detailed dimension arid performance  estimates are  given in Appendix
 A.
      This design preserves all existing  components  except the
 manifold cylinders themselves.   If  further attenuation is re-
 quired, a still larger manifold could be installed  by taking  ad-
 vantage of the  existing clearance between the bottom of the
 existing manifold and the top of the  engine.
  GE U-Series.   The GE locomotives do  not have fans  or other
 equipment above the  engine;  this space is therefore  available for
 muffler installation.   On all the locomotives,  the  vertica-1 space
 between the top of the engine and the maximum height limit  is
 20 in.; the length of this space varies  from model  to model.   For
 our computations, we  have used an available  volume  16 in. high by
 36 in.  wide by  160 in.  long;  the length  corresponds  to the  U25,
 U33, and U36 models.   (Source:   GE  presentation to  AAR, 8 August
 1973.)   The available space  and the muffler  designed to fit it
 are shown in the plan in figure  3-10.  The muffler is  a Type  C,
 having  an expansion  chamber  with a  cross section  of  16 in.  by
 36 in., which is separated into two segments by a plane baffle
 having  an open  area  of 300 In.   The detailed dimensions and in-
 sertion loss are given in Appendix  A.  This  muffler  design  will
 give approximately 10 dBA of exhaust  noise reduction with a back-
 pressure penalty of  1.5-in.  H20.  It  should  be  noted that this
                                G-12

-------
                                      Existing
                                       Manifold
                i  W «  e(.») '   *) >) '-> ^ J

                l8«l©Ca)© ©©©pit
                U It           —^rrpJU'
                                        Suggested
                                         Manifold
FIGURE 3-9.   MANIFOLD MUFFLER DESIGN FOR GM GP-38
                         G-13

-------
                      •160"-
 TP
 36" I                    FLOW
    I
I'D
                    X
                                        I_	1
                           "M"
                        l60x36xl6 RECTANGULAR SOLID
    	SPACE AVAILABLE (SEE TEXT)
    — SCHEMATIC BBN MUFFLER DESIGN (DETAILS OF INLET AND
        OUTLET DESIGN OMITTED)
FIGURE 3-10.  PLAN VIEW OF AVAILABLE SPACE AND MUFFLER
            OUTLINE FOR GE U25, U33,  AND U36 LOCOMOTIVES
                        G-14

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muffler would protrude through the roof and thus would require
some car body modifications.

Summary

     Table 3-1 summarizes the attenuation and backpressure per-
formance of the four muffler designs described above.  With the
exception of the GP-38, all the designs met their goals.  The GP-
38 manifold muffler provided only 5-d"BA attenuation, but the de-
sign did not take advantage of all the available space.

                            TABLE 3-1
            ATTENUATION AND BACKPRESSURE PERFORMANCE
                  OF CONCEPTUAL MUFFLER DESIGNS
Locomotive
EMD GP-35
EMD GP-40
EMD GP-38
GE U-25,
33, 36
Type
TC
TC
RB
TC
Reduction in
A-Weighted
Exhaust Noise
Level-dB
10
12
5
10
Increas-e in
Backpressure -
in. H20
4.5
3.0
0.5
1.5
     The attenuations shown apply at full throttle.  Attenuation
at idle was not computed with the model, but was estimated by hand
calculations.  The estimate Indicated that a muffler which pro-
vides 20-dBA attenuation at full throttle will provide 5- to
6-dBA attenuation at idle.
     This development shows that it is possible to design effec-
tive locomotive mufflers to meet present volume and backpressure
constraints.  The preceding designs are still conceptual.  They
would need to be developed further, refined, and tested before
                               G-15

-------
they could be Implemented on a large scale, but that process
does not appear to present any Insuperable problems.
                               G-16

-------
                    Appendix H




DETAILED MUFFLER DESIGNS AND PERFORMANCE ESTIMATES

-------
                           APPENDIX H
       DETAILED MUFFLER DESIGNS AND PERFORMANCE ESTIMATES

     This appendix contains the detailed muffler designs dis-
cussed in Sec. 3«   Each muffler is described in terms of its
physical dimensions and its estimated attenuation and back-
pressure performance.  The dimensions of each muffler are des-
cribed in terms of successive "elements", each element being a
cross section of the muffler having a given length and specified
inlet and outlet areas.  The computer-produced tables describe
the sections as "approximately circular", although, in fact,
they are rectangular; for acoustic purposes, the two are equiva-
lent if the cross-sectional area is the same.

     The additional backpressure for each muffler is shown at
the bottom of the table of dimensions.  Attenuation performance
is shown in a second table, which displays the original and
modified A-weighted noise levels in each one-third octave band,
as well as the overall A-weighted levels with and without the
muffler.

     The tables relating to the manifold muffler designed for
the GP-38  (Tables A-5 through A-8) must be read somewhat
differently from the tables for the turbocharged locomotives.
In the case of the Roots-blown engines, the existing manifold
provides some attenuation already.  To estimate the effective-
ness of the suggested larger manifold, the backpressures and
noise attenuation of both manifolds must be estimated.  The
noise benefit of the new manifold  is then the  difference in
attenuation between the new and the old manifolds, and  similarly
for backpressure.
                               H-l

-------
     Because the absolute A-welghted noise level for the exhaust
without any manifold is not known, the figure of 11*1.1 dBA was
taken as an arbitrary reference.  The absolute A-weighted levels
shown in Tables A-6 and A-8 are therefore not correct; the
differences in these levels between the two manifold designs,
however, are reliably estimated.
                              H-2

-------
                            TABLE A-l

DIMENSIONS  AND  PREDICTED  BACKPRESSURE   OF. MUFFLER
                         FOR EMD GP-35
                            SjSTZB »AIABZTZIS

           Totvn:' Trioeirr  .          35500. ct  co. rt./KXi.
           TZIsrECAZUrE •               158.    OEft. T
           till. SI1IZC rKSS. asOf •   2767,97  XI. OF V«T»»
           RXI. STATIC mss. Daor •  .2767.97  XI. or «»T!I
           BAXitivr. RACK tvKtzt •          i.aeo
           mi CCS31-I3KS:             rizi mio
           mixr »srtjc?io» catrr. «      .700
           JOBIP nociir.  ajr •       uii.rc  m
               tR~ fOiiovxio tiziiEiTs tt  osio x» T»S  CASZ.
        fltHIHT VOHBZI  1 IS H »>»»OXIBHTElt CltCUUl,  IXOXO TIAISXTXOI.
           iE»8tK •                     1.23 XI.
           un or :KIII •            2io.cs so. x>.
           am cr sine? -            asa. rz so. r».
        •ax.  lien aesBii x* DUCT •       O.K»


               V08BZ1  2 IS A» A»F*OXX»iTIl)t CXtCVlAI.  1X010 XIAKSXXXOI.
                                       i.ea XK.
               cr xaizx •            292. *z so. ».
           AICA or OUTtIT •            3f0.el SQ. I».
        •AZ.  8ACI BDKBZ1 10 DUCT •       f.13T


               BVUftZI  3 IS A* AIllOXXRATtlT Cl»CBtAl,  HOIS llAfSXtXOB.
           USA Or XCLtt «            30D.C3 30. I*.  .
           AltA Or OOTIK? •            360.82 80. X>.
        •AS. BACR UttntZk I» DOCT •       0.11S


        sttntBt Bonni  « is A» trrioxz.iAt!it CIECBUI,  txaxo TIABIXTXOI.
           1ZBCTK •                     1.» XI.
           AirA or :rt» •            360.03 so. H.
           AttA Cr OOIIKI •            (00.12 SO, X>.
        •AX. BACH 8UMBZ1 XI OOCI •       0.0»«


        SiCRtST K03II*  $ x< »• ArVIOXXRATHX CXICBIAI.  1X8X0 TIAISXSXai.
           itian •                     «.ei if,
           AirA cr jmn «            cr0.cz so. z>.
           iiEi or oantt •           292«.».so. :s.
       , IIX. BACH 5VCBZ1 XI ODCT •       0.257
        XURIIT IDKIZB  I IS  A »ICTA»«01>»  IUBZ.
           RII8KT •     •S.SO X.1.
           »IBIH •      et.so z;.
        AU.tIZ VAZtS A» 1X5X0.
        •AS. SACK 70.1BZI IS  30Ct •       0.»1J
              t J03SII .7 XS  A* ArrBOXXRiTZlT CXICOIAI.  HIGIB TIAISITIOI.
           izi9T* •                     e.ai xi.
           AICA or XSLIX «       •    2*2».:: so. xi.
           AltA Or OUTUt •           »ia.!2 S3. XI.
        •AX. BACK lUftUII XI OOCT •       f.372
                                  H-3

-------
         TABLE  A-l.     (Cont.)
 mum jraasz«  i is it mioxxnmiT ciicuui.  XIGIO TIAISITIOK.
    ttlOlK •                      1.32 XH.
    mi cr istiT •            aia.i; so, n.
    mi cr aunt? »           3u.i jiruoxit)A:itx cucoixi. RIGID HAKSITXO*.
   IIK9TH «                     1.S8 I».
   mi or :siir .            1*1.3; so.  IE.
   Jill Cr CDTli: .            132.79 SQ,  ».
•IX. KICK SUKBia III DOCI •       B.J61


tltHtVT BOKBEH 11 IS  1» 1PPIOXI»ATILT CI»CffL»l. ZIGID IlllSIIIOK.
   itiGTH •                     i.ae in.
   itti or rriii .            132. ?r so.  xv.
   lltl CT OVTltT m            14U.OZ SO.  XI.
H». RICH SU.MlZk II OUCI •       0.261


Btintir posjin i:'is  is irrsoxiniicit CI»CBLA». IIGIP idisnioi.
   11»61« •                     1.2Z XI.
   IIEI or xctzi •            100. ez so.  xi.
   nzi cr ounzT •            i6i.ez so.  xi.
•IX. HICH EUriBM IK OOCI «       0.239


ucnsn Kor.sM 13 xs  A> imoxiKitzLi cxscoiii, IIGIS xmmiov.
   itiaix •                     2.C0 ii.
   jiizi or urn .            ie». ft so.  ii.
   Aid Or OUTLET .            210. ZB SO.  XI.
•AX. HICK SVKtti II DOCI •       8.225


SUKZIT I0.1IEH 1U IS  1 «tCI)HaUi»«  IC8Z.
   ICIOIK •      t.33 IK.            A
   •SIGHT »      7.33 IB.
   VXOIK •      te.se is.
ill ZH: kins  11; EIGIO.
•AX. BACK S3I1BZS IE DUCT •       C.Ik*


           D  sin TIC  mssuiz eior  •     •.$•' xi. or «itz»
                       H-4

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                       TABLE A-2

  PREDICTED  ATTENUATION PERFORMANCE  OF MUFFLER
                   FOR EMD GP-35
                    SPL
HUFF
25.
32.
«0.
50.
63.
80.
103.
128.
160.
200.
250.
320.
000.
500.
630.
800.
1000.
1250.
1600.
2000. .
2503.
3202.
4000.
5000.
6390.
6003.
10002.
71. D
70.0
70.0
89.0
79.0
87.5
101.0
99.5
94.0
96.0
101.5
103.0
103.0
1F0.0
103.0
103.0
103.0
103.0
100. 0
12JU.0
10U.0
101.0
98.0
9U.5
92.0
88.0
82.0
' 73.3
73.9
77.7
103.0.
82.9
64.0
92.2
86.4
77.5
77.1
81.5
84.4
91.4
86.3
87.1
90.6
87.1
89.4
82.0
84.1
82.2
77.8
74.3
71,8
70.2
65.8
61.2
  XL

 .2.0
 -3.9
 .7.7
.14.0
 .3.9
  3.5
  8.6
 13.1
 16.5
 18.9
 20.0
 18.6
 11.6
 13.7
 15.9
 12.a
 15.9
 13.6
 22.0
 19.9
 21.8
 23.2
 23.7
 22.7
 21.8
 22.2
 20.8
HUFF(OVEFAL)  s  104,6  DBA
SPL (OVEPAL)  s  114.1  DBA
             i  sotwn  PRESSURE LEVEL  CDPA) WITH MUFFLER
        SPL  I    "       "       »     "   WITH HO MUFFLER
        1L   I  MUFFLER  INSERTION LOSS CDB)
        HUFFCOVF.FAt-)  I  OVERALL DBA WITH «UFFLER
        SPL (OVERAL)  |  OVERALL DBA WITH NO MUFFLER

*LL SOUND PPESSURE  LEVELS  MEASURED AT A DISTANCE OF 2,5 FT
FFOM THE LOCOf.OTIVK EXHAUST  STACK,
                           H-5

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                          TABLE  A-3

DIMENSIONS  AND  PREDICTED BACKPRESSURE  OF MUFFLER
                       FOR  EMD  GP-40
                          SYSTEM PARAMETERS

        VOLUME VCLOCITY •          29000.0*  CO. FT./MIN.
        lEMPERATI'FE •                850.    DEC. T
        fAX. STATIC PRESS. DROP •   2767.97  IN. OF WATER
        KIN. STATIC PPtSS. OPOP •  -2767.97  1*1. OP BATtR
     •   HAX1MU1 K*CH NUMBER •          1.V00
        EXIT CONDITIONS!             FREE FIEtD
        CKGINK RCILtCltOK COtrF, •      ,Mfl
        SOUND VELOCITY, J2F •       108l.ee  FPS


            THE FOLLOWING ELEMENTS APE VSED I!> THIS CASE,


     ELEMENT *0«RER  1  IS AN APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
        ttNCTH •                     1.00 IN.
        AREA OF INLET •             21*.e« S3.  IN.
        APCA OF OUTLET  •            2)2.50 SO.  IN.
     MAX, MACK NUMBER IK DUCT •      •,1«1


     ELEMENT DUMBER  2  IS AN APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
        LENGTH •                     1,00 IS.
        APEA Or IMET •             232.Se SO.  IN.
        AREA or OUTLET  •            2*0.00 so.  IN.
     MAX. KACH NUK4ER IN DUCT •       0.169


     CLEMENT N'lXRER  3  IS AN APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
        IEKCTK •                     l.*0 IN.
        APEA OP IMET •            260.00 SO,  IN.
        AREA OF OUTLET  •        '    30.S.00 SO,  IN.
     MAX. "ACM NUMBER IN DUCT  •       0.1S1


     CbfCNT NUMBER  4  IS AN  APPROXIMATELY CIRCULAR,  RICID TRANSITION.
       tCNCTH •                     0,01 IN.
       AREA Or INtCT »,            IIS.00 SO. .IN.
       AREA or OUTLET  •          aais.p* so.  IN.             . •
     Ml. MACH NUMBER IN DUCT •       0.102


    CLCME«T NUMBER  S  IS  A RECTANGULAR  TUBE.
       LENGTH •      JS.te IN,
       HEIGHT  •      )S.'0 IN.
       WIDTH •      65.CB IN,
    ALL THE bALLS  ARE  HIGID.
    MX. MACH  HU.-BCR IN DUCT •       0,«P


    ELEMENT NUMBER •  IS AN APPROXIMATELY CIRCULAR, RIGID  TRANSITION.
       LENGTH •                      9,01  IN.
       AREA OF  INLET •            2275.e* SO. IN.
       AREA or OUTLFT  «            Jjs.ec so. IN.
    MX. MACH NUMBER IN DUCT •       0.124
                                H-6

-------
                 TABLE  A-3.    (Cont.)
CLEMENT NUMBED  7 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION.
   LENGTH •                     0.75 IN.
   AREA OF INLCT •             115.0* SO, IN.
   AREA OF OUTLET •     •       19*.SB (0. IN.
MM, HACK NUKBER IN DUCT •       0.19S


CLEMMT NUWHCR  I 15 AN APPROXIMATELY CIRCULAR. RIGID TRANSITION.
   LtNCTH •                     0.75 It.
   AREA Or INLET •             1*9.50 SO. IN,
   AREA OF OUTLFT •            159.00 SO. IN,
MAX. HACK NUMBER IN DUCT •       0.247


ELEMENT NUMBER  9 IS A  RECTANGULAR TUBE.
   LENGTH •      1,00 1*,
   HEIGHT •      ».<•« IN,
   WIDTH •      76.5e IN.                   •   '
ALL THE KALIS ARE KICID.
MM. MUCH NUMBER IN DUCT •       6*947

                                                          •
CLEMENT NUKRCR IB IS AN APPROXIMATELY CIRCULAR. RIGID TRANSITION.
   LENGTH •                     1.58 IW.
   AREA Or INLET •             IS9.ee SO. IN.
   AREA or OUTLET •            ti*.00 so, IN,
MAX. r*CH NUKBER IK DUCT •       1,947


ELEMENT NUMBER 11 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
   LENGTH •                     l.fC IN.
   AptA Or INICT •             119,00 SO, IN.
   AREA Or OUTLET •            970,00 SO. IN,
MAI, NACH NUMBER IN CUCT •       0,907


CLEMENT NUMBER 19 IS A  RECTANGULAR TUBE.
   LENGTH *      S.S0 IV.
   HEIGHT •      9.tf« IS.
   WIDTH •      )ttf* IN.
ALL THE WALLS ARC KICID.
MAX, KACH NUMBER IN DUCT •       0.145


   CALCULATED STATIC PRESSURE DROP •     l.U t«. OP HATER
                            H-7

-------
                      TABLE  A-4

PREDICTED ATTENUATION PERFORMANCE  OF MUFFLER
                    FOR EMD  GP-40
                    SPL
25.
32.
«0.
50,
63.
80.
103.
128.
160.
200.
250.
320.
400.
500.
630.
800.
1000.
1250.
1600.
2000.
2500.
3200.
K000,
5000.
6300.
•000.
10000.
71.0
70.8
70.0
89.0
79,0
87,5
101.0
99.5
90.0
96.0
101.5
123.0
103.0
100.0
103,0
103,0
103.3
103.0
10U.0
101*. 0
155U.B
101.0
98,0
9U.5
92,0
88.0
82.0
              HUFF

              69.4
              70.3
              7tt,0
              «9.3
              60.2
              • 1.5
              69.9
              8B.5
              75'. 9
              '5.7
              60.2
              82.6
              418.1
              60,9
              93.5
              90. S
              ee.fj
              86.1
              85.8
              Si).7
              83.1
              81.5
              78.3
              111.9
              73.8
              70.9
              66,6
  XL

  1.6
 .0.3
 .(1,0
.10,3
 -1.2
  6,0
 11.1
 15.0
 18,1
 20,3
 21.3
 29.2
 1tt,9
  9.1
  9.5
 12.2
 15.0
 16.9
 18.2
 19.3
 23.9
 19,5
 19.7
 19.6
 18.2
 17,1
 18,*
MUFr(OVEPAL)
SPL (OVERAL)
s 102', 5 DBA
* 114.1 DBA
        KUFF 1 SOUND PRESSURE LEVEL (DBA)  WITH MUFFLER
        SPL  I   »      "       "     "   WITH NO MUFFLER
        1L   I MUFFLER INSERTION LOSS (DB)
        KUFF(OVEPAL) I OVERALL DBA WITH MUFFLER
        SPL (OVERAL) I OVERALL DBA WITH NO MUFFLER

ALL SOUND PRESSURE'LEVELS MEASURED AT A DISTANCE OF 2.5  FT
FROM THE LOCOMOTIVE EXHAUST STACK,
                          H-8

-------
                                    TABLE A-5

         DIMENSIONS* AND  PREDICTED BACKPRESSURE OF  EXISTING
                            MANIFOLD ON EMD  GP-38
                                   SYSTEM PARAMETERS

                  VOLUME VELOCITY •          9500,00  cu,  rt.
                  TEMPERATURE •               150.    DEC. F
                  MAX, STATIC PRESS, DROP •   2767.97  IN,  OF HATER
                  HIM, STATIC PRESS. DROP •  •2767.97  IN.  OF WATER
                  MAXIMUM HACK NUMBER •          1,000
                  EXIT CONDITIONS!             Tf.ll FIELD
                  CKCINE REFLECTION COtrr. •      ,0»0
                •  SOUND VELOCITY, 32F •       jen.ee  rPs


                      THE FOLLOWING CLEMENTS ARC USED IN THIS CASE. •


               CLEMENT NUMBER  \ IS A RECTANGULAR TUBE,
                  LENGTH •    11.00 IN,
                  HEIGHT •    10.00 IN.
                  WIDTH •     i0.ee IN,
               ALL THE NAILS APE RIGID,
               MAX, KACH NUMBER IN DUCT •       0.121
                                                             •

               CLEMENT NUMBER  2 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION.
               '   LENGTH •                    0,01 IN.
                  AREA OF INLET •     .       100.«0 SO, IN,
                  AREA OF OUTLET •           641,OP SO. IN.
               MAX, MACH NUMBER IN DUCT •       0.121


               CLEMENT NUMBER  J IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
                  LENGTH *                    9,00 IN,
                  AREA OF INLET •            64l.ee SO, IN,
                  AREA OF OUTLET •          1296,00 SO. IN,
               MAX, MACH NUMBER IN DUCT •       0,020


               CLEMENT NUMBER  4 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
                  LENGTH •                    9,00 IN,
                  AREA OF INLET •           1296.06 SO, IN.
                  AREA OF OUTLET •           641.00 SO, IN,
               MAX, MACH NUMBER IN DUCT •       0,020


               CLEMENT NUMBER  S IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
                  LENGTH •                    0,01 IN,
                  AREA OF INLET •            641,00 SO, IN,
                  AREA OF OUTLET *           1»,«0 SO, IN,
               MAX, MACH NUMBER IN DUCT •       0.122


               CLEMENT NUMBER  6 IS A RECTANGULAR TUBE,
                  LENGTH .«    16,00 IN.
                  HEIGHT •     7.08 IN,
                  WIDTH •     15,08 IN.
               ALL THE WALLS ARE RIGID,
               MAX, MACH NUMBER IN DUCT •       0,122


                  CALCULATED STATIC PRESSURE DROP •     1,64  IN, OF HATER
'Dimensions  correspond  to  an  acoustically  equivalent  analog  of
 the  manifold rather  than  the actual  unit.
                                          H-9

-------
                      TABLE A-6

PREDICTED ATTENUATION PERFORMANCE  OF EXISTING
               MANIFOLD ON EMD GP-38
                    SPL
25.
32,
40.
50,
.63,
80.
100,
128,
160.
200.
250,
320,
400,
500,
630.
•00.
1000,
1250.
1600.
2000,
2500,
3200.
4000.
5000.
6300.
8000.
40000.
71,0
70,0
70.0
89.0
79.0
87,5
101,0
99.5
94.0
96.0
101.5
103.0
103.0
100,0
103,0
103.0
103,0
103.0
104,0
104,0
104.0
101,0
98.0
94.5
92,0
88.0
82,0
HUFF

76.4
79.9
74.3
65.9
70.5
74.8
85.0
81.3
75.4
80.9
90,3
83,0
84.8
95,4
92.5
89,3
91.2
86.1
87.7
87.0
85.5
82.5
78.1
T4.0
71.8
68.4
63,5
 XL

-5,4
•9,9
•4.3
 3.1
 8,5
12.7
16.0
18.2
18,6
15,1
11.2
20,0
18,2
 4.6
10.5
13.7
11,8
16,9
16.3
17.0
18.5
18.5
19,9
20.5
20.2
19.6
18.5
 HtiFF I OVERALL DBA WITH MUFFLER
        SPL (OVERAL) I OVERALL DBA WITH NO MUFFLER

 ALL  SOUND PPESSUPE LEVELS MEASURED AT A DISTANCE OF 2,5 FT
 FROM THE LOCOMOTIVE EXHAUST STACK,
                         H-10

-------
                                   TABLE  A-7

      DIMENSIONS*  AND  PREDICTED  BACKPRESSURE OF  SUGGESTED
                    MANIFOLD MUFFLER FOR  EMD  GP-38
                                   SYSTEM PARAMETERS

                  VOLUME VELOCITY •          isea.ee  cu. FT./MIN,
                  TEMPERATURE •               I5B.   DEC, F
                  MAX.  STATIC PRESS, DROP •  2767.97  IN. OF WATER,
                  H1N,  STATIC PRESS, DROP • -2767.97  IN. OF WATER
                  MAXIMUM HACK M1UBER •         I,000
                  EXIT  CONDITIONS!             FREE FIELD
                  tWCINt REFLECTION COCFF, •      ,6«e
                  SOUND VEtOCITt, 12F •      100B.00  FPS


                       THE rOUOHIHG ELEMENTS APE USED IN THIS CASE,


               ELEMENT  "UCBER 1 IS A RECTANGULAR TUBE.
                  LENGTH •    lt.ee IN.
                  HEIGHT •    l*,e* IN,
                  MOTH •     ia,ee IN.                        .
               Alt THE  fcALLS APC RIGID,
               KAX, HACK NUMBER IN DUCT •      •.131


               CLEMENT  NUMBER 2 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION.
                  tENCTM •                    0.01 IN,
                  AREA  OF IKIET •            100,00 SO. IN.
                  AREA  OF OUTLET •           »Jfc.ee SO. IN,
               MAX, MACK NUMBER IN DUCT •      »,12»


               ELEMENT  KUfBER ) IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
                  LENGTH *                    «.«B IN.
                  UREA  OF INLET •            996.00 SO. IN.
                  AREA  OF OUTLET •          2tSS.ee 80, IN,
               KM, MACK NUMBER IN PUCT •      0,114


               CLEMENT  DUMBER 4 IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION,
                  LENGTH •                    f.et IN,
                  AREA  OF IKLET •           2656,88 SO, IN,
                  AREA  OF OUTLET •           9)«.«0 SO. IN.
               MAX. MACH NUMBER IN DUCT •      «t»H


               KUMEKT  NUMBER S IS AN APPROXIMATELY CIRCULAR, RIGID TRANSITION.
                  LENGTH •                •    0.01 IN.
                  AREA  OF INLET •            »J«,00 SO. IN.
                  AREA  OF OUTLET •           105,00 SO, IN,
               MAX. MACH NUMBER IN DUCT •      0.122


               ELEMENT  NUMBER » IS A RECTANGULAR TUBE,
                  LENGTH •    IS.00 IN.
                  HEIGHT •     7,00 IN,
                  WIDTH •     IS.ee IN.
               MI. THE  KALIS ARE RIGID.
               MAX, MACH NUMBER IN DUCT •      0,122


                  CALCULATED STATIC PRESSURE DROP •    •,•• IN, or WATER
'Dimensions correspond to an acoustically equivalent analog  of
 the  manifold muffler  rather than the  unit  as  installed.
                                           H-U

-------
                      TABLE A-8

 PREDICTED ATTENUATION PERFORMANCE  OF SUGGESTED
          MANIFOLD MUFFLER FOR  EMD GP-38
                     SPL
25,
32,
40,
50.
63.
80.
100.
128,
160.
200.
250,
320,
400.
900,
630.
800.
1000.
1250,
1600,
2000.
2500.
3200.
4000,
5000,
6300,
8000.
10000.
71.0
70.0
70.0
89.0
79,0
87,5
101,0
99,5
94,0
96,0
101,5
103,0
103,0
100,0
103,0
103,0
103.0
103.0
104.0
104.0
104,0
101,0
98.0
94.5
92,0
88.0
82.0
             OVERAL
  MUFF

  77.3
  67,3
  61,3
  75.5
  61,4
  66,4
  77,2
  74,0
  68,7
  75,0
  85,3
  80,7
  87,2
  87,3
  85.1
  84.8
  85.2
  86.5
  85.4
  83,5
  82.7
  79.3
  75.0
  71.5
  68,9
  65.2
  60.5

96.1  DBA
                                    •6.3
                                     2.7
                                     8.7
                                    13.5
                                    17,6
                                    21.1
                                    23.8
                                    25.5
                                    25.3
                                    21.0
                                    16.2
                                    22.3
                                    15.8
                                    12.7
                                    17.9
                                    18.2
                                    17.8
                                    16,5
                                    18,6
                                    20.5
                                    21.3
                                    21.7
                                    23.0
                                    23.0
                                    23.1
                                    22.8
                                    21,5
•miFF(OVEPAL) a  96,1  DBA
SPL (OVERAL) a 114.1  DBA

        HUFF I SOtWD  PRESSURE  LEVEL  (DBA) WWH MUFFLER
        •W- 'I   "       "        "     "   WITH HO KUFFLER
        IL   I MUFFLER  INSERTION LOSS (DB)
        HUFF(OVERAt)  |  OVERALL DBA KITH VUFFLER
        SPL (OVERAL)  |  OVERALL DBA WITH NO MUFFLER

ALL SOUND PRESSURE  LKVFLS  MEASURED AT A DISTANCE OF 2.S FT
FPOM THE LOCOMOTIVE EXHAUST STACK,.                  *
                           H-12

-------
                             TABLE  A-9

DIMENSIONS  AND PREDICTED  BACKPRESSURE OF  MUFFLER
                 FOR  GE  U25,  U33, and  U36
                           SYSTEM PARAMETERS

                                  aSMB.ee  CO.  fT./MIN.
                                    ise,    DEC.  r
         MAX, STATIC PRESS,  DROP •   1147, «7  IN,  OF KATER
         "If. STATIC PPESS.  DPOP •  •>?«?. «T  IN.  Of WATER
         MAXI*U« MACM Nu.MKtp •          t.tee
         E.XIT COKOITIO.ISI              run riEto
         EKCINC utr itc: i ON coErr, •      .«««
         SOU»D vrtocm, ar •       ieei.ee  rp*


             T«e rouOkiMC  CLCHCKTS ARC USED IN THIS CASE.


      '"ttKCttl".*"  ' " *" "'l>*0'tI"*TCI>r "RCtftAR, RIGID tRAMItlOII.
         AREA Of IMLCT •             !*».'•* SO? IN,
         •RCA OF OUTiET •            }!•.«« SO, IH.
      MM* HACK ttUKitR IN ODCT •
      CtCMEMT »n«ER  I  IS AN APPROXIDATCl* CIRCULAR, RIGID TRANSITION.
        UN6TH •                     4,ee IM,
        AREA or IMIET •             ais.ee so, IN,
        am or OUTLET  •            JM.ee so, IN,
      MAX. MACN NU««R IN DUCT •       t.Ut
     KU»ENT ^flfSKR   t IS AN APPROXIMATELY CIRCULAR, RIGID TRANSttlO*.
        LENGTH •                     9,91 IN,
        AREA or met •             »••.«« so. IN.
        AREA Or OUTLET •            S?S,»t SO. IN.
     MAX. HACK KURtER IN DUCT •       f.lt)
                                                             *


     CLEMENT NOKSE*  4 IS A RECTANGULAR TUBE.
        lENGTM •    4*. »• IN.
        •EICMT t    |«,0« IN.
        MIDTH •     >b,e« IN.                       •
     Alt THE KALLS ARE RIGID.
          HACK NMHMR IN DtfCT •
             NOM»ER  S IS AN APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
        LENGTH •                     e.ei M.
        AREA Or INLET •            >?•.•• SO, IN.
        AP.EA Or OUTLET •           J0».f« SO. IN.
     MAX* HACK KUMSER IN DUCT •      0.1 II


     ELEMENT NOFBER  S IS AN APPROXIMATELY CtPCULAK,  RIGID TRANSITION.
        LENGTH •                     e.Hl IN,
        AREA Or IKLET •            90S.SS SQ. IN.
        ARCA Or OUTLET •           tit. 04 SO, IN.
     MAX, HACK DUMBER IN DUCT •   •   0,1 JJ
                                  H-13

-------
              TABLE  A-9.    (Cont.)
 CLEMENT kUKBEK  1 IS A RECTANGULAR TUBE,
    ttNGTH «     in.00 IN.
    HEIGHT •     16.00 IN.
 •   WIDTH •      16.00 IN.
 All. THC HALLS APE RIGID,
 MX. HACH MUKBCR IN DUCT •       • ,»*!


 CLEMENT NUMBER  I 18 AN APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
    LENGTH •                      0,ffl IN.
    ARCA OF IKLCT •             »«.P0 SO.  IN.
    AREA or OUTLET •            100.00 so.  IN.
 MAX. KACH NUMBER IK DUCT •       0.11 J


 CLE'CNT HUKBER  * IS AN APPROXIMATELY CIPCULAR,  P.ICID TRANSITION.
    LCNCTH •                      4,fe IN,
    AREA Or INI.CT r             t00,0P SO,  IN,
    Mtr.A or ouTtrT •            asa.ee so.  IK,
 MAX. KACH Nunrc* IN DUCT •       0.119


 CLEMENT NWBEP 10 IS AM APPROXIMATELY CIRCULAR,  RIGID TRANSITION.
    LENGTH •                      4.K* IN.
    APEA Or INLET •     •        2S*.Ce SO.  IN.
    APtA OF OUTLET •            >00.P0 SO,  IN.
 MAX. KACH KUHPC* IN DUCT •       0«l»ff                    .
         *                                                     •

 CLEMENT NUMBER 11  IS A  PCCTANCULAK TUBE.
   LENGTH «     JB.Oit IN,
   HEIGHT •     11,10 IN,
   H1DIH •      11.ft IN,
ALL THE WILLS APE  PlClO.
MAX, HACH'NUnBtR IN  DUCT  •       0.1»«


   CALCULATED STATIC  PRESSURE CROP •     1.41 IN, or NATCR
                             H-14

-------
                    TABLE A-10

PREDICTED ATTENUATION PERFORMANCE  OF MUFFLER
           FOR GE U25, U33,  and U36
                  SPL
MUFF
25.
32.
40.
50.
63.
80.
100,
128.
160.
200.
250.
320.
400.
500.
*30.
800.
100*.
1250.
1600.
.2000;
2500.
3200.
4000,
5000.
'6300.
8000.
10000.
71.0
70.0
70,0
89.0
79.0
87.5
101.0
99.5
94.0
96,0
10.1,5
103.0
103.0
100.0
103.0
103.0
103.0
103.0
104.0
104,0
104,0
101,0
98.19
94,5
92.0
88,0
82,0
82,3
71.1
65,5
81.6
71.7
84.3
91.7
87,3
87,4
84.5
100.5
98.2
91.2
90.2
89.7
87.7
83.9
81,3
80.6
79,0
77,3
73.1
70,2
66,7
65,7
65.4
62,5
  XL

•11.3
 •1.1
  4.5
  7.4
  7.3
  3.2
  .9.3
 12.2
  6.6
 11,5
  1.0
  4.8
 11.8
  9.8
 13.3
 15.3
 19.1
 21.7
 23.4
 25.0
 26.7
 27.9
 27.8
 27.8
 26.3
 22.6
 19.5
 HUFF(OVEPAL)  «  104,1 DBA
 SPL (OVERAL)  *  114.1 DBA

         MUFF  t  SOUND PRESSURE LEVEL (DBA)  WITH MUFFLER
         SPL   I   •      "       "     "   WITH NO MUFFLER
         IL   I  MUFFLER INSERTION LOSS (DB)
         MUFFCOVERAt) | OVERALL DBA WITH MUFFLER
         SPL  (OVERAL) I OVERALL DBA WITH NO MUFFLER

 ALL SOUND PRESSURE LEVELS MEASURED AT A DISTANCE OF 2.5 FT
 FROM THE LOCOMOTIVE EXHAUST STACK.
                        H-15

-------
                    Appendix I




SPACE AVAILABILITY FOR MUFFLERS INSIDE LOCOMOTIVES

-------
                 NOISE LEVELS AND SPACE AVAILABILITY

     In this section, we summarize additional locomotive noise
level data acquired during the course of fhis program and discuss
space availability for the installation of mufflers on a range of
locomotives.  This information is based, in large part, on a num-
ber of field studies that are discussed in detail in Appendices
B, C, and D.

Additional Noise Levels

     Table 4-1 provides idle and throttle 8 data on noise from 12
locomotives.  Several measurements were taken-at sites that were
usually .nonideal because of the unavoidable presence of reflect-
ing surfaces such as cars, other locomotives, and buildings.
However, the data are still of value in that they represent upper
bounds to clear-site locomotive levels.

Space Availability

     The principal factors to consider when determining the space
available for locomotive mufflers are:  (1) clearance space
around and within the locomotive, (2) backpressure generated if
exhaust is ducted to remote locations, and (3) visibility.
     External clearance profiles have been established by the AAR
for various levels of service interchangeability of locomotives
and cars among various railroads and routes (Railway Equipment and
Publication Co. 1973).  The tightest clearance profile which
allows for unrestricted interchange service Is shown in figure 4-L
The dimension of greatest interest is the overall height of 15 ft
1 in. because of the above-hood location appropriate to many  loco-
motives.  A less stringent standard height of 15 ft 6 in. is  suit-
able for use on 95 percent of total mileage in eastern railroads.
                               ! H

-------
                    TABLE 4-1.
SUMMARY OF STATIONARY LOCOMOTIVE NOISE LEVELS
Locomotive
Hfr/Modcl
OM/OP-9
OM/OP-38-2
OM/OP-9
MLW/M-420'
OE/U36C
Road No. 3322
Rated 3600 hp
OE/U36C
Road No. 3322
Rated 3600 hp.
Actual 3564 hp
OE/U34CH
Road No. 3358
Rated 3435 hp,
Actual 3*197 hp
OM/SD45-2
Road No. 3680
Rated 3600 hp,
Actual 3840 hp
OE/U25B
bad No. 2502
Rated 2500 hp,
Actual 2375 hp
Alco/0424
Road No. '2406
Rated 2400 hp,
Actual 1760-2297 hp
(•urging)
PE/U33C
toad No. 3314
Rated 3300 hp.
Actual 3278 hp
OM/OP-9
Road No. 1262
Rated 1750 hp,
Actual 1878 hp
OM/OP-35
Road No. 2556
Rated 2500 hp,
Actual 2424 hp

Lota
Device
Load Cell
Self Load
Load Cell
Load Cell
Self Load
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Noise Level at 100 Ft .
Ambient
-
-
-
-
57 dBA
55 dBA
57 dBA
60 dBA
64 dBA
65 dBA
60 dBA
61 dBA
59 dBA
Idle
67' dBA
66.5 dBA'
69 dBA1
65 dBA1
68 dBA
68 dBA
70 dBA'
66 dBA
70 dBA
72 dBA
69 dBA
68 dBA
69 dBA
Throttle 8
89 dBA1
92 dBA1
89 dBA1
87 dBA1
87 dBA
90 dBA
87 dBA
91 dBA
92 dBA
89 dBA*
90 dBA
92 dBA
86 dBA
Source
Appendix B
Appendix C
Appendix C
Appendix D
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey

'Nonldeai test site, usually becauae of sound-reflecting objects within 100 ft
of locomotive or microphone.
'The Montreal Locomotive Works M-420 model 1* very similar to the Alco C-420
•erlea.
'At 450 rpm. This locomotive can have three. Idling conditions depending on the
electrical requirements (heating, lights, etc.) of the passenger cars.
*Thls test considered not representative since the engine was not developing
full power.
                    ' 1-2

-------
            8   'g
            5  S:?
            g  s'S
            W  K,«
            M  S3
                                                   •IO'-B'-
                                                        •io'-o*-
                                                             •7'-0"-
                            LIGHT CAR CONDITIONS


              CARS Mar BE CONSTRUCTED TO AN EXTREME WO™ CF IO'-»"
              AND TO THE OTHER LIMITS OF THIS OlAftRAM WHEN TRUCK
              CENTERS 00 NOT EXCEED 4l'-3"ANO WHEN, WITH  TRUCK
              CENTERS OF 4i'-3", THE SWINOf'iT AT ENDS CF CAR DOtS
              NOT EXCEED THE SwiNOOUT AT CC'i'LR OF CAR ON A U*
              CURVE;  A CAR TO THESE DIMENSIONS IS DEFINED AS THE
              BASE CAR.
                         WHEN  TRUCK  CENTfRS EXCEED 4l'-3',
              CAR WIDTH  FOR  ENTIRE CLEARANCE OUTLINE SHALL BE
              REDUCED TO COMPENSATE FOR THE INCREASED SWINGOUT AT
              CENTER  AND/OR ENDS OF CAR ON A 13* CURVE SO THAT THE
              WIDTH OF  CAR  SHALL  NOT PROJECT  BEYOND  THE
              CENTER  OF TRACK MORE THAN THE BASE CAR.

              MAXIMUM CAR WIDTHS FOR VARIOUS  TRUCK CENTERS, AT CENTER
              OF  CAR,  ARE SHOWN ON PLATE  6-1. MAXIMUM CAR WIDTH  AT
              LOCATIONS OTHER THAN CENTER OF CAR ARE  SHOWN ON PLATE  0.

              W. nillLT PRIOR TO 1948 WtTit DOOR FIXTURES. HANDHOLDS, ETC.,
              mojEcmr, Btvorio lo-ir ixTRtMn WIDTH, BUT HOT I.IYONO lo'io"
              WILL PE  COHMDtRLU A3 IttETKIG THE RLQU1RCKUIT& CF  CAR SCRV1CE
              RULE !0-2(e).


              CARS WITH RAIL  LOADS IN EXCESS OF  69.7SOLBS. PER AXLE
              CANNOT  DE OPERATED IN UNRESTRICTED INTERCHANGE. HOWEVER,
              THEY MAV BE PERMITTED UNDER CONTRCxLEO CONDITIONS
              WHERE SPECIAL AGREEMENT  HAS BEEN REACHED BETWEEN
              PARTICIPATING  RAILROADS TO SO CANDLE,
                                   THE 2-1/2" ABOVE-TOP OF RAiL  I? ABSOLUTE MINIMUM
                                   UNDER ANY AND ALL CONDITIONS OF  LADING, OPERATION.
                                   AND MAINTENANCE.

                                   All NEW OR REBUILT CARS SHOULD BE so  DESIGNED THAT NO
                                   fART OF CAR SMALL BE LESS THAN Z-3/4" ABOVE  THE TOP OF
                                   • THE RUNNINO RAIL UNDER ALL ALLOWABLE  WEAR  AND SPUING
                                   DEFLECTION CONDITIONS. THOSE ROADS USING MULTIPLE  WEAR
                                   WHEELS MAY FIND IT NECESSARY, IN MAINTAINING  THE 2-9/4*
                                   MINIMUM CLEARANCE. TO COMPENSATE FOR  WHEELS WORN
                                   CLOSE TO THE CONDEMNING LIMIT BY REPLACING WHEEL.  AND
                                   AXLE SET*, BEARINGS OK WEDGES, ,
FIGURE   4-1.
RAILROAD  CLEARANCE
Clearances   (1973).
DIAGRAM.    SOURCE:    Railway  Time
                                                     1-3

-------
Western railroads often use higher equipment.  For example, the
Burlington Northern operates GP-38 and GP-40 locomotives that are
6 ft from top-of-rail  (Burlington Northern Railroad Co.).  Since
the 15-ft 6-in. clearance height applies so widely, it is the one
we shall use in evaluating the above-hood space.
     Backpressure requirements are usually sufficiently stringent
to preclude remote location of mufflers at the ends, or possibly
the sides, of locomotives.  Backpressure accrues from flow through
the ducting from the top of the engine to remote locations.  Ac-
cordingly, we consider applying mufflers only above the engine,
either above or below the locomotive hood.
     It is generally stated that switchers need their low hoods
for visibility and that mufflers would interfere with this vis-
ibility.  Yet visibility does not seem to be an essential factor,
as is shown by the frequent use of high-hooded GP-7-and GP-9 lo-
comotives as switchers.  Also, the volume of the muffler can be
distributed over the length and breadth of the hood, so that the
vertical dimension need not be large.  For example, a muffler
having the same volume as the Maxim MSA-1 for a 12-cylinder EMD
645E engine (42.4 ft3) could be built to have dimensions of 5 ft
in width, 10 ft in length, and less than a foot in height.  Such
a muffler would easily fit over the hood of an EMD SW1500 switch-
er with minimum visibility interference.
     One of the very real problems of evaluating space availabil-
ity is the large number of locomotive types.   Before considering
many of these types in detail, let us consider some of the gener-
al geometries of road- and switcher-type units.
     The most common road locomotive is the high-hood type, with.
a cab that protrudes on each side for purposes of fore-and-aft
visibility.   An example of this type of locomotive is the General
Motors GP-9, shown in figure 4-2  (Pinkepank,  1973).  These  locomo-
tives have only limited space above the hood for the installation
of mufflers.
                               1-4

-------
L/l
                                               Reprinted with permission  from the Second Diesel Spotter's
                                            Guide, Jerry  A.  Pinkepank, © 1973 by Kalmback Publishing Company,
                                            Milwaukee,  WI.   Photo by Louis A. Marre.
                      FIGURE 4-2.   GENERAL MOTORS  GP-9  LOCOMOTIVE.

-------
     A  second type of road locomotive structure is represented by
the General Motors F9A locomotive illustrated in  figure 4-3.  Al-
though  this locomotive is more streamlined than the GP type, it
does not have rearward visibility and cannot easily be run back-
wards.  Accordingly, it has not been popular and  has been out of
production for about 15 years, although about 1500 of these loco-
motives are still in service.  The F-type locomotives also have
limited above-load space for muffler applications.
     Switcher locomotives are quite another matter.  The General
Motors  Sw.1000 switcher, illustrated in figure 4-4, shows that
there is nearly 3 ft of vertical space above the  hood (Burlington
Northern Railroad Co.).  There is also a substantial amount of
space rearward and laterally.

     A detailed evaluation of space availability  Is given in
Table 4-2.  This table applies to locomotives in  service at the
beginning of 1974; the population data were obtained from Osthoff
(1974).  Note that switchers* have from 2^ to 4 ft of height
above the hood, which is adequate for the installation of muf-
flers.  Certain road locomotives such as the GP-9 have as much as
2 ft of space above the hood for which a muffler  could be de-
signed.  Also, some of these locomotives have below-hood space
for an expanded exhaust manifold that would reduce noise emis-
sions.
     The preceding discussion of available space  is based largely
on inspection of the interior plans of a large number of locomo-
tive models and, in some cases, on visual inspections of the lo-
comotives themselves.  In all cases, Judgments of space available
were based on the locomotive configuration as delivered by the
manufacturer.   It is possible that some locomotive users have
modified the internal arrangements of their units in ways that
*GM designation NW and SW; Alco designation S and RS.
                               1-6

-------
                        Reprinted with permission from the Second Diesel  Spotter's
                    Guide,  Jerry A. Pir.!o3pank, ©1973 by  Kalmback Publishing Company,
                    Milwaukee, WI.  Photo"by Louis A. Marre.
FIGURE 4-3.   GENERAL MOTORS  F9A  LOCOMOTIVE.

-------
            FI6URE 4.4.  EMD SW. 1000 - 1000 hp LOCOMOTIVE.

would hamper muffler installation, such as by rerouting cables or
piping.  Such components would have to be moved to permit muffler
installation.  The number of locomotives in which this may be a
problem is unknown; it could only be determined by a detailed
unit-by-unit survey.
                               1-8

-------
                 TABLE 4.2
LOCOMOTIVE SPACE AVAILABILITY AND POPULATION
Model
END NW2
NW3
NW5
SW1
SW8
SW600
SW900
SW7
SW9
SW1000
SW1200
W1500
F3
F7
OP7
SD7
P9
QP9
SD9
OP18
GP28
QP38
SD38
GP20
SD21
Space for Muffler
Length/Width/Height
(Dimensions In Inches)
Under Hood



*









Enlarge exhaust
manifold to
27 in. diam.
Enlarge exhaust
manifold to
27 in. diam.

Enlarge exhaust
manifold to
27 in. diam.
Enlarge exhaust
manifold to
27 in. diam.

Enlarge exhaust
manifold to
27 in. diam.
Enlarge exhaust
manifold to
27 in. diam.


Above Hood •
-/72/42»(±6)

-/72/422(±6)
-/72/462(i6)
-/72/422(±6)
-/72/422(±6)
-/72/4o2(±6)
-/72/422(±6)
-/72/422(±6)
-/72/352(±l/2)

-/72/362{±6)
-/8Vl8'(±6)
-/84/i72(±l/2)
-/8«iyi92(tl/2)
-8J»/19*(±l/2)
-/8Vl72(tl/2)
-/8»J/2l»2( + l/2)
-/8V182(±6)
-/84/2l2(±6)
Insufficient3
Insufficient'
-/84/l82(t6)
-/8V -'
No. in
Service*
as of
1/1/74



684




2626

685

36H5



388U

400
1886

200
295
                      1-9

-------
                      TABLE 4.2   '
LOCOMOTIVE SPACE AVAILABILITY AND POPULATION (Cont.)
EMD GP30
SD30
GP35
SD35
OP39
GPl»0
SD40
F15
SD45
QE U25
U28
U23
U30
U33
U36
U18
U50
Alco S1.S3,
S6.S2.S4
RS1.RSD1
T6
RS2.RSG-2
. PA1.PB1
RS3.RSD5
FA/B-2
RS11.12
CH20
DL109
PA1
37/72/36*
36/72/32*
>
48/72/32*
18/72/32*
48/72/36*
163/35/16"
163/35/16"
130/35/16"
163/35/16"
163/35/16"
180/35/16"
97/35/16"
163/35/16"



lHk/H2/2H*
11V12/21*
Insufficient'
Insufficient3
Insufficient1
-/84/l82(±l/2)
Insufficient
Insufficient3
Insufficient3








-/-/48
-/-/30
-A/30

•
1196
1583
92
2702
1652
552
201
28?
677
522
63
65
60
80
579
111)

362
156
                          MO

-------
                         TABLE 4.2

    LOCOMOTIVE  SPACE  AVAILABILITY AND  POPULATION  (Cont.)
RSD15
Cl|2l» •
CH25
C628
C630
0*130
1W42/246
1W42/21I6
192/M2/186
192/42/186
1W42/186
• . 107
84
131
81
Source:   Osthoff (1974).
2Estimated from diagrams  in Burlington Northern (undated).
 Numbers  in parentheses designate estimation tolerance.
'"Insufficient" is used when space above hood appears to be
 12 in.  or less.
"Strictly speaking, this  much space is not available under the
 hood.  The center section of the hood would have to be  raised
 to accommodate a muffler.
5Estimated from diagrams  in Burlington Northern (undated) and
 General  Motors Corp.  (1974).  Extended range dynamic brakes
 are discussed where appropriate.
'Obtained from drawings supplied to BBN by Montreal Locomotive
 Works,  Montreal, Canada.
                              HI

-------
                        Appendix J

LOCOMOTIVE NOISE MEASUREMENTS TAKEN IN CONJUNCTION WITH HARCO
    MANUFACTURING COMPANY AND ADDITIONAL MEASUREMENTS

-------
                           APPENDIX *
       MEETING WITH HARCO AND LOCOMOTIVE NOISE MEASUREMENTS

     On Tuesday, 21 January 1975$ several EPA personnel* and Dr.
Erich Bender of BBN met with Mr.  Frank N. Harris, Manager of
Harco Manufacturing Co., to discuss Harco's activities in locomo-
tive silencing.  We also measured the noise of several Union
Pacific locomotives under various conditions.  In this appendix,
we (1) discuss the noise measurements of a GP-9 locomotive in
three exhaust-silencing configurations, (2) present noise data on
a GP-38-2 locomotive, and (3) identify some salient aspects of
Harco's productive capacity.

Noise Measurements -  6P-9
                                                   •
     During the afternoon of 21 January 1975» noise measurements
were made on a Union Pacific GP-9 locomotive  (#246) in the Union
Pacific yard on Swan Island, Portland.
     Test Site.  Figure C-l is a sketch of the test site.  The
locomotive was connected electrically to a General Electric load
cell, and the microphone was located 100 ft'from the track cen-
terline between two parallel rows of truck trailers, spaced about
82 ft apart.  The large end wall of a locomotive shop was located
approximately 50 ft from the locomotive, as  indicated.  The day
was clear, the temperature about 50° F, and  the wind very light.
Because of the shop wall and trailers, this  site is not suitable
for certification-type tests but Is appropriate for comparative
tests of mufflers.
*Dr. Alvin Meyer, Mr. Henry Thomas, Dr. William Roper, Mr.
 Jeffrey Cerar.
                                II

-------
                                 BUILDING
        \X\\\\\\\K\\\\\\\V;
           TRUCK
         TRAILERS
100'I
                                  LOCOMOTIVE
                            S/4///////\
                            jj^^^^^^^jjg^^^fl
TRUCK
TRAILERS
                       K-30'-*
   1 MICROPHONE
    	42'—J
                 FIGURE  C-l.  TEST  SITE.

     Instrumentation.  For all measurements on this locomotive,
A- and C-scale levels were read directly  from a P&K Model 2203
Sound Level Meter equipped with a B&K Model 41^5 1-in. microphone
and recorded (linear scale) for subsequent analysis of a Kudelski
Model Nagra III tape recorder.  Before and after the sequence of
measurements, the system was calibrated with a B&K 4220 piston-
phone.
     Mufflers.   The performance of two different muffler types
was investigated.  The first mufflers, called "snubbers," are
sketched in figure C-2. They are designed to fit between the car
body and the engine.  The  exhaust gas flows through a perforated
sheet metal liner into a cylinder and back through the perfor-
ated metal before exiting.  The second, called "cross-mounted
                             J-2

-------
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FIGURE C-2.  SNUBBER-TYPE MUFFLER.
               J-3

-------
mufflers," are designed to fit above the car body but within the
clearance envelope.  Figure C-3 is a sketch of the outside of the
cross-mounted mufflers.  Their operation is similar to that of
snubbers in that all of the flow is forced through a perforated
inner lining.
     It should be recognized that the snubber type of muffler in
which exhaust gases are forced through perforated material is
generally not used in other engine silencing applications.  The
reason is that substantial backpressures are generated.  Muffling
is done more efficiently by allowing the bulk of the exhaust gas
to flow through a perforated tube, which attenuates sound because
only little flow passes through the perforations (see sketch
below).
                          MUFFLER SHELL
                                                    PEFORATED
                                                   'TUBE
                                                      FLOW
     Cost Estimates.   Although costs have not been estimated by a
detailed manufacturing analysis, Mr. Harris offered the following
estimates:
        snubbers:   less than $500 for a set of 2 required for a
                   single locomotive
                               J-4

-------
175/16"
                                 72"
                                x
                                             c
                                             8 HOLES 1/2
            FIGURE C-3.  CROSS-MOUNTED  MUFFLER,
                                 J-5

-------
      •   cross-mounted:   about  $750 per  locomotive,  or  about  $1000
                         per  locomotive  when  integrated with  spark
                         arresters.
      Life  Factors.   Since Harco's locomotive mufflers  are  still
 developmental,  data  are  not  presently available  on  their durabil-
 ity.  However,  several observations were made  on spark arresters,
 which attach  to a locomotive stack in much the same way as a muf-
 fler.  First, the primary source of failure  appears to be  fatigue
 of  flat  sections, which  resonate.  The  cure  is to raise the  reso-
 nant  frequency  by means  of stiffeners or by  curving each sheet
 metal element.  Corrosion occurs on the outside  and only if
 painting is not performed with  sufficient frequency.   The  inter-
 ior tends  to  be protected by an oily coating generated by  the
 engine.  Harco  personnel expect their spark  arresters  to last a
 minimum  of 5  years.
      Noise Data.  Noise  levels for the  locomotive equipped with
 mufflers were measured at all throttle  settings;  only  throttle 1
 and 8 settings  were  tested with the unmuffled  locomotive.
      A and C  scale levels for all noise measurements are shown in
'figure C-4.  The following observations may  be made:
      1.  The  snubbers provide virtually no noise  reduction com-
 pared with the  unmuffled locomotive.  In fact, the  A-weighted
 level at throttle 8  is actually higher without the  snubbers  than
 with  them.  The reason may be that one  set of  doors on the loco-
 motive was inadvertently left open while the snubbers  were being
 measured.  These doors were  closed during tests with cross-
 mounted  mufflers and with no mufflers.
      2.  The A-weighted level increases more rapidly than  the
 C-weighted level with increasing throttle setting.  The reason is
 that as  the engine operates  at increasingly  higher  speeds, the
 noise and  vibration  shift to higher frequencies where  less atten-
 uation is provided by the A-weighting network.
                               J-6

-------
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                        THROTTLE .SETTING
                                            8
FIGURE C-4
PERFORMANCE OF HARCO MUFFLERS  AS  A FUNCTION  OF

THROTTLE SETTING.
                                J-7

-------
      3.   The cross-mounted mufflers 'enable  the  locomotive  to meet
 the proposed 87-dBA  throttle  8  standard,  but  exceed  by  0.3 dBA
 the 67-dBA throttle  1  standard.
  \
      Extraneous  Factors.   Two extraneous  factors may have  caused
 the measured noise level  to be  higher  than  the  level that  would
 have been measured under  ideal  conditions.  They are (1) the
 pressure  of a reflecting  shop wall and (2)  reflections  from two
 rows of parked truck trailers.  Estimates of  the effect of each
 follow.
      Reflecting  Shop Wall:. The level  of  the  sound reflected from
 the shop  wall may be estimated with the assistance of the  follow-
 ing sketch.
    MICROPHONE
                                          BUILDING
                                            50' - H
SOURCE
The sound reflected from the wall may be thought of in terms of
an "image source," Identical to the actual locomotive but located
50 ft behind the wall location, with the wall removed.  This
sound propagates over the top of the locomotive and is diffracted
down toward the microphone.  Attenuation of the reflected sound
comprises two parts:  spreading and diffraction.  Because the re-
flected sound travels 200 ft (compared with 100 ft in the direct
path) to the microphone, the spreading accounts for a 20 log
(200/100) = 6-dB reduction in level.
                               J-8

-------
     Computing the shielding provided by the locomotive is more
detailed.  First, we compute the number N given by
where A is the distance from the top of the locomotive to the
microphone (/lOO* + 11* = 100.65); B is the distance from the top
of the locomotive to the top of its image (100 ft), d is the
straight-line distance from the top of the image to the micro-
phone (/200Z + llz a 200.3025), and X is the wavelength of sound
at frequencies of interest.
     Using the above parameter values and noting that A = 1100/f ,
we find
                    N *= 0.55 * 10"s f  .                     (c-l)
By using Eq. C-l and Figure 7-8 of Beranek (1971), we derive
the attenuation curve labeled "locomotive shielding" in
figure C-5.  Note that shielding is more effective at high
frequencies than at low frequencies.
     To obtain the actual sound spectrum produced at the micro-
phone by the image source, we proceed in two steps.
     1.  Apply  the locomotive shielding curve to the A-welghted
octave-band locomotive spectrum shown in figure C-5,* compute the
spectrum of reflected sound, add the octave-band levels of each
spectrum to obtain the overall A-weighted levels,, then take the
difference between the two levels to find the overall attenuation
from shielding.  The result is approximately 10 dBA.
•This spectrum is an average of the spectra corresponding to the
 three silencing configurations listed previously, with the loco-
 motive operating in throttle setting 8.
                               U-9

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                           ESTIMATED OCTAVE BAND

                           SPECTRUM WITH SHIELDING
                    MEASURED 1/3 OCTAVE BAND

                    SPECTRUM
                         LOCOMOTIVE SHIELDING

                         (RIGHT HAND SCALE)
                                                      	-OCTAVE BAND

                                                      V  SPECTRUM WITHOUT
               \
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      16    31.5    69    125    250   500   1000  2000  4000   8000  16,000 31,500


                    ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
    FIGURE  C-5.   COMPUTATION OF THE EFFECT OF LOCOMOTIVE SHIELDING ON REFLECTED

                 SOUND LEVELS (EXPLANATION IN TEXT).

-------
    .2.  Add the 6-dBA spreading loss to the 10-dBA shielding
loss.   The result is that the sound reflected from the shop wall,
as measured at the microphone, is 16 dBA less than the sound prop-
agating directly to the microphone.  This wall reflection thus
adds approximately 0.1 dBA to the direct level.  Or, if the wall
were not present, the level at the microphone would be 0.1 dBA
less than measured.  The presence of the wall therefore produces
a negligible contribution to the measured noise level.
     Parallel Rows of Truck Trailers;  Sound from the locomotive
is reflected or scattered from each of the trailers in parallel
rows running perpendicular to the track.  This scattered sound
adds to the sound propagating directly from the locomotive to the
microphone, causing a higher level to be read than if the trucks
were absent.
     At very low frequencies the sound is scattered- nearly uni-
formly in all directions.  (See following sketch.)  However, at
high frequencies the sound is reflected specularly, much like
                      INCIDENT
INCIDENT
                                   TRUCK
                                   TRAILER
                    SCATTERED
                                                   REFLECTED
                               J-ll

-------
light from a mirror.  The transition frequency ft occurs approx-
imately at ft = c/Tfi = 1100/ir«8 * 45 Hz.  Since most of the A-
weighted acoustic energy is in frequency bands at least a decade
above f. , it is reasonable to consider a specular reflection
       T/
model.
     The problem now is to estimate the spreading attenuation
from the increased distance of sound travel and the portion of
the locomotive "seen" from the microphone, imagining the trailer
ends to be mirrors.  The expression for this attenuation A is
given by
              10 log 10°2 *        + 10 log
                         1002               ^visible

where d is the perpendicular distance from the line, connecting
the microphone and locomotive center to the trailer ends and a
refers to the locomotive area.  Since the bottoms of the trailers
are approximately 4 ft off the ground, are 8 ft wide, arid are
Separated by approximately 5 ft, and the locomotive is 15 ft
high:
          a
           total     15    8+5
                           ~~
For the left row of trailers, d = 30 ft and A = 4.8 dB.  For the
right row of trailers, d = 42 ft and A = 5.8 dB.  Together, the
scattered sound level is only about 2.2 dBA lower than the di-
rect level.  Thus the measured level can be approximately 2 dBA
higher than the level that would exist in the absence of the
trailers.
                               J-12

-------
Noise Measurements - GP-38-2

     Noise levels of a GP-38-2 locomotive were measured under
self-load conditions outside a large shop, as indicated in the
following sketch.
           BUILDING
                   /
                   /
                   /
                   /
                   /
                         MICROPHONE^-
      •75-
                      100
                     LOCOMOTIVE
     Because of reflections from the sides of the shop, the mea-
sured noise level is expected to be higher than that which would
be measured in free-field conditions.  Attenuation A of the re-
flected wave is estimated from
              10 log
100
                            (2d)2
                         100
where d » 75 ft and A « 5.1 as.  Therefore, the measured  level  is
about 1.2 dB higher than the free-field level.  The measured and
corresponding estimated values of free-field levels are shown in
Table C-l.
                               J-13

-------
                            TABLE C-l
                  VALUES OF FREE-FIELD LEVELS
                     Measured Level
                           dBA
             Estimated Free Field
                 Level - dBA
     Idle
66.5
65.3
     Throttle 8
92
90.8
Marco's Productive Capacity

     The Harco Manufacturing Co.  is a rather small organization
with approximately 15 to 25 personnel and about $1 million in
sales.  However, Mr.  Harris claims to have the capacity to de-
liver up to 6000 muffler units/year (enough for 3000 locomotives)
by entering into a licensing or subcontracting arrangement with
the Portland Wire and Door Co.   This muffler production would be
sufficient to equip more than 20 percent of the present locomo-
tive fleet in a 2-year period.
                               J-14

-------
                    TABLE 4-1.
SUMMARY OF STATIONARY LOCOMOTIVE NOISE  LEVELS
Locomotive
Mfr/Model
OH/OP-9
OM/GP-3B-2
OM/cr-9
MLW/M-420'
CE/U36C
Road No. 3322
Rated 3600 hp
OE/U36C
Road No. 3322
Rated 3600 hp.
Actual 3561 »P
OE/U34CH
Road No. 3358
Rated 3)135 hp,
Actual 3097 hp
OM/SD45-2
Road No. 3680
Rated 3600 hp.
Actual 3840 hp
OE/U25B
Road No. 2502
Rated 2500 hp,
Actual 2375 hp
Alco/C424
Road No. '2406
Rated 2400 hp,
Actual 1760-2297 hp
(•urging)
OE/U33C
Road No. 3314
Rated 3300 hp.
Actual 3278 hp
OM/OP-9
Road No. 1262
Rated 1750 hp,
Actual 1878 hp
OM/OP-35
Road No. -2556
Rated 2500 hp.
Actual 2424 hp

Load
Device
Load Cell
Self Load
Load Cell
Load Cell
Self Load
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Load Cell
Noise Level at 100 Ft
Ambient
-
-
-
-
57 dBA
55 dBA
57 dBA
60 dBA
64 dBA
65 dBA
60 dBA
61 dBA
59 dBA
Idle
67' d3A
66.5 dBA1
69 dBA1
65 dBA1
68 dBA
68 dBA
70 dBA'
66 dBA
70 dBA
72 dBA
69 dBA
68 dBA
69 dBA
Throttle 8
89 dBA1
92 dBA1
89 dBA1
87 dBA1
87 dBA
90 dBA
87 dBA
91 dBA
92 dBA
89 dBA*
90 dBA
92 dBA
86 dBA
Source
Appendix R
Appendix C
Appendix C
Appendix D
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
State of
New Jersey
.
'Nonldeal test alte, usually because of sound-reflecting objects within 100 ft
of locomotive or microphone.
'The Montreal Locomotive Works H-420 model Is very similar to the Aleo C-4JO
serlts.
'At 450 rpm. This locomotive can have three Idling conditions depending on the
electrical requirements (heating, lights, etc.) of the passenger cars.
'This test considered not representative since the engine was not developing
full power.
                      J-15

-------
                    Appendix K




EXHAUST NOISE MEASUREMENTS FOR THE GP-9 LOCOMOTIVE

-------
                           APPENDIX K
       EXHAUST NOISE MEASUREMENTS FOR THE GP-9 LOCOMOTIVE

     The exhaust noise signature of a GP-9 locomotive was mea-
sured during a visit to the B&M service plant at North Billerica,
Mass, on November 26, 1971*.
     Sound pressure levels were obtained 2.5 ft away from one (of
two) exhaust stack outlets and 100 ft away from the side of the
locomotive.
     The data acquisition equipment consisted of the following:
     •  B&K-4220 pistonphone, Serial No. 221359
     •  microphone wind screen
     •  GR-4134 1/2 in. microphone, Serial No. 103016
     •  GR-1560 P42 preamplifier Serial No. 492
     •  BBN power supply for the P42
     •  GR-1551B sound level meter, Serial No. 289
     •  Nagra IIIB Kudelski Tape Recorder, Serial No. 621789.
     Figure B-l is a rough sketch of the structures in the vicin-
ity of the locomotive.  It. was not possible to move the  locomo-
tive away from all reflecting surfaces to achieve ideal  hemi-
spherical space conditions.  However, most of these surfaces were
far anough away so that any resulting discrepancies are  expected
to be minimal.  There were about 4 in. of snow on the ground sur-
rounding the locomotive.
     A sketch of the microphone positions for the 2.5-ft measure-
ments is shown in figure B-2.  The overall levels in both the  lin-
ear and A-scale were monitored in all three positions indicated
in figure B-2, and no  significant differences were observed.
                                K-l

-------
STATIONARY
   CAR
                                   MICROPHONE
SERVICE
PLANT
• | l s'
1 ' i
. i^n1 .

PT
100' r
I/
( o o | R

c x n
V^ s~

GP-9"ON"
^GP-9"0
* I— I
a o rh
— i — i—


                          STATIONARY
                             CARS
FIGURE B-l.   LOCATION OF GP-9 LOCOMOTIVE DURING FARFIELD
             (100  FT) MEASUREMENTS OF EXHAUST NOISE.
                             K-2

-------
                TOP VIEW OF LOCOMOTION
                          M

                        ^MiMl^H^^ ^•MBMB



                h-25'—|H5%|  I
                                     C
                                    -*
             • DESIGNATES PRIMARY MICROPHONE

              POSITION

             C DESIGNATES MICROPHONE POSITION

             * FOR SIDE-TO-SIDE CHECK MEASUREMENTS
            _L
            10"
C
*
M
C
*
                              	r\
               VIEW ALONG LOCOMOTIVE AXIS
FIGURE  B-2.  MICROPHONE POSITION  FOR NEARFIELD MEASUREMENT

            OF EXHAUST NOISE.
                          K-3

-------
     Figures B-3 through B-5 contain the 1/3-octave band spectra
at idle, throttle 8 with no load, and throttle 8 with full load,
respectively, corresponding to the 100-ft position.  Figures B-6
through B-8 contain the same information for the 2.5-ft position
recorded at position B (figure B-2).
     The relatively short distance of 2.5 ft from the stack out-
let ensures that the recorded sound pressure level L  (2.5 ft)
                                                    O
corresponds solely to exhaust noise. ' To estimate Lg (100 ft),
that is, the contribution of the exhaust to the noise level at
100 ft, we assume spherical spreading and then use


     AL «= L  (2.5 ft) - L  (100 ft) = 20 log [Pi-4r-l - 32 dB .
           s             s                   \. t. • j i\> \
     Strictly speaking, the value of AL should be decreased by
3 dB because the far field will also contain the contribution of
the second stack.  At the same time, AL should be increased by a
similar amount because of partial shadowing; therefore, the two
effects cancel each other partially, and the assumed AL = 32 dB
is expected to offer a good estimate of L_ (100 ft).
                                         s
     The estimated spectrum L_ (100 ft) is compared to the actu-
                             S
ally measured noise spectrum in figure B-9.  Both traces corre-
spond to a throttle 8 with full load'setting and follow each
other fairly well, a positive indication that the farfield noise
is primarily due to exhaust.  The trend is also quite similar at
throttle 8 with no load and at idle.
                               K-4

-------
en
                                                                GP-9
                                                                IDLE
                                                                TOO FT. FROM SIDE
                                                                OVERALL LEVEL:
                                                                       80.5 dB LINEAR
                                                                       67.0 dBA
                  16    31.5    63    125    250    500   1000  2000  4000  8000  16,000  31,500

                                 ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
                      FIGURE B-3.  6P-9, IDLE, AT  100 FT.

-------
    100
u
3
90
UJ
     40
GP-9
THROTTLE 8s NO LOAD
100 FT FROM SIDE
OVERALL LEVEL'92.5 dB LINEAR
              83.0 dBA
                   63    125    250   500   1OOO  2000  4000   80OO  16,000 31,500

                     ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
         FIGURE B-4.  GP-9, THROTTLE 8, NO LOAD,  AT 100 FT.

-------
                                      GP-9
                                      THROTTLE 8-.FULL LOAD
                                      100 FT FROM SIDE
                                      OVERALL LEVEL:
                                              99 dB LINEAR
                                              89dBA
            63    125    250    500   1000  2000  4000   8000  16,000 31,500

              ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
FIGURE B-5.  GP-9, THROTTLE 8, FULL LOAD, AT 100 FT.

-------
s
           UJ
           a:


           V)
           2s
           i
           (O
           CD
           o
           a:
           o
IIV
100
^ 90
o
.O
4.
8 80
0
2 70
60
50
1 1

. r
j

r
i
^_L 1
I
••M

1
Lr

r
i —
i
i
l
i
i
i
«-«i
J
* «
16 31.5
1 1
L

<— i r
• !--•
-J

.
1 1
LIN
^1
l
.
r
dBA



i i
EAR
T-J 	
r-J
i
...^


i i





i i




i i

i i

i i

GP-9
IDLE
2.5 FT. FROM EXHAUST
OVERALL LEVEL:
106 dB LINEAR
90 dBA



_..i






--— i
f— i










H

63 125 250 500 1000 2000 4000 800O
ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
L.
i i




i^M

16,000 31,500
             FIGURE  B-6.  GP-9,  IDLE,  AT 2.5 FT.

-------
s
               120
               110
           UJ
           i
           8
           £
           O
           =3
           (O
  ~KX>
  5

  X 90
m
             CD
             2  80
           O
           O
           UJ
           o
               70
               60
                   J	I
I
I
i i
             i	i
i	i
                                      6P-9
                                      THROTTLE 8'NO LOAD
                                      2.5 FT FROM EXHAUST
                                      OVERALL LEVEL022.5dB LINEAR
                                                   110  dBA
j	i
                                         Ll
rrn
                                                  i  i
      16   31.5    63    125    250    500   1000  2000  4000  80OO
                    ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
                                                                            16pOO 31,500
                    FIGURE B-7.  GP-9, THROTTLE 8,  NO LOAD, AT 2.5 FT.

-------
   130
                                              6P-9
                                              THROTTLE 8'FULL LOAD
                                              25 FT FROM EXHAUST
                                              OVERALL LEVEL 020 dB LINEAR
                                                            120 dBA
                              250   500   1000  2000  4000  8000  16,000  31,500

                    ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
FIGURE B-8.   GP-9, THROTTLE 8, FULL LOAD,  AT 2.5 FT.

-------
       31.5
63    125    250    500   1000  2000  4000  8000  16,000 31,500
  ONE-THIRD OCTAVE BAND CENTER FREQUENCY (Hz)
FIGURE B-9.  COMPARISON OF ESTIMATED AND ACTUALLY  MEASURED NOISE SPECTRA.

-------
                     Appendix L

TRIP TO MONTREAL LOCOMOTIVE WORKS AND MEASUREMENTS OF
                  M-420 LOCOMOTIVE

-------
                           APPENDIX  L
               TRIP TO MONTREAL  LOCOMOTIVE  WORKS

     On October 2,  1974,  BBN personnel traveled to Montreal,
Canada to visit the Montreal Locomotive Works (MLW) ,  formerly a
division of Alco Products but presently owned (52 percent of  its
stock) by Studebaker-Worthington.   Though MLW owns all Alco
Products' engineering designs, the firm presently manufactures
locomotives of its  own design, primarily for customers outside of
the United States.   The purpose  of the visit was  to measure the
noise from an M-420 diesel electric  locomotive and also to gather
Information on Alco locomotives  no longer manufactured but still
operating in the U.S.

M-420 Noise Measurements

     Although completely an MLW design, the M-420 diesel electric
locomotive is similar to the old Alco Century Series  C-420 in
that the same Alco 251 series 2000-hp turbocharged 12-cylinder
diesel engine is used as the power plant (MLW manufacturers en-
gines under license from Alco Engines Division of White Indus-
trial Power Inc., the surviving corporate identity of the origi-
nal Alco Products Corporation).   However, the M-420 and C-420 use
different trucks, and the operator's compartment and the front
(short) hood are slightly different (see figure D^l.)
     Although the C-420 and the M-420 are slightly different in
appearance, the stationary noise from the M-420 should be repre-
sentative of the C-420 because the two locomotives used the same
power plant.
     With the aid of Richard  Cooper of MLW, measurements of the
noise from the M-420 locomotive were made in the yard behind the
MLW plant on October 3, 1974  between the hours of  9:30 a.m. and
11:00 a.m. EDT.
                                L-l

-------
FIGURE D-l.  M-420 DIESEL ELECTRIC LOCOMOTIVE.

                  L-2

-------
     The following measurements were performed:
     1.  The overall A-weighted sound pressure level was measured
at 100 ft from the locomotive at idle and at throttle 8 under full
load.
     2.  The unweighted sound pressure level was recorded at 100
ft from the locomotive at throttle 8 under full  load.
     3.  The unweighted sound pressure level was recorded at 2.5
ft from the exhaust stack, as shown in figure D-2, with the loco-
motive at idle and at throttle 8 under full load.
     Because of the short cables from the resistor bank used to
load the locomotive, the M-420 could not be moved to a location
completely free from all reflecting surfaces.  Figure D-3 shows
the location of the locomotive, the measurement  position, and the
significant reflecting-surfaces (buildings etc.).  The overall
A-weighted sound pressure levels are shown in Table D-l.  These
measurements were made with a B&K #41^5 1-in. microphone (Ser.
No. 259175) with foam wind screen connected to a B&K No. 2203
Sound Level Meter (SLM) (Ser. No. 151612).

                           TABLE D-l
                  M-420 NOISE LEVELS AT 100 FT
                       Position 1
                 Position 2
        Throttle 8
        Idle
85 - 8? dBA
64 - 65 dBA
87   - 92   dBA
63-5 - 6H.5 dBA
The sound level meter was in the "fast" A-weighted setting.
     The 3- to 5-dBA increase in noise measured at Position 2 was
probably due to reflections from the corrugated metal building
shown in figure D-3.  Because Position 1 is more removed from all
                               L-3

-------
                             t
                         FORWARD TO
                         OPERATOR'S
                            CAB
                           1
                    2.5'
                                   PLAN VIEW
    MICROPHONE
             L'
    IS'
NX.
                        LOCOMOTIVE
                                   VIEW LOOKING

                                     FORWARD
FIGURE 0-2.   NEARFIELD MICROPHONE LOCATION.
                         L4

-------
t/l
                                        CORRUGATED METAL BUILDING
                                               ~30' HIGH
                                      ~69'
CONCRETE
   BLOCK
     BLDG

 -35' HIGH
                                   | LOCOMOTIVE  |
                         •  ' *»»43    H
                                               <  POSITION*!
                                                                       POSITION #2
           FIGURE D-3.  M-420 NOISE MEASUREMENT  LOCATIONS.

-------
reflecting surfaces, the levels measured there are more represen-
tative of the noise produced by the locomotive.
     With the same microphone windscreen and SLM, recordings of
the noise were made by connecting the output of the SLM to a
Kudelski Nagra III (Ser. No. B-61-110?) single-track tape recor-
der.  The SLM was in the fast linear setting.  The recordings
were later reduced in the BBN laboratory in Cambridge, Mass.
under a Federal Scientific UA-500 Ubiquitous Spectrum Analyzer.
The data are displayed in figures D-4 through D-7.
     We had hoped to'use the narrowband analysis of figure D-6 to
compare exhaust and cooling fan noise levels by comparing the
peak levels at the appropriate frequencies; i.e., firing fre-
quency and blade passage frequency.  The necessary data to calcu-
late the firing and blade passage frequency are given in Table
D-2  (courtesy of Bud Parker of MLW).
                           TABLE D-2
                M-420 ENGINE AND COOLING FAN DATA
        Engine RPM at throttle 8
        Engine RPM at Idle
        Number of cylinders
        Number of fan blades
        Fan speed
            •  top speed
            •  intermediate  speed
        Fan  diameter
1050
12
 6
      strokes/cycle)
1.31:1 speed increase over
       engine
" 10 percent slip in clutch
       or less
1.31:1 speed Increase over
       engine
RPM 50 percent to 60 percent
       slip in clutch
66 in.
                              L-6

-------
s
                        lOHz BANDWIDTH
                                                         1,	-pS
                                                      LOCOMOTIVE,
                            EXHAUST STACK

                                                         FULL POWER,THROTTLE 8
                                                         1050 RPM
                     X*A^vv
                      1000
200O
3000
40OO
5000
                                            Hz
           FIGURE D-4.  FULL POWER, THROTTLE 8, 1050 RPM.

-------
                                                      X EXHAUST STACK
            1000
2000
30OO
4OOO
5000
                                   Hz
FIGURE 0-5.   IDLE,  400  RPN.

-------
                                                    FULL POWER .THROTTLE 8
                                                    2.51 FROM EXHAUST STACK
                                                      1 Hz BANDWIDTH
70
                               200
300
400
500
                                     Hz
   FIGURE D-6.   FULL POWER, THROTTLE 8, 2.5  FT  FROM EXHAUST STACK.

-------
                                  10 Hz BANDU iDTH
                                                    MICROPHONE
1
0

                                                LOCOMOTIVE
                                             FULL POWER,THROTTLE 8
                                             100' FR"OM LOCOMOTIVE
                                             6* ABOVE GROUND
            1000
2000
30OO
40OO
50OO
                                   Hz
FIGURE D-7.   FULL POWER, THROTTLE 8,  100 FT  FROM LOCOMOTIVE.

-------
     The figures computed from these data are shown In Table
D-3.

                           TABLE D-3
            FIRING AND BLADE PASSAGE FREQUENCY DATA
                      Firing frequency =   105   Hz
               Top-speed Blade Passage
                 frequency             =   124   Hz
              Intermediate-speed Blade
                Passage frequency      = 55 — 69 Hz
     Unfortunately, there are two possible fan speeds, depending
on the heat load on the engine.  An electromagnetic clutch be-
tween the engine and the fan produces some uncertainty in the
speed reduction through that clutch.  The resulting uncertainty
in the blade passage frequency and the profusion of lines in figure
D-6 make it difficult to trace the fan noise lines in the spec-
trum without an elaborate and careful analysis in which each line
in the figure is identified.

Information on Alco Locomotives
     With the help of Hugh Paton, Vice President of Engineering
at MLW, we reached Robert Bergner, formerly employed by Alco
Products in Schenectady, New York, and presently employed by MLW
in Montreal.  Mr. Bergner was very familiar with all of the loco-
motives that are of interest to us.  A summary of his comments
follows.
                         *
     1.  For all Alco low-hood switchers or road switchers, there
Is room for a muffler above the hood directly above the engine.*
*0n the S-l, S-2, S-3, S-4, and T-6 switchers, this area is
 approximately 2 ft high by 6 ft wide by 22 ft long.
                              L-ll

-------
Visibility problems can be minimized by mounting the muffler as
far aft on the hood (near the radiator) as possible without inter-
fering with the cooling fan air flow.  The locomotives that fit
in this category are all the Alco switchers, the T-6, RS-1, RS-2,
RS-3, RSC-2, RSD-4, and RSD-5-
     2.  The muffler above the hood would present some additional
maintenance problems,  since piston and cylinder liner removal is
presently done through a trap door in the top of the hood on all
in-line 6-cylinder engines.  As a result, the muffler would have
to be removed before this major maintenance could be performed on
any Alco switcher and the T-6, RS-1, and RSD-1 locomotives.
     3.  For all high-hood Alco road switchers without dynamic
brakes, there is considerable space under the hood between the
engine and the roof of the hood.*  Figure D-8 shows this space on
the M-^20 locomotive,  looking aft from the generator to the tur-
bocharger.  If these locomotives have the dynamic brake option,
however, this space is used for the dynamic brake resistor assem-
bly.   As a result, muffler placement will be difficult on the
RS-11, RSD-12, RSD-15, C-420, C-424, C-425, and C-430 locomotive
with the dynamic brake option.
     4.  For the larger Century Series locomotives, the C-628,
C-630, and C-636,  the  dynamic brakes are in a compartment separ-
ate from the engine and,  as a result, the space above the engine
is always available for a muffler.
*0n the C-^20 locomotive there is, conservatively, a space
 approximately 12 ft long, 1 ft high, and about 3 ft wide above
 the engine.  It may not be possible to utilize the 3-ft width
 over the full height of the space; i.e., the muffler may have to
 be V-shaped so as not to interfere with cylinder liner or piston
 removal.
 Approximately 148 C-H20, C-424, C-^25, and C-^30 locomotives out
 of 27^ were built with the dynamic brake options.
                               L-12

-------
FIGURE D-8.  SPACE IN THE ENGINE COMPARTMENT OF  THE  M-420 SU1TAB
             FOR THE INSTALLATION OF A MUF.FLER.
                              L-13

-------
                       Appendix M

THE USE OF MUFFLERS ON LARGE DIESEL ENGINES IN NONRAILROAD
          APPLICATIONS: RESULTS OF A BBN SURVEY

-------
The Use of Mufflers on Large Diesel Engines In Nonrallroad
Applications:  Results of a BBN Survey
     Previous work made clear to us at BBN that little is known
about the possible effects of mufflers on locomotive diesel en-
gine performance.  This lack of information, we suspected, re-
sulted from the rarity of mufflers on locomotives.  We reasoned

that we might obtain such information from industries,  other than
railroads, which use large diesel engines and in which  mufflers
are more common.  Accordingly, we conducted an informal survey of
users, suppliers, and rebuilders on the influence of mufflers on
engine operations.  We did not discuss the acoustic performance
of mufflers, since this subject is well documented in the case of
nonrailroad diesel installations.
                                M-l

-------
     Our conclusions are:
        Mufflers are used in marine and stationary power plant
        application in conformance with the backpressure recom-
        mendations of the engine manufacturers.  There is no evi-
        dence that use of mufflers in such applications causes
        decreased engine life or reduced performance.
        No information publicly available provides a technical
        rationale for the exhaust backpressure limitations
        (5-in. HpO for turbocharged engines) which EMD specifies.
        The technology exists to produce turbochargers to with-
        stand temperatures up to 1500°F, but units in present
        production withstand temperatures up to 1200°F only.
        No nonproprietary test data on the effects of high back-
        pressure mufflers on emissions, engine reliability, or
        efficiency are available at this time.
     The survey was conducted primarily by telephone, with appro-
priate letter follow-ups.  There were two groups of interviews.
The first group, 10 interviews, was with people involved with
marine applications of diesel engines.  These people were asked
what effects muffler-induced exhaust backpressure had on effi-
ciency, power, emissions, reliability, and noise, and what sizes
of mufflers were used on their engines.  The second group of in-
terviews was with four persons responsible for manufacturing ex-
haust system manifolds and turbochargers.   These people were
asked to provide information on the state of the art of materials
                                M-2

-------
and the reliability of components to be used at temperatures
above those now common diesel electric locomotives.   Summaries of
those interviews which yielded useful information follow.

INTERVIEW SUMMARIES:
George Ponton
Hyattsville, Maryland
Former engineer with
Nashville Bridge Co.
Nashville, Tenn.
     Nashville Bridge designs and builds diesel-powered tow boats.
Mr. Ponton reported that tow boats are gneerally equipped with
spark arresters and sometimes with mufflers.   (Sparks are con-
sidered at least as much as problem on boats as around rail-
roads).  Mr. Ponton said that when mufflers are used, they are
sized to avoid backpressures in excess of those specified by the
engine manufacturer.  No independent muffler design is attempted
by the boat builder.  He mentioned Maxim Silencer Company and
Burgess Manning Company as two major suppliers of mufflers for
large diesel engines.
James Gunlauch, Vice  President
Canal Barge Line
New Orleans, La.
     Canal Barge Line operates diesel  tow boats.  Mr. Gunlauch
said that operators typically do not measure exhaust backpressure
on their boats; they  assume that the designer  has designed the
exhaust system properly.
     The total amount of fuel used by  a tow boat is known, but
the power delivered by the engines is  typically not measured.
Therefore, the effect on engine  efficiency  of  different mufflers
is not known.  Canal  Barge has not attempted to correlate muffler
use with engine failures and  has made  no measurements of engine
emissions.

                                M-3<

-------
R.B. Gladstone, Manager-Government Sales
General Motors - Electromotive Division
La Grange, 111.
     Mr. Gladstone sent us copj.es of pertinent pages of EMD's
Marine Applications Book; figure 8-1 shows a page describing muf-
flers specified for EMD 6^5 series diesel engines.
     Mr. Gladstone reaffirmed the previously stated limitations
on engine backpressure and said that use of higher backpressure
could void the engine warranty.  He did not know about effects of-
mufflers on emissions or efficiency.
Robert Fortenbury, Salesman
Sample Brothers
New Orleans, La.
     Sample Brothers markets industrial mufflers.  Mr. Fortenbury
said that mufflers used on EMD 6*15 E-5 engines typically have a
28-in. inlet diameter and provide 5-'to 6-in. E^O of total back-
pressure at the exit of the turbocharger.
Gerrit Van Dissel, Naval Architect
Potter & McArthur Inc.
Watertown, Mass.
     Mr. Van Dissel has designed numerous boats using EMD diesels
fitted with mufflers and spark arresters.  He considers these
standard items and is not aware of any detrimental effects on
performance.
C.M. Bennett
Precision National Corp.
Mt. Vernon, 111.
     Precision National is a major engine rebullder.  Mr. Bennett
said that since his firm does not measure engine operating para-
meters on boats, he does not know the effects of muffler back-
pressure.  He has not seen any engine failures which could be
traced to high exhaust backpressure.
                               M-4

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                                       EXHAUST MUFFLERS
                                 645E2, G45F5. G45EG AND 645E7 ENGINES
       SPARK ARRESTER MUFfLER
                          :1~--U  B
                                       G •
                                           \
                                                           Flow.
                                           ''-^-Cleanouts
                       n ',    Spark Box Connection
                       Drai"     (Vert. Mtg.)
                                         Spark Box
                                        (lloriz. >ltg.)
                                                                         	I
                                                                               \


Muffler
Bade
taate
Enlc
Std. Extra
Std. Extra
Etd. Extra
Std. Extra

K'ngtrc
Model
8-Cyl. R-B
12-Cyl. R-B
16-Cyl. R-B
8-Cyl. Turbo.
12-Cyt. Turbo.
16-Cyl. Tur!>o.
20-Cyl. Turbo.

Dimensions - Inches
A
5'9
6'7
7'3
•j'O
»
30
3*
40
50
±1 °
12J19
Ul21
16'23-l/2
20!27-l/2
e
17 B.C.
18-3/4 B.C.
2l-l/Vi B.C.
25 B.C.
IO'Bj6n;24'32 29-1/2 B.C.
11'-' '64 26134- 1/4! 31-3/4 B.C.
12', 68 28'36-l/2JJla.-23 Holes
C
22-S/8
41
43
49
54
*3-3/S
63

we.
Lbj,
490
770
1020
1660
2910
WO
44»0
Pressure Diop ]
Inches HjO
900 RPJ1
10.5
12.4
U.6
2.7
T..4
2.9
3.0
       Dalle muffler Is.U.S.C.C. approved for the Roots-blovcr engines.
       Std. Extra muffler It U.S.C.G. approved for lh« tutbocharged engines.

        R-B  Roots-Llowcr engine
       Turbo.  Turbocharged engine

       STRAIGHT THROUGH MUFFLER
          B  D C
                                              Flow


Huffier
Bn»U
Baalc
Jailc
Bane

Engine
Model
8-Cyl. Turbo.
12-Cyl. Turbo.
16-Cyl. Turbo,
20-Cyl, Turbo.

Dimensions • IncKei
A
96
113
115
US
B
26
36
42
42
C
16
20
22
n
0
23-1/2
27-1/2
29-1/2
29-1/2
E
21-1/4 B.C.
25 B.C.
27-1/4 B.C.
27-1/4 B.C.
F
1-1/8 Din. -16 Holes
1-1/4 Pin. -20 Holes
1O/B Ola. -20 Holes
1-3/8 01*. -20 Holes

«t.
U,s.
560
1100
1380
1380
Pressure Drop
Inches HjO
900 Rl'M
.4
.3
.4
.4
       Turbo. Turbocharged engine

       WJTE:  All nufricri nay be Mounted in «ither a vertical or horizontal position.
             All fiancee are 125* An. Sid.  - conrMilcn Clnn&cs to be furnished by shipbuilder.
FIGURE  8-1.
SAMPLE  PAGE  FROM EMD  MARINE  APPLICATIONS  DATA  BOOK,
SHOWING MUFFLERS RECOMMENDED  FOR 645E  SERIES DIESEL
ENGINES.
                                            M-5

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Robert Gant
Preco Equipment Company
Houston, Texas
     Preco is a rebuilder of diesel engines.  Mr. Gant did not
know of any data taken on tow boats relevant to engine perfor-
mance as affected by mufflers.

INTERVIEW SUMMARIES: •TURBOCHARGER MANUFACTURERS
Howard Bach, Manager-Turbocharger Marketing
Elliot Company, a Division of Carrier Corp.
Jeannette, Pa.
     Elliott Company supplies turbochargers to General Electric
and to De Laval.  Mr. Bach was asked to discuss presently allow-
able operating temperatures for turbochargers, future trends in
turbocharger temperatures, and the costs of manufacturing and
servicing turbochargers for higher temperatures.  He indicated
that the costs of components and servicing for turbochargers de-
signed to operate at 1200°F turbine inlet temperature and 10-in.
H20 backpressure are the same as the costs for a unit designed to
operate at 900°F.   (Absolute manufacturing costs are not avail-
able.)  Elliott is testing prototype turbine and nozzle ring com-
ponents at 1350°F with limited success.  The cost of these com-
ponents is estimated to be 3 to 4 times as high as for the pres-
ent production components.  Table 8-7 summarizes the cost infor-
mation provided by Mr.  Bach.
     The backpressure limitation of 10-in. E^O seems to be set by
a lack of experience at higher backpressures.  When questioned
about the factors which limit the backpressure recommendations,
Mr. Bach indicated that lower pressure difference causes bearing
seals to leak, for example, when a locomotive is at high alti-
tudes.  There is apparently no experimental substantiation for
the 10-in.  H00 level which they recommend.
                               M-6

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                         TABLE 8-7

RELATIVE COMPONENT AND SERVICING COSTS FOR TURBOCHARGERS AS A
                 FUNCTION OF DESIGN TEMPERATURE
Inlet Temperature to
Turbocharger
Relative Turbine
Cost
Relative Housing
Cost2
Relative Servicing
Interval for Turbine
and Bearings
Relative Service Life
of Housing
Relative Cost of
Servicing
Turbocharger Ou*1et
Pressure Above
Atnos eric
Relative Turbine
Cost
Relative Housing Cost
Relative Servicing
Interval for Turbine
and Bearings
Relative Service Life
of Housing
Relative Cost of
Servicing
1. Source: H.
2. Present hous
SOO°F
i
i
i
i
i
0"H20
1
1
1
1
1
Bach,
5ing r<
1000aF
Production
(1)
(1)
CD
(HA)
(NA)
5"H20
(!)
• (1)
(1)
(1)
(NA)
;IOO°F
Production
(1)
CD
(1)
(NA)
0.'A)
10"H20
(1)
(1)
(1)
CD
(HA)
12DO°F
Production
(1)
(1)
(D
(NA)
(MA)
15"H20
OJA)
CIA)
CNA)
CNAI
(NA)
UOO°F '1350°F UOO°F 1500°F
Prototype Prototype
(3-f) (3-1) (NA) (NA)
(NA) (NA) (NA) (HA)
(HA) (NA) (NA) (NA)
(NA) (NA) (NA) (NA)
CJA) (NA) (.\'A) (NA)
20"H20
.'(HA)
(NA)
(NA)
(NA)
(NA)
Elliot Company.
^placement
rate Is
approxim;
ately 15% per year.

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               Appendix N




AMTRAK EXPERIENCE WITH MUFFLED LOCOMOTIVES

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AMTRAK Experience with Muffled Locomotives

     In 1973, the National Railroad Passenger Corporation (AMTRAK)
took delivery of forty EMD SDP-40F locomotives fitted with Uni-
versal Silencer exhaust mufflers.  These units have been opera-
ting in the Western District at an average rate of approximately
200,000 miles per year.  We talked to Mr. Deane Ellsworth, mana-
ger of the Mechanical Systems Department of AMTRAK, about service
experience with these mufflers.
     The locomotive price differential due to the muffler was
$500 to $600, exclusive of carbody modifications.  The muffler's
space requirements dictate an overall engine height of 15 ft 9
in.; this height makes the locomotives unusable in the Baltimore
Harbor Tunnel or Union Station, Washington, D.C.   Wyle Labora-
tories has made noise level measurements for EMD, which now
retains  those  data.*   Mr. Ellsworth's recollection was that  typi-
cal  levels were  66.5  dBA  art'  idle and  88  to  89 dBA at  full throt-
tle.
     To  date,  AMTRAK  has  experienced  no  service  problems which
could  be related to mufflers.  There  have been no locomotive road
failures.  There have been no  muffler-induced engine  maintenance
problems; as yet,  however, AMTRAK  has not had to remove the
turbochargers,  so the muffler's  effect on engine accessibility
has  not  been evaluated.   No  increase  in  fuel  consumption  levels
have been noted; on the  other  hand, it would  be  difficult to mea-
sure changes as  small as  1 percent.   There  have  been  no turbo-
charger  failures-or replacements to date,  so  the effect of back-
pressure on  turbocharger life  cannot  be  evaluated.
 •An  earlier telephone  conversation with Mr.  R.  Pribramsky  of  EMD
  Indicated that  any  data which they would make  available would
  be  given directly to  EPA at. the Agency's request.
                               N-l

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     Appendix O




REFRIGERATOR CARS

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Noise From Refrigerators and Auxiliary Engines

     BBN has reviewed the data on noise levels produced by refrig-
eration units on cold-storage cars and by auxiliary engines on
passenger locomotives.  The work summarized data available in
reports and other sources; no original measurements were made.
     Refrigerator Cars.   There are 26,000 refrigerator cars in
the United States, half of which are owned by one company (Paci-
fic Fruit Express Company of San Francisco).  The refrigeration
units on the cars are powered by 2- or 3-cylinder Detroit Diesel
engines running at 800 or 1200 rpm.  These engines run continu-
ously to cool the cargo.
     Our primary source of noise data for refrigerator cars is
Wyle Laboratories Report WCR-73-5 (1973).  Table 8-8 lists noise
levels of four cars at a 50-ft distance.  Note that, assuming
6-dB attenuation per doubling of distance, only the 3-cylinder
units violate the 6?-dB standard at 100 ft for a single car and
then only on one side.  However, refrigerator cars are usually
made up into trains of 100 cars or more; at that size, the noise
level of the train will exceed the 67-dB-at-100-ft standard.  In
addition, note that several of the measurements in Table 8-8 were
actually made in the near field and were extrapolated to 50 ft.
In these cases, further extrapolation to 100  ft may result in
inaccuracies.
     The data for the second car in Table  8-8 indicate that as
much as 6 to 7 dB of noise reduction could be achieved by muff-
ling the engine.
     An additional noise measurement was obtained  from Rickley,
Quinn and Sussan  (197^), who reported a  level of 84.5 dBA at  a
distance of  50 ft from  the engine  side of  a Boston $ Maine re-
frigerator car.  The model of diesel engine and the compressor
manufacturer were not noted.

-------
                                          TABLE 8-8
                       MEASURED NOISE LEVELS OF FOUR CARS, 50-FT DISTANCE*

Engine Model
and
Rated Power
Detroit Diesel
2-71 80 hp
Detroit Diesel
3-17 120 hp
Detroit Diesel
3-53 100 hp

Compressor
Manufacturer
Trane
Carrier
Trane
Trane
Typical Noise Levels Emitted by
Mechanical Refrigerator Cars
Operating Mode
Low Throttle: 800 rpm
High Throttle: 1200 rpm
Low Throttle: 800 rpm
High Throttle: 1200 rpm
Diesel off - motor com-
pressor driven by 220V
auxiliary electrical
power. High Setting
High Throttle: 1200 rpm
High Throttle: 1200 rpm
A-Weighted
in dB (re 2C
Engine Side
69-5
76.5
75. 5f
61*
8Qt
.80.51"
Noise Level
IpN/m) at 50 ft
Condenser Side
66 I
70. 5T
65 (66. 5f)
71
64 (63f)
73. 5f
71. 5f
s
    'Source:  Wyle Labs (1973).
     Calculated via nearfield measurement procedure and analytical technique.

-------
     Auxiliary Diesel Engines.   Passenger locomotives and cars
are frequently equipped with (1) diesel engines to drive an alter-
nator supplying electric power to the train, and (2) steam gener-
ators (on the locomotive) to supply heat for the train.  AMTRAK
is purchasing new locomotives with auxiliary diesel engines on
board; some of their club cars already have them.
     Data on noise levels from auxiliary engines were provided by
the Illinois Railroad Association in its submission to Docket No.
ONAC 7201002; the IRA cited noise levels of two auxiliary engines
as measured by the Chicago & Northwestern Railway.  These engines
were Cummins V-block diesels running at 1800 rpm so as to gener-
ate 60-Hz electricity.  Noise measurements were taken with no
load on the engines; they would have been higher if a load had
been applied.  The measured levels were 58 and 55 dBA at 100 ft
from the locomotive.
                              O-3

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                       Appendix P




APPLICABILITY OF TRACK AND RAIL SAFETY STANDARDS TO NOISE

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       APPLICABILITY OF TRACK AND RAIL SAFETY STANDARDS TO NOISE
Introduction

     In this section,  we comment on the DOT FRA Track Safety
Standards* and Railroad Freight Car Safety Standards,  insofar as
their enforcement affects noise.
Track Standards

     Track standards limit train speed by assigning each track to
a class, which is determined by the quality of track maintenance.
Table 7-1 provides the maximum allowable operating speed (in mph)
for each class.
                            TABLE 7-1
                MAXIMUM ALLOWABLE OPERATING SPEED

Class

1
2
3
4
5
6
Maximum Allowable Speed (mph)


Freight Trains
10
25
MO
60
80
110

Passenger Trains
15
30
60
80
90
110
Section 213.9 states "If a segment of track does not meet all of
the requirements for its intended class, it is reclassified to
*CFR Title 49, Part 213, Sec. 213.1 - 213.241, with Appendix  B
  (Fed. Register, Vol. 39, No. 67, April 5, 1974).
fCFR Title 49, Part 215.
                                P-l

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the next lowest class of track for which it does meet all of the
                                     /
requirements of this part."  This provision, together with a
schedule of fines for violations, puts teeth into the standard.
A railroad can indeed operate on poorly maintained track - but
only at inefficiently low speeds.  Therefore.it is in the rail-
roads' interest to maintain track where high-speed operation is
needed.
     In this section, we evaluate the impact of various sections
of Part 213 on the noise generated by trains.  Each section is
quoted, then followed by an explanation of its effect on noise.

§213.53  Gage
     (a)  Gage is measured between the  heads of the rails at
right angles to the rails in a plane five-eighths of an inch
below the top of the rail head.
     (b)  Gage must be within the limits prescribed in Table 7-2.
                            TABLE 7-2
                           GAGE LIMITS
Class of
Track
1
2 and 3
4
5
6
Tracic Gage of Tangent
Track Must Be —
At
Least
4 ft 8 in.
H ft 8 in.
4 ft 8 in.
H ft 8 in.
U ft 8 in.
But Not
More Than
i\ ft 9* in.
4 ft 9h in.
4 ft 9\ in.
4 ft 9 in.
4 ft 8^ in.
The Gage of Curved
Track Must Be -
At
Least
4 ft 8 in.
H ft 8 in.
4 ft 8 in.
4 ft 8 in.
U ft 8 in.
But Not
More Than
4 ft 9* in.
4 ft 9* in.
4 ft 9*5 in.
4 ft 9% in.
4 ft 9 in.
                              P-2

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§213.55  Alignment


     Alignment may not deviate from uniformity more than the

amount prescribed in Table 7-3.


                            TABLE 7-3

                   ALIGNMENT DEVIATION LIMITS
 Class of Track
                     Tangent Track
The Deviation of the
  Mid-Offset From
  62-ft Line1 May
  Not Be More Than
                           Curved Track
The Deviation of the
 M1d-0rd1nate From
  62-ft Chord2 May
  Not Be More Than
       1

       2

       3
       5  in.

       3  in.

       !<; in.

          in.

          in,

          in,
       5  in.

       3  in.

          in.

          in,

        } in,

        I in,
  *The ends of the line must be at points on the gage side of
  the line rail, five-eighths of an inch below the top of the
  railhead.  Either rail may be used as the line rail, how-
  ever, the same rail must be used for the full length of
  that tangential segment of track.

  2The ends of the chord must be at points on the gage side of
  the outer rail, five-eighths of an inch below the top of
  the railhead.
 Effect

     Variations  In  gage may  result  in lateral  motion of the

 train,  with possible  impact  of  wheel  flanges against rail  heads
 and car sway with attendant  rattle, etc.   These  types of noise

 mechanisms  have  not been  investigated quantitatively, however,

 and can only be  mentioned in qualitative  terms.
                                P-3

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 §213.109  Crossties
      (a)  Crossties may be made of any material to which rails
 can be securely fastened.  The material must be capable of hold-
 ing the rails to gage within the limits prescribed in §213.53(b)
 and distributing the load from the rails to the ballast section.
      (b)  A timber crosstie is considered to be defective when it
 is:
          (1) Broken through;
          (2) Split or otherwise impaired to the extent it will
              not hold spikes or will allow the ballast to work
              through;
          (3) So deteriorated that the tie plate or base of rail
              can move .laterally more than one-half inch relative
              to the crosstie;
          (4) Cut by the tie plate through more than 40 percent
              of its thickness; or
          (5) Not spiked as required by §213.127-
      (c)  If timber ties are used, the minimum number of nonde-
 fective ties under a rail joint and their relative positions
 under the Joint are described in Table 7-4.  The letters in the
 chart correspond to letters underneath the ties for each type of
 Joint depicted.

 §213.121  Rail joints
     (b)  If a Joint bar on classes 3 through 6 track is cracked,
broken, or because of wear allows vertical movement of either
rail when all bolts are tight, it must be replaced.
                               P-4

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                            TABLE 7-4
                    NONDEFECTIVE TIES CHART
           SUPPORTED JOINT
                •  •  o  •
                                 >  \
                                           ENDED  JOIMT
\ l« • o .| (

ty>

yjj

              Clan et track
Minimum number o( nondefecttr*  Required position of nondefectlr* tie*
    tie* under (Joint    '                  •
                 Supported Joint  Suspended Joint
                          1	X.Y.orZ	Xar Y.
                         , 1	 Y!...	X or Y.
                         , j.	X and Y. or   X tod Y.
                                           YtndZ.
Effect
     These two sections require  (1)  increasingly firm tie support
for Joints with higher track  classes and (2) the prevention of
relative vertical motion of two  rails at a joint.  The effect of
a poorly supported Joint is to allow the rail to deflect more
than usual under load.  If the Joint bar connecting abetting
rails were extremely tight and well  fitted, as is the case for
classes 3 through 6 track, this  deflection would not have serious
noise consequences.  However, the track standards allow for poor
support at Joints and relative vertical motion of the rails for
class 1 and 2 track.  Under these conditions, noise is expected
to be significant.
     Rail Joints are one  of the  major sources of railroad track
noise.  They account for  the  familiar "clickety-clack" one hears
as wheels pass over the Joint.   Accordingly, the noise from this
type of mechanism is one  of the  important  sources of community
noise from rail  lines.  The noise level from impact at rail
                                P-5

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joints is proportional to 20 log V,  where V is  the train veloc-

ity. •   Accordingly,  a train traveling at 50 mph over class 2

track  would generate approximately 6 dB more noise than if it

were traveling at  the legal limit  of 25 mph.



§213.113  Defective  rails

      (b)  If a rail  in classes  3 through 6 track or class 2 track

on which passenger trains operate  evidences any of the conditions

listed in Table 7-5, the remedial  action prescribed in the table

must be taken.



                              TABLE  7-5

                          REMEDIAL ACTIONS
        Condition
If a Person Designated
 Under S213.7 Deter-
 mines That Condition
   Requires Rail  To
     Be Replaced
If a  Person Designated
 Under  §213.7 Deter-
 mines  That Condition
   Does Not Require
 Rail To Be Replaced
  Shelly  spots

  Head checks

  Engine  burn
    (but  not fracture)

  Mill defect

  Flaking
  Silvered

  Corrugated

  Corroded
Limit speed to 20 'mph
and schedule the rail
for replacement.
Inspect the rail at
Intervals of not more
than every 6 months.
Inspect the rail  for
Internal defects  at
Intervals of not  more
than every 12 months.
Inspect the rail  at
Intervals of not  more
than every 6 months.
      (c)   As used in this section.

           (12) "Shelly  spots" means  a  condition where a thin

                (usually three-eights inch in depth  or less)
•Source:   Remington, Rudd,  and Ve"r  (1975).
                                 P-6

-------
               shell-like piece of surface metal becomes separ-
               ated from the parent metal in the railhead, gener-
               ally at the gage corner.  It may be evidenced by a
               black spot appearing on the railhead over the zone
               of separation or a piece of metal breaking out
               completely, leaving a shallow cavity in the rail-
               head.  In the case of a small shell, there may be
               no surface evidence, the existence of the shell
               being apparent only after the rail is broken or
               sectioned.
          (13) "Head checks" mean hair-fine cracks which appear
               in the gage corner of the railhead, at any angle
               with the length of the rail.  When not readily
               visible, the presence of the checks may often be
               detected by the raspy feeling of their sharp edges.
               "Flaking" means small shallow flakes of surface
               metal generally not more than one-quarter inch in
               length or width that break out of the gage corner
               of the railhead.
Effect
     This sample of Sec. 213.113 Illustrates that train speed is
limited on defective rail, if an Inspector decides the rail must
be replaced.  Defects such as shelly spots on the rail running
surface will generate noise in much the same way as Joints.

§213.115  Rail end mismatch
     Any mismatch of rails at Joints may not be more than that
prescribed by Table 7-6.
                               P-7

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                            TABLE 7-6
                  LIMITATIONS OF RAIL MISMATCH
Class of
Track
1
2
3
4,5
6
Any Mismatch of Rails at Joints May Not
Be More Than The Following*
On the Tread of
the Rail Ends
(Inch)
1/4
1/4
3/16
1/8
1/8
On the Gage Side of
the Rail Ends
(Inch)
1/4
3/16
3/16
1/8
1/8
Effect
     Noise from joints is a function of train speed, as men-
tioned above, and of mismatch in rail heights.  Mismatch on the
gage side of the rail ends is not expected to be significant but
mismatch on the tread side of the rail ends (i.e., the running
surface) is important.  For this type of mismatch, noise in-
creases as 10 log (h), where h is the amount of height differ-
ence. *  Accordingly, at a given train speed, noise will be 3 dB
more for track with 1/4-in. mismatch (Class 1,2) than for track
with 1/8-in. mismatch (Class 4,5,6).

§213.117  Rail end batter
     (a)  Rail end batter is the depth of depression at one-half
inch from the rail end.  It is measured by placing an 18-inch
•Source:  Remington, Rudd, and Ve"r (1975).
                               P-8

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straightedge on the tread on the rail end, without bridging the
Joint, and measuring the distance between the bottom of the
straightedge and the top of the rail at one-half inch from the
rail end.
     (b)  Rail end batter may not be more than that prescribed by
Table 7-7.
                            TABLE 7-7
                  RAIL END BATTER LIMITATIONS
Class of
Truck
1
2
3
5
6
Rail End Batter May Not
Be More Than (Inch)
1/2
3/8
3/8
1/8
1/8
Effect
     Qualitatively, rail end batter has much the same effect as
Joint mismatch.  As illustrated in figure  -1, even if the Joint
ends are aligned, the wheel leaves one rail and contacts the next
at an angle which causes the wheel to be pushed suddenly upward
and the rail down.  The result is an impact noise, the level of
which Increases with increasing batter.
                                P-9

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   FIGURE 7-1.  SCHEMATIC SHOWING MECHANISM OF RAIL-END BATTER.

§213.137  Frogs*
      (c)  If the tread portion of a frog casting is worn down
more  than three-eighths inch below the original contour, operat-
ing speed over that frong may not be more than 10 miles per hour.

Effect
      As with rail end batter, degradation of frog tread Increases
noise.

Wheel Standards (Part 215)
      Part 215 requires that each railroad freight car which has a
component described as defective in this part must be (a) re-
paired or (b) removed from service (§215.7).  Furthermore, "any
railroad that operates a railroad freight car in violation of any
requirement prescribed in this part is liable to a civil penalty
•A "frog" is the X-shaped member that is used where one rail
 crosses another, as in a turn-out.
                               P-10'

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of at least. $250 but not more than $2500 for each violation^.
Each day of each violation constitutes a separate offense"
(§215.19).

§215.43  Defective Wheels
     A wheel Is defective If It has any of the following condi-
tions:
     (g)  Contiguous (adjoining) pieces of metal shelled out of
the circumference of the tread.
     (h)  A slid-flat spot more than 2*s inches in length or two
adjoining flat spots each more than 2 inches in length.

Effect
     Wheel flats and shelled spots cause an impulsive noise each
time the defective area contacts the rail.  This noise can often
be detected aurally as a "clunking" sound in a passing train.
Furthermore, the noise level Increases with increasing flat spot
dimension.  Accordingly, compliance with §215.*»3 will decrease
community noise.
                               P-ll

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        Appendix Q




RAIL CAR NOISE LEVEL DATA

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Table 1.  Example of Observed Rail Car Noise Level Variations
          Due to Sound Level Meter Detector Time Constant and
          Statistical Variations over Train Length for a Fifty-
          Car Freight Train Traveling at 34 MPH on Welded Rails
          (less locomotive noise).
Actual
Time
(sec)
Computed Percentile L9g
II II T
iAJ/\ /\
90
H II T
L50
N It £
n " L
" " L ,
• X
Maximum Level (dBA)
"Max." Meter Reading
50
45

25
5
.5
.05
51
51
"Impulse"
35 ms
(dBA)
75.5
77.0

•79.0
81.0
82.5
85.0
85.0
85.0
"Fast"
125 ms
(dBA)
75.5
77.0
,
79.0
81.0
82.5
85.0
85.0
84.0
"Slow"
1000 ms
(dBA)
76.0
77.5

79.0
80.5
81.0
81.0
81.0
81.0
                                  Q-l

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Fig. 1.  Maximum  Rail  Car Noise Level Measured at  100  feet by Wyle and DOT/TSC
     Freight :-  Wylejj;
     Freight  -  DOT -•
EPA Rail Car Limit
     Turbotrain  -  DOT
     Metroliner  -  DOT
                  . . I  ~~~! UJ7~~~ .  ~: ~Z^~<:^~ '.      ~"~
      	  !~1	
                                                                                  -=:- A A
                                           30           40
                                           Train Speed,  mph
                   50
60
80
100

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Fig. 2.  Average Freight Rail Car Noise Level Measured at 100  feet by Wyle and BBN
    —Jointed Track— - Wyl
                                            EPA Rail Car Limit
                                         30         .  40
                                    Train Speed, mpn

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Fig. 3.  Maximum and Average  Rail Car Noise  Level Measured at  100  feet by Kamperman Associates
                                                          I..jI.:^iL].L__!i: TTI "i rrrn
-}- -P a s s e nger~---Maximum n

   Passenger" - Average ~
                                                          EPA Rail Car Limi
      F rei ght ~^_-_ Maxi munr—
      F rej. ght, _;^_ Ave r age
             "

                                            30           40
                                       Train Speed,  mph
                                                                         60
80
roc

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    .005          -1       -5    1   2.5    5
    0.01    0.05 0.1  0.2   0.5  1    2      5    10
Percent  of Time  the Rail Car Noise Level  Exceeded

10           25                 45               50  (Time  in seconds)
 20    30   40  50  60  70   80      90    95     98   99  99.5  99.8 99.9       99.99

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                        Appendix R

ANALYSIS OF PUBLIC COMMENTS ON THE ENVIRONMENTAL PROTECTION
     AGENCY PROPOSED RAILROAD NOISE EMISSION STANDARDS

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                         TABLE OF CONTENTS


                                                     Page

A.  INTRODUCTION                                     1

B.  COMMENTS DIRECTED TO SPECIFIC SECTIONS
    OF THE PROPOSED REGULATIONS                   2

         Section 201.1 - Definitions                       2

         Section 201.10 - Applicability                    2

             a.  Warning Devices                         4

             b. Fixed Facilities /Retarders               8

             c. Special Purpose Equipment              13

             d. Track and Right of Way                 15

             e. Refrigerator Cars/Auxiliary
                 Engines                               16

          Section 201.11 -  Standards for Locomotive
          Operation Under  Stationary Conditions           20

             a. Locomotive at Idle                      20

             b. Locomotive at any Throttle
                Setting Except Idle                      24

          Section 201.12 -  Standard for Locomotive
          Operation Under Moving Conditions             26

          Section 201.13 -  Standard for Rail Car
          Operations                                   27

          Sections 201.11,  .12,  .13 - 270 Day
          Standard                                     28

C.  COMMENT ON ADDITIONAL ISSUES                 29

          1.  Meeting the Standard with Newly
             Manufactured Locomotives                  29
                               R-l

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                   TABLE OF CONTENTS (Cont'd)
         2.  Meeting the Standards with Existing
             Locomotives (Retrofit)                       29

             a.  Economic Considerations                 29

                (1) Economic Impact in General           29

                (2)  Economic Impact on Bankrupt/
                    Marginal Railroads                   35

             b.  Technical Considerations                 36

         3.  Health and Welfare                          40

         4.  Legal Considerations                        42

         5.  Measurement Methodology and                45
             Compliance Regulations

         6.  Special Local Conditions                     48

         7.  Property Line Standards                     50

         8.  Background Document Data and
             Information                                 51

         9.  Statements of Support                        53

D.  SYNOPSIS OF COMMENTS FROM THE SPECIAL
    CONSULTATION MEETING ON THE PROPOSED
    INTERSTATE RAILROAD NOISE EMISSION
    STANDARDS                                         54

INDEX OF WRITTEN DOCKET SUBMISSIONS               i

INDEX OF SPECIAL CONSULTATION MEETING
 PARTICIPANTS                                       iii
                              R-2

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A.  INTRODUCTION


    On July  3,  1974,  a  Notice  of Proposed Rulemaking on the Inter-


State Rail Carrier  Noise Emission Regulations  was published in the


Federal Register.  In  the same publication, notice was also given of


the availability of the  Background Document and Environmental Expla-


nation for  the  Proposed  Interstate Rail  Carrier Noise  Emission


Regulations.  Public  comment was solicited with respect to both the


proposed  regulations  and  the  data presented  in  the Background

Document, with the period extending from July 3, 1974,  to August 17,


1974.   On August 14,  1974, a special consultation meeting was held on


the proposed regulations.


    The public comments received  relative to the proposed  regulation


and the Background Document  as well as  the transcript of the special


consultation meeting make up the total body of public comment received.


    The contents  of all docket  submissions have been  reviewed and


analyzed by the staff  of the Environmental Protection Agency.  These


analyses follow.


    A synopsis of the issues  raised in  the transcript of the special


consultation meeting  has been included as a separate  section  of this


document. All of  the issues raised  in that meeting have been addressed


in the analyses which precedes such synopsis.

    All public comment associated with this regulation  is maintained


at the EPA  Headquarters,  401 M.  Street,  S.W.,  Washington,  D. C.
            i

20460, and  are available for public inspection during normal working


hours (Monday through Friday,  8 am to 4:30 pm).
                               R-3

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B.  COMMENTS ^ DIRECTED  TO  SPECIFIC  SECTIONS  OF  THE
    PROPOSED REGULATIONS
Section 201.1 - Definitions;
    The New York  Department of  Environmental Conservation and the
Department  of  Transportation both  indicated that  syice  the term
"retarder" is not used in the regulation its definition should be elimi-
nated from Section 201.1. In addition the DOT raised the same point con-
cerning the term "sound pressure level."
    Both definitions have been removed from Section 201.1.
Section 201.10 - Applicability;
    There were a considerable number of different questions and issues
received  which dealt with the applicability of the regulation to  var-
ious types of railroad facilities and equipment.  The  Association of
American Railroads raised questions of a largely legal nature dealing
with matters involving the interpretation of the Act and with the EPA's
duties and authority.   The Agency has addressed these legal questions
in a later section of this analysis.  Other questions dealt with matters
peculiar to the particular railroad facilities or equipment at issue, and
are  discussed in  detail below.   However,  a significant  number of
comments,  in particular those  of  the  Association of American Rail-
roads, US Department of Transportation, Illinois Railroad Association,
and the Fruit Growers Express Company, also brought into issue the
general question of why the  EPA  decided, apart  from considerations
of available technology and  cost  of compliance,  not -to regulate all
railroad facilities  and  equipment,  and  chose rather to regulate  only
certain equipment at this time.
                               R-4

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   This decision by the EPA was based on  its view that the uniform
Federal regulation of the noise produced by certain railroad facilities
and equipment is not necessary at this time  since such noise sources
can best be  controlled by measures which do not now require national
uniformity of treatment in order  to  facilitate interstate commerce as
specified in Section 2(a)(3) of the  Act.
   The EPA has studied the operations  of the  rail carriers engaged
in interstate commerce by rail  and has seen  that such  operations are
imbedded into every corner of  the nation at thousands of locations and
along hundreds  of  thousands of miles of right-of-way. The nature and
magnitude of the noises produced by the many types of facilities and
equipment utilized in these operations differ greatly and their impact
on the environment  varies widely depending on whether they occur,
for example, in  a desert or adjacent  to a residential area.  The Agency
concludes that the control of certain of these noise sources, such as
fixed facilities,  or equipment used  infrequently or primarily  in one
location,  is best handled by the  State and  local  authorities,  rather
than the  Federal government.  State and local authorities are believed
in this case to be better able than the Federal government to consider
local circumstances in applying such measures as the addition of noise
barriers or sound insulation to  particular facilities, or the positioning
of noisy  equipment within  these facilities  as  far as possible from
noise-sensitive  areas. Further, and more importantly, the EPA did not
find during its analysis, and has not received from rail carriers,  any
information identifying situations where the  lack of uniform State and
                               R-5

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local laws with respect to these facilities and equipment has imposed
any significant burden on interstate commerce.
  .  In view  therefore  of the absence of evidence  calling for  the
national regulation  of  all railroad facilities  and equipment in order
 to facilitate interstate commerce,   the EPA  believes that its limited
regulatory action as proposed in the Notice of Proposed Rule  Making
to consider railroad  operations, facilities,  and equipment on an indi-
vidual basis in deciding the need for their uniform Federal regulation
is appropriate.
    a. Horns,  bells, whistles, and  other acoustic warning devices.
    The New  York Department of Environmental Conservation,   the
South Carolina Department of Health and -Environmental Control, and
the Oregon Department of Environmental Quality, all  indicated that
complaints from citizens about railroad warning device noise were not
only large in number but comprised the major  source of all complaints
about railroad noise, and therefore contended that such warning  devices
should be regulated.
    The Agency in analyzing  the problem of acoustic  warning  device
noise recognized a unique characteristic  of such noise  as opposed to
other railroad noises.   That is, it is a form of noise that is purpose-
fully created  and intended to be heard  for  safety reasons,  instead of
being an unwanted by-product of some other  activity.   As such,  the
EPA found that  these warning devices and  their  use are regulated at
                              R-6

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 both the Federal  and State  levels.  Federal  regulations ensure that
 such devices on locomotives are suitably located and in good working
 order,  (Safety Appliance Act,  45 USCA; 49 CFR, 121, 234, 428, 429).
 State regulations are oriented toward specifying the conditions of use
of these  devices.   A recent  study  of  the 48 contiguous States (see
Appendix B of Background Document)  shows that 43 of these States have
such regulations.   In addition, studies  considered by the EPA also
included in Appendix B  of the Background Document show that such
warning devices do not appear to be unrelated to highway and pedestrian
safety, especially in emergency situations.  The reduction or elimina-
tion of such warning devices  through the  authority of the Noise Control
Act does not therefore appear  to be a  reasonable   consideration as
suggested by B. Leath,  the  South Carolina Department of Health and
Environmental Control, and Citizens Against Noise.
    The EPA does recognize  that a noise problem exists as  to the use
and extent  of railroad warning devices,  and that regulatory action may
be appropriate for controlling same.  However,  the Agency believes
that the requisite regulation can best be considered and  implemented
by State and local authorities who are better able to evaluate the par-
ticular  local circumstances  with respect to the nature and extent  of
the noise problem and the requisite safety considerations involved. Any
comprehensive Federal regulation in this area could be overly diverse
and  cumbersome.  The EPA encourages in this regard the interaction
between local and State governments and the  railroads directly con-
cerned in solving  the particular local noise problems associated with
                             R-7

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the use of such warning devices. Such  interaction has taken place,
examples of which  are included in the Background Document, and has
apparently  produced both  safe and  cost effective  solutions to these
local noise problems.  However, if local authorities, after having first
sought solutions with the railroads involved, have  still  not been able
to resolve their problems,  they are  encouraged to then direct their
concerns to the EPA for  possible further  Federal action.
    The South  Carolina Department of Health and Environmental Con-
trol and the Oregon Department of Environmental  Quality expressed
the opinions that  acoustic warning devices are not needed around rail-
road yards, and are overused by the railroads, respectively.
    The EPA  has determined that the use of such warning devices in
and around railroad yards is not entirely out of place due to the often
heavy intermingling of workers and mobile equipment with locomotives
and rail cars.  Such use  may of course be beyond the extent necessary
to ensure safety,  not only in railroad yards but wherever else railroad
horns,  bells,  and whistles are used. The term "overused" however,
is relative to  the  particular  circumstances surrounding such  use:
whether,  for example, a railroad  yard or rail-highway intersection is
situated in a residential as opposed to an industrialized area. These
situations are instances where the EPA's  recommendation for railroad
and community interaction is at this time the most appropriate means
of achieving effective warning device noise abatement.
                              R-8

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   R.  Leath stated that railroad acoustic warning signals are ineffec-
tive due to the often loud ambient noise levels that exist in motor vehicle
interiors due to radios and other noise sources.
   Acoustical  analysis available to the Agency indicates that the
effectiveness   of  acoustic warning signals as  used on police and
emergency  vehicles as well as  urban buses and trucks is a function
of frequency or tonal characteristics as well as amplitude or loudness.
That is, recognition is achieved by a particular fixed or variable fre-
quency of a reasonable loudness  that impinges  itself upon whatever
ambient noise  may exist.  This view is in accord  with the study refer-
enced  above which indicates that railroad warning signals do not appear
to be unrelated to safety, especially in emergency situations.
    R.  Leath also indicated that roadway  drop  gates equipped with
flasher units provide visual warning that is adequate without acoustic
signals.
    EPA encourages alternate solutions to  the routine use of acoustic
warning devices at rail and road crossings.  For example, the elim-
ination of  public grade level railroad  crossings would do away with
 the  source of the problem, the intersection of  rail tracks and  public
 thoroughfares.   Such a program on a national  basis of elevating or
 depressing either the railroad line or the public thoroughfare at each
 crossing, solely for the  purpose of the abatement of  acoustic warning
 signal noise,  is  not considered appropriate.  However,  it should be
 seriously  considered  in   future public thoroughfare  or railroad line
 construction programs for both safety and environmental noise reasons.
                              R-9

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   Warning gates  too,  as suggested, would  appear to be an effective
safety alternative to acoustic warning signals.  Specifying their use on
a national basis, however, would be prohibitively expensive considering
that costs  range from  $45, 000 to $90, 000 per unit, and that with the
extensive use of grade level crossings in the United States,  for example
Illinois having  15,000  railroad  crossings without drop gates, the cost
would be $675 million or more in that State alone.
    b. Repair and maintenance shops, terminals, marshaling yards,
humping yards,  and specifically,  railcar retarders.
    The Association of American Railroads commented that the EPA
should prescribe noise  standards for area-type sources such  as yards
and terminals.
    The  facilities  and  equipment  found within railroad  yard and
terminal areas,  with the exception of locomotives, rail cars, and some
mobile special purpose equipment,  are permanent installations which
are normally subject to the environmental noise regulations of only one
jurisdiction.
   The Agency has determined that such fixed facility railroad yard and
terminal noise is best controlled at this time at the local level,  employ-
ing measures which do  not in themselves affect the movement  of trains
and therefore do not  require national uniformity of treatment. Signif-
icantly, the Agency has received no indication that existing State or local
ordinances  which  regulate noise emissions from such fixed facilities,
have in fact created  any substantial burden  on interstate commerce.
                              R-10

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Local jurisdictions  are familiar with  the particular complexities of
their their community /railroad yard noise situation,  and as such, are in
a position to  exhibit greater sensitivity in prescribing practical  and
cost effective solutions to the  local noise problem. Indeed, although
the AAR has encouraged the establishment of Federal area noise stand-
ards for yards and terminals, it specifically pointed out in its remarks
that such facilities do vary in size, shape, and special characteristics,
and that the noises produced there are  diverse.  The EPA  recognizes
that the  communities which neighbor  these yards  and  terminals  are
equally  diverse,  varying in  land zoning and  population  density  and
distribution. As such, a Federal regulation which successfully produces
substantial  population health and welfare benefit at one locality may
produce little or no such benefit at another locality.  For  example,
the regulation of  a railroad yard facility which is enveloped by a resi-
dential  community  would not  achieve similar population  health  and
welfare benefit when equally applied to a  similar railroad yard facility
which exists within a  large industrial park complex.  This observed
differential is  directly  attributable  to the different land zoning and
population density and distribution characteristics of the two commun-
ities.
    Acknowledging  both  the   single  jurisdictional nature and  the
diversity which characterize railroad yards and  terminals  and  their
neighboring communities, and citing the virtual absence of evidence that
nonuniform  State and local regulation of railroad yard and terminal
facilities in fact substantially burdens interstate commerce, the Agency
                                R-ll

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 at this  time does not  propose to establish standards for the regulation



 of railroad yard and terminal fixed facility noise.



    The Department of Transportation commented that the EPA should



 regulate retarder noise emissions. They indicated that active retarders



 should be regulated by October 1976 since established barrier technol-



 ogy makes it  possible to meet that schedule.  DOT further stated that



 a plan to convert to retractable inert retarders should be implemented



 by 1979.



    The EPA recognizes that rail car retarding operations may produce



 individual  peak noise  levels of up to 120 dB(A) at 100 feet, and may



 be a problem  noise source  to  the surrounding community.  However,



 as with other fixed facilities,  retarders are subject to only one juris-



 diction, and as such can best  be regulated at the local level by means



 which do not in themselves  affect the movement of trains and therefore



 do not require national uniformity of treatment.



    The Agency's  study of  railroad yard noise (inclusive of retarder



 noise) indicates that concern for noise from railroad yards is apparently



 limited to certain  locales,  and is not  a national concern.  This is due



 in large part  to the location of a number of  yards  in non-urban areas



 and the relatively few existing retarder systems,  approximately 120



 today.  This local nature of  the retarder noise problem further reduces



 the desirability of a Federally  preemptive regulation.



   DOT's  comment in  support of a Federally preemptive retarder noise



 regulation  which would  utilize barrier technology does not consider



the local characteristics  of each community which is  impacted by retar-



der noise.    For example, in a situation where a retarder  yard  is




                              R-12

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bordered  on one side by  a residential area and on all other sides
by an unpopulated wooded area, a barrier could be beneficial to public
health and welfare on that side of the retarder which faces the residen-
tial area. Under such circumstances a community would receive insuf-
ficient health and  welfare benefits  to justify  the costs incurred by
a Federally  preemptive regulation which mandates  the installation of
barrier walls on both sides of retarders. At the currently estimated
materials cost  of  $70 to  $100 per linear foot for barriers, barrier
costs would run from $50 thousand to  $100 thousand per railroad yard
and from $9.6 to $19.1 million for the entire railroad industry. Main-
tenance and replacement costs, yard down time, and track modification
costs have  not  been fully identified. Expenditures  should be assured
of producing maximum  benefits,  and this may  best be done  through
local regulation. Available  space for  installation  of  barriers,  and
safety  hazards, which might accrue thereto, have not been identified,
and  are peculiar to the particular characteristics  of the  individual
railroad yards, and as  such may be best accounted for through local
 regulation.
    A Federal regulation for conversion of inert retarders to retract-
able inert retarders would be subject to considerations similar to those
discussed for the erection of barriers around active retarders, except
that probable yard down time and installation and materials costs would
be considerably greater for conversion to inert  retractable retarders
than for the erection of barriers.  The EPA  estimates that conversion
to retractable inert retarders would cost $7.5 thousand for each re-
tarder,  not  including labor, yard down time, or maintenance costs.
                             R-13>

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Applying a gross estimate of 20 thousand such  retarders nationally,
estimated national conversion costs to the retractable mode, exclusive
of labor, yard downtime, and operational costs, would be $150 million.
    Although the EPA does not currently propose to regulate retarder
noise, it does recommend that local jurisdictions  establish regulations
which require railroads  to utilize barrier technology where needed,
and where both practical and feasible.  Further consideration may be
given by the  EPA to  possibly providing future regulations to  require
that new retarder installations be equipped with retractable inert re-
tarders,   computer  control  systems,   retarder  beam lubrication
systems, or other available  technical developments which result in
significant  noise  reduction  from  retarders as  the  need for  such
regulations is demonstrated  relative to the  costs   involved and the
availability of of technology.
    DOT also commented  that the EPA  should promulgate a regulation
which protects railroad workmen as well as the community from retar-
der noise.
    For reasons outlined above, the EPA does not  presently propose to
regulate retarder noise from either the community health and welfare
or the occupational health and safety point of view.  The latter consid-
eration is specifically under the purview of the Occupational Safety and
Health Administration (OSHA)and is properly addressed by that Agency.
    Currently, the Federal Railroad Administration (FRA) is proposing
a regulation which would limit noise levels within railroad workmen's
sleeping quarters.  This proposal is in response to a petition from the
Congress of  Railway Unions (CRU) that the FRA  institute rulemaking
                             R-14

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procedures to prohibit railroads from having  or providing employee
sleeping quarters less than one mile from its property or yards where
switching or  humping operations are performed.  The FRA's proposed
regulation  does not regulate the  distance of sleeping  quarters from
the railroad yard; however,  it does specify acceptable interior noise
levels for sleeping quarters.
    c.  Special purpose equipment.
       The  Association of American  Railroads  commented  that  the
EPA should promptly establish noise  limits applicable  to  the noise
from special purpose equipment.
       Examples of special purpose equipment which may be located
on or operated from  rail cars include:  ballast cribbing machines,
ballast regulators,  conditioners and scarifiers, bolt machines,  brush
cutters, compactors, concrete mixers, cranes  and derricks,  earth
boring  machines,  electric  welding machines,  grinders,  grouters,
pile drivers, rail heaters, rail  layers,  sandblasters,  snow  plows,
spike drivers, sprayers and  other numerous  types of maintenance-
of-way  equipment.
        The Agency realizes  that  special  purpose equipment such as
that used for maintenance-of-way activities is  essentially construction
equipment,  and as such may emit loud intermittent noise.  Railroads
may avoid  noise problems  by keeping routine maintenance  activities
to  reasonable times, and local jurisdictions may easily regulate oper-
ation times for such equipment as long as exceptions are allowed for
emergency use. For example, a community may wish to regulate the
hours allowed for  routine operation of spike  driving equipment, but
                              R-15

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 exception must be made for the operation of such equipment in  the
 aftermath  of a  derailment,  so  that  interstate  commerce would  not
-be unduly impeded.            -
        The small numbers of such  equipment*  their infrequency of
 use, and the relative  ease with  which viable local regulations may
 be instituted, all tend to make a Federally preemptive regulation overly
 expensive relative to the benefits received.
        Comments received by the Agency  did  not  indicate  that any
 cases currently exist  where  nonuniform  local or  State regulation of
 special purpose equipment has unduly burdened those railroads so regu-
 lated, and at this time the Agency does not believe that special purpose
 equipment  requires national  uniformity of treatment.  However,  the
 rail cars themselves on which such special purpose equipment is located
 are included under the standards for rail car operations. The Agency
 continues to solicit notice of specific cases where nonuniform local
 or State regulation of special purpose equipment has created a burden
 on interstate commerce.   If in the future it appears that national uni-
 formity of treatment of such equipment is appropriate, noise emis-
 sion standards may be proposed.
                             R-16

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   d.  Track and Right of Way.
       The Minnesota  Pollution Control Agency, the Illinois Environ-
mental Protection Agency,   and the ADM  Company raised questions
dealing with  the  absence of track  and right-of-way standards in the
proposed  regulation.   The  Minnesota Pollution Control Agency and
the Illinois Environmental Protection Agency stated that in view of the
fact  that the  EPA had  preempted State and  local authorities from re-
gulating track and right-of-way in the Notice of Proposed Rule Making,
it was in  conflict with its mandate to  issue noise emission standards
reflecting "best  available technology" since the regulation itself did
not  contain any  track standard.  The ADM Company was concerned
that  since a  track  standard was not included in the regulation,  quiet
railcars might be penalized for wheel/rail noise caused by faulty track.
        The EPA  fully recognizes the need  for track and right-of-way
standards in  any regulatory strategy that attempts to quiet the move-
ment of rail  cars.
        The standard promulgated for rail cars applies to the total  noise
produced by the operation of trains on tracks. As such it is preemptive
with respect to both rail cars and track.   It reflects the noise  level
achievable by application of best maintenance standards to rail  cars.
Further reductions in noise levels are achievable through various  track
repairs and  modifications.  However, the EPA has not fully identified
the available technology or the  applicable costs associated with such
practices.  In the future, the EPA may propose standards which  would
require their application.
                              R-17

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    e.  Rail cars equipped with auxiliary power equipment, and mass
transit systems.
    The Department of Transportation and Fruit Growers Express Co.
recommended  the  inclusion  of   noise standards  for  mechanically
powered refrigerator cars in the regulation.  In addition,  the National
Railroad Passenger Corportation (AMTRAK) called for separate regu-
lations  dealing with  passenger related  cars  equipped  with auxiliary
power equipment.
    The initial decision' by the Agency was to regulate noise from  all
sources produced by  rail  cars while in motion only, and to leave to
State and local authorities the regulation of whatever  noise is produced
from rail cars while stationary. This decision was made because these
noises are a problem  only  when  such  cars  are  parked  near noise
sensitive areas  (such noises being indistinguishable from other rail--
road car noises while the cars are in motion),   and because it was
felt that  such localized problems could best be controlled by measures
such as  the  relocation of  such cars to less noise-sensitive  areas.
    The Agency   was and continues to be cognizant of the extent of
the problem  that can be caused in specific instances by the continuous
operation of thediesel or gasoline engines which operate on such cars.
Noise  levels as high as  75 dB(A)  at 15 meters (50  feet) are possible
from refrigerator  cars parked with  their cooling systems running
in marshalling  yards and  humping yards. Noise from refrigeration
cars becomes a more appreciable problem due to the fact that operating
refrigerator  cars are often parked  coupled together in large numbers.
                               R-18

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A dditional data acquired by and supplied to the Agency has shown that
the problem exists not only with refrigerator cars but also with various
passenger-related  cars  such as dining cars,  lounge cars,  cafe-type
cars, and others equipped with self contained power units; and that
the abatement of such noise appears able to be and in certain instances
is now being accomplished through the use of existing muffler designs.
In this regard, and in response to  the point raised by Fruit Growers
Express Co.,  the statements on p. 4-28 and 4-37 of the original Back-
ground Document  have been corrected to reflect the use  (although of
undetermined  adequacy) of mufflers on the auxiliary engines used in
refrigerator cars.
    The Agency therefore  may  consider  the possible promulgation of
a  regulation dealing with the noise produced by mechanically refriger-
ated freight cars and passenger cars equipped with auxiliary power
equipment so as  to reduce the impact of such noise when these cars
are parked near noise sensitive areas.
    It should be noted that  in  the regulation being promulgated herein,
the standard for rail    car operations refers to the total noise gen-
erated,  and that  the setting  of emission standards on any element of
that noise is  preempted, whether the rail  car is  in motion or sta-
tionary.   This Federal  regulatory action does not,  however, interfere
with  the ability of State  and  local  governments to  enact or enforce
noise  emission    regulations   on   railroad  yards  that require
railroads   to   erect  noise  barriers.   Nor  does  this  regulation
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interfere with the  ability  of State and local governments to enact or
enforce noise emission regulations which require the  relocation of
parked rail cars that generate noise  so long  as such  regulation is
reviewed and approved by EPA pursuant to Section 17(c)(2) of the Act.
    Fruit Growers Express Co. asked for an extension of the period of
time prior to promulgation of the final regulation so that refrigerator
car  noise emissions could be studied in relation to wheel/rail  noise.
    Studies  and data considered by the  EPA show that such noise can
range from 72 dB(A) (Thermo King Corporation,  a major manufacturer
of refrigeration equipment,  1975) to 75 dB(A) (Wyle Laboratories, an
acoustical consulting firm, 1973),  and that it is indistinguishable from
overall train  noise while  the  train is moving.  As such, and  in the
absence of a showing that the existing data is questionable, no extension
has been granted.
    The Department of Transportation expressed concern for the fact
that very few  refrigerator cars are owned by the railroads,  and that,
consequently,  refrigerator car  owners'  ability to pay  for  mufflers
should be considered quite apart from  the economic position  of the
railroads.
   As indicated above, this regulation does not require the abatement
of refrigerator car auxiliary equipment  noise, and accordingly there
is no related  cost  of compliance incurred.   Consideration as  to the
costs to  be incurred by the'actual  owners of such rail cars as may be
affected  by  any future regulatory action would be  fully and adequately
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addressed during the course  of the regulatory process that would be
conducted relative to such regulation.
    Citizens Against Noise suggested that the regulation be made appli-
cable to  the  operation of and equipment utilized by intraurban mass
transit systems.
    The Agency  has not  intended  and does not intend that intraurban
mass transit systems  be covered by the regulation being promulgated
herein.  It is the Agency's judgment that such systems are specifically
excluded from regulation under  Section 17 of the "Noise Control Act
of 1972 by the  definition of'carrier cited in the  Act which excludes
"... street,  suburban, and interurban  electric railways unless oper-
ated as a part of  a general  railroad system of  transportation."  In
addition such systems operate principally within one jurisdiction  or
in some cases throughout a small number of contiguous metropolitan
jurisdictions under the purview of a single  transit authority, and  as
such do  not appear to require uniform Federal regulation in order
to  facilitate interstate commerce.   However,  the exclusion  of such
systems does not also exclude the operations and equipment associated
with commuter  rail services provided  by a number of  interstate rail
carriers.
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 Section   201.11  -  Standards  for  Locomotive  Operations  Under

 Stationary Conditions.

       a.  Locomotive at Idle

       Both General Motors and the AAR commented on the proposed

 idle standard. While the AAR comment was general  and they stated

 only that a muffler that meets the proposed full throttle standard is not

 likely to meet the idle requirement too, General Motors' comment was

 quite specific and was  backed by  data. Within the text of the General

 Motors  document  entitled "Additional Comments of General Motors

 Corporation  With Respect to the Proposed Railroad Noise Emission

 Standards,"  General  Motors offers a graphical analysis of idle noise

 level emissions as measured for SD40-2,  GP39-2, and GP38-2 loco-

 motives.  The graphs compare A-weighted octave band sound levels

 measured  at three feet from the exhaust outlet and 100 feet from the

 side of the locomotive during  full  power.  Radiator cooling fans were

 not operating during  the time of the testing in order to eliminate their

 influence.  Quoting General Motors:

         Inspection  of  these   plots  shows   that  a good
      correlation   for all three locomotives can be made  be-
     tween the full power exhaust noise inspection at three feet
      and the  overall locomotive noise inspection measured at
     100 feet,  when a 30 dB attenuation factor for hemispher-
     ical sound spreading is used to correct for the increased
     distance.  For most points,  the measured octave band
     level at 100 feet,  is less than  that predicted using the
     30 dB attenuation  factor  indicating excess attenuation not
     accounted for.  When  the measured octave  band level is
     greater than that predicted, structurally radiated locomo-
     tive noise is contributing to the overall locomotive noise.

     In  the General Motors document entitled  "Comment of General

Motors Corporation with Respect to Proposed Railroad Noise Emission

Standards,"  General  Motors states "that  our  tests have  shown that

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a muffler capable  of reducing number 8 throttle position, full power

locomotive noise by 5 dB (A) at 30 meters,  reduces the idle locomotive

noise only 0.5 dB(A ) at 30 meters." This statement is not backed with

specific data as was the case in General Motors Additional Comments.

     Based on the above.  General Motors summarized that a standard

of 67 dB(A)at 30meters during idle is  not considered feasible by muf-

fler technology alone,  that engine exhaust  is not the  dominant source

mechanism when the locomotive is in idle, and that structurally radiated

sounds are dominant:

            It is  GM's opinion that extensive car body treatment
         such  as the  addition  of sound absorbing and  damping
         materials,   the  addition  of  access  door seals,  the
         replacement  of access doors and panels with acoustical
         shielding, or any combination of these methods,  would
         be  necessary in  an attempt to achieve a  standard
         67 dB(A) at 30 meters under idle conditions.  Such car
         body  treatment violates the basic design concept of the
         narrow multi-door  hood-type locomotive which number
         approximately 90%  of  the locomotives in use, in that
         it would greatly restrict the  ease of maintenance and
         compliance.

    GM estimated that  car body modification alone would cost as much

or more than a muffler retrofit program.

    The General Motors data  indicates that certain idling locomotives

emit noise levels dominated by structural radiation which  may be as

high  as  69 dB(A) at 100 feet.   EPA data  further indicates that some

locomotives may emit idle  noise levels in excess of 69 dB(A) which are

also dominated by structurally radiated noise. Locomotives with such

high levels of structurally radiated noise cannot be brought  into com-

pliance with the proposed level of 67 dB(A) through, for example, muf-

fler application alone.  Accordingly, the Agency has amended the loco-
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motive idle noise standard, increasing the allowable noise emission
level from the proposed 67 dB(A) to 70 dB(A) at 100 feet.
    The  National    Railroad    Passenger   Corporation  (A.MTRAK)
commented  that diesel  electric  locomotives  equipped  with auxiliary
power generators or twin traction engines, and gas turbine locomotives,
may not be able to meet the idle standard, and that  special standards
should be promulgated for such equipment.
    In proposing this regulation the Agency intended to provide Federal
preemption  for all locomotive noise sources  excepting  acoustical
warning devices, thus providing national uniformity of  treatment for
these mobile noise  sources. Accordingly, State and local regulation
of noise emissions from such locomotives equipped with auxiliary gen-
erators used to power electrical  units on passenger  cars,  including
the noise from such auxiliary generators per se, should be Federally
preempted.
    Thus the Agency has determined that Federally preemptive regula-
tion of noise from auxiliary power units is appropriate.  However, the
noise from such sources was not specifically addressed by the Agency
during rule making, and the standard as proposed considered only idle
setting noise emissions from the primary propulsion engines of the
stationary locomotives.
    Because passenger locomotives do spend considerable time in a
stationary disposition with auxiliary power units operating at the same
time that the primary diesel  engines  are idling,  the  Agency forsees
circumstances where the auxiliary  unit noise may dominate other noise
emissions from the idling locomotive, and thus be  appropriate for
regulatory action. After further consideration of this matter the Agency
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may address noise standards for such auxiliary units in a separate rule
making. However, because the intent of the Act was to provide national
uniformity of treatment  where non-uniform State and local ordinance
could likely impose a burden on interstate commerce, and because the
locomotive as a whole is subect to this regulation, the Agency believes
that its regulatory  action  relative to locomotive noise emissions is
also preemptive with  respect to State and local  ordinances relative to
noise emissions from the  auxiliary power units which  are an integral
part of many such locomotives.
    The Agency has received no  data which would indicate that twin-
engined diesel-electric locomotives are in fact incapable of compliance
with the idle   standard.   Since the Agency has no data which  would
demonstrate that twin diesel engines are inherently louder than larger
single diesel engines, and since twin engined locomotives utilize the
same  basic diesel-electric technology as  the  more common  single
engined   locomotives,     separate   standards   for  twin-engined
diesel-electric  locomotives   are  not   included in this regulation.
The standards  as promulgated  are therefore applicable to these loco-
motives.
    While the Agency has sufficient data to confidently assess the ability
of  gas turbine-powered locomotives to meet the  moving  condition
standard, the  Agency has not been able to acquire sufficient data on
the  idle   setting or stationary  runup  noise  levels  of  gas turbine
locomotives.   Due to the virtual unavailability of such stationary noise
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data,  the regulation as proposed has been revised, and the idle setting
and stationary runup noise standards are no longer applicable to gas
turbine locomotives.   However,  this regulation is  preemptive with
respect to State  and  local regulation of all turbine locomotive noise,
excepting that  from acoustical  warning devices, including  regulation
when  such  locomotives  are stationary at  idle.  After the Agency has
compiled a sufficient database, idle settings and stationary runup noise
standards for gas turbine locomotives may be established as  a revision
to these regulations.
   b.  Locomotive at any Throttle Setting Except Idle.
   The U.S.   Department of  Transportation  (DOT) questioned the
acoustical  acceptability of the typical load- cell test sites and the valid-
ity of self  loading due to the  unaccounted for influence of noise emis-
sions from the dynamic brake grid fans.  Also cited was the possible
obstruction of routine  railroad  operations  due to local enforcement
of the stationary  standards.
   DOT indicated that areas near railroad load cells are not far enough
from  reflective surfaces to be effective test sites. They also indicated
that if load cells are to be  used for enforcement,  the  EPA should
prescribe  correction factors  to account for the acoustical variability
of actual load  cell test sites.
   In answering  the  above claim that load  cells are unsuitable for
locomotive noise measurement because they are situated too close to
reflective  areas,  the EPA cites  the fact that  a  number of load  cells
are portable and are readily available on a rental basis. These portable

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cells  may  be  transported  to  an acoustically  acceptable  site  for
locomotive noise testing. At such sites, accurate and meaningful noise
measurements may be obtained without  the use  of site  correction
factors.
   Additional DOT response  indicated that the self loading test  is not
valid because the cooling  fans on the dynamic brake grids operate
during self-loading,  while in  actual  operations,  grid  fans are  never
operated. They state that the inherently high level of noise attributable
to cooling fan operation  (both engine and dynamic brake grid fans)
during self load would interfere with the accurate and meaningful meas-
urement of exhaust noise.
    The EPA has considered the above comment and believes  that objec-
tions to  the self loading test are valid.   Therefore,  considering the
difficulties involved  in obtaining accurate  measurements  due  to the
interference of dynamic brake grid fan noise, and citing the availability
of portable rented load  cells,  the Agency has decided to delete the
self loading test as a recommended stationary testing procedure, while
simultaneously endorsing the  use of portable load cells.
    DOT indicated concern that enforcement of stationary  standards
could result in significant obstruction of routine railroad  operation
and hence interfere with the flow of interstate commerce. That is, any
enforcement official could order any one  or any number of locomotives
to be moved to  a load cell or self load  area for testing, regardless
of the maintenance work schedule at the  load cell or  the need for the
subject locomotives to be engaged in interstate commerce.
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    Such potential  difficulties have been considered by EPA,  and the
Agency believes that their effects  may be  minimized through proper
structuring  of the  DOT compliance regulations which  may  specify
responsible enforcement procedures.
Section  201.12 -  Standard for  Locomotive Operation Under Moving
Conditions;
    The  U. S. Department of Transportation (DOT) favors a  moving
locomotive  standard  as a substitute for  a stationary standard,  but
stated that EPA's  definition  of wayside surface conditions should be
improved.
    The EPA strongly believes that a stationary as well as a moving
locomotive  standard  is necessary  in order to account for the varying
nature of locomotive noise.   Utilization of both  stationary and moving
standards also facilitates  adequate and accurate enforcement.   The
additional measurement criteria which are being incorporated by the
EPA as part of the final regulation will  specify wayside  surface con-
ditions in greater  detail.
    The National Railroad Passenger  Corporation (AMTRAK) indicated
that the moving locomotive  standard should be speed related as is
the case with the  rail  car standard. They further stated that gear
noise, traction motor noise,  and noise from locomotive appurtenances
are speed  related.
    EPA data indicates that while diesel-electric locomotive noise does
not appear to be speed related,  electric freight, electric high speed
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passenger, and turbine  high speed passenger noise levels do exhibit
some speed-related correlations.   However,  the high speed noise
emission levels exhibited by these locomotives appear to fall within
the EPA's  90  dB(A) standard, and should pose no special  compliance
problem.
Section  201.13  - Standard for Rail Car Operations;
    DOT indicated that  it is appropriate to limit any car regulation to
at least  two degree or wider turns as with the locomotive standard.
    The  EPA concurs with that statement and has made the appropriate
changes in  the Rail Car Standard.
    A private car owner,  the ADM Company, was concerned that the
EPA Rail Car Noise Standards would require greater maintenance than
that prescribed  by  the  FRA (1974)  Railroad Freight  Car Safety
Standards already in effect.
    The EPA Rail Car Noise Emission Standards  are based on those
noise levels achievable through best practice maintenance.   As such,
the data used to determine the noise level standards was obtained from
noise measurements of typical rail  cars which were subject to main-
tenance requirements  no  more  restrictive than those currently pre-
scribed by the FRA Railroad Freight Car Safety Standards.
    Since the data which were  used to determine the Rail Car Noise
Emission Standards were  based on current maintenance requirements,
compliance with  the noise regulations is not anticipated to cause any
additional maintenance burden.
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    Shell Oil Company,   a private car owner,  stated that the Federal
 standards  on rail car noise should not apply to privately owned cars
 because private owners  do not have the ability to service cars engaged
 in interstate commerce.
    The Agency replies  that while ultimate responsibility and liability
 for rail car maintenance lies with rail car owners, immediate respon-
 sibility and liability is assumed by the rail carrier who is moving the
 car in interstate commerce, and who does possess the ability to service
 rail cars.
 Section 201.11, 201.12, 201.13 - 365 Day Standard;
    The U. S.  Department of Transportation (DOT)  stated that the 365
 day standards provide a disincentive to  rebuild old locomotives into
 compliance or to specify newlocomotivesbe delivered with the mufflers
 needed to achieve compliance.
    Since the  Agency has elected to delete the retrofit requirement
 due to disparities in current cost and technological data,  only the sec-
 ond part of the above comment  requires consideration.  The Agency
 intends the 365 day standard to be a "best maintenance practice" stan-
 dard which precludes further deterioration of locomotive noise levels,
while allowing adequate time for application of the available technology
prior to the  effective date of the more restrictive newly manufactured
locomotive standards.
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C.  COMMENT ON ADDITIONAL ISSUES
    1.  Meeting the Standards with Newly Manufactured Locomotives
    The Association   of  American  Railroads  and General Motors
Corporation both indicated their support of newly manufactured locp-
motive regulations, and Donaldson Company, Incorporated, stated that
the technical and production capability does exist  for  new  locomotive
muffler applications. Having received no appreciable comment in oppo-
sition to the regulation of newly manufactured locomotives, the Agency
has promulgated best technology  noise  emission standards applicable
to locomotives whose  manufacture is completed four years  from the
date of promulgation of the regulation.
     2.  Meeting the Standard with Existing Locomotives (Retrofit)
       a. Economic Considerations
           (1) Impact in General
Economic Comments of the Association  of American Railroads
    The Association of American Railroads  (AAR) commented that the
EPA vastly underestimated retrofit/muffler introduction costs, with
costs actually running between  $6,390 and $12,890 per locomotive.
              (a) The  AAR indicated that the  EPA did not properly
account for:
                 (1) Increased annual fuel consumption of 40, 000, 000
gallons,   or 1%  of present consumption,  at  an  additional cost  of
$11, 600,000 per annum.
                 (2)  Increased maintenance expenses.
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               (3) Capital cost of new facilities for retrofit.
               (4) Cost  of repair  to  internal parts  of  locomotives
 damaged  by a poorly working muffler  (the direct result of increased
 backpressure).
               (5) Replacement cost of mufflers.
               (6) A $14.18/hour  labor  charge, instead of the  EPA
 figure of $5. 80/hour.
           (b) EPA underestimated the number of locomotives involved
 in the retrofit (by 13% error).
           (c) EPA underestimated the value  of a "locomotive day."
           (d) EPA did  not take into account the "bottleneck" effect of
 stoppage at any point in the total operation of the railroad system due
 to locomotive downtime.
           (e) EPA's  cost  ignores the very important  matter of the
 probable forced retirement of some 1, 000 older Alco  and Fairbanks
 Morse locomotives due to retrofit.
              (1)  The railroads and locomotive manufacturers are cur-
 rently working at  capacity.  Any  forced retirements would accentuate
 the locomotive shortage.
              (2) Replacement costs would run from  $250, 000, 000 to
 $400, 000, 000.
            (f) The EPA  rationale for using net revenue (in estimation
 of the financial burden of retrofit  in the Background Document) is not
 explained.   Net revenue  is irrelevant there; ordinary net income (ONI)
 should have been used.   If O. N. I. had been used,  ratios would have
been five times  as great as those shown in the Background Document.
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EPA Responses to Specific AAR Comments
    (a)(l) The EPA acknowledges that muffling of locomotives could con-
ceivably cause increased fuel  consumption of up to 1% annually,  as
estimated by the  AAR.   This percentage is based on an AAR estimate
where  the mufflers are  assumed  to  create additional backpressure
which equals the  maximum allowable backpressure specified by loco-
motive  manufacturers' warranties - 5 in.  H2O for EMD turbocharged
locomotives and 21 in.  H20 for EMD Rootes blown locomotives. Since
increasing  backpressure  generally  creates  a  proportionate fuel
increase, such worst case backpressure assumptions may be similarly
expected  to  project   an estimate   of worst  case increased fuel
consumption.
    The Agency believes that the 1% figure is  considerably high, since
for many locomotives,  mufflers may  be designed to produce a back-
pressure which is  substantially below the locomotive manufacturers'
warranty specifications; hence, fuel consumption increases for those
locomotives should be considerably less than the AAR's  projected 1%
figure.
    (a)(2) A   concern   over  increased  maintenance  expense  also
presupposes a considerable backpressure increase  due  to muffler
introduction,   with   increased  backpressure  causing   additional
maintenance requirements for internal locomotive parts.
    A recent   report  on computerized muffler design,  prepared  by
B.  H Baranek and Newman for the EPA, as well as several instances
where test  mufflers have been fitted to locomotives,  give indication
that sophisticated muffler design may restrict backpressure increases
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to substantially less than manufacturers' warranty specifications upon
application   to   most   existing locomotives.  This would result in
significantly less wear of internal locomotive parts. However, further
testing of physical prototype muffler applications would be necessary
for a  more  definitive  resolution to this problem.
    Maintenance requirement increases  are  also related to  muffler
failure rates.   Mufflers could be made out of anti-corrosive,  heat-
resistant alloys for a long service life. Also, an important considera-
tion is the fact that mufflers would be within  the carbodies of the loco-
motives and would not be exposed to the elements, thus extending their
expected useful life.  Large industrial mufflers have been designed for
a useful life of over 20 years and it is expected that locomotive mufflers
may be designed for a similarly long life  span.
    (a)(3) Studies completed  by  the  EPA  indicate that the  railroad
industry currently has approximately  9 percent excess shop capacity.
Further  information  concerning this subject  may  be  found  in  the
Background Document.
    (a)(4) Adequate testing of locomotive muffler applications  prior to
a widespread  retrofit program would preclude  widespread defective
muffler performance,  and accordingly, damage of internal locomotive
parts   due to a poorly working muffler  would  be  a  very infrequent
occurrence.
    (a)(5) As previously mentioned in discussion (a)(2), concerning in-
creased maintenance expense, locomotive mufflers may be designed
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for a long useful service life and they are protected from the elements
by enclosure within the locomotive carbody.  Accordingly, they should
require minimal and infrequent replacement.
    (a)(6) The Agency has conducted further study of the labor rate,
and has adjusted its estimated figure from $5. 80 to $7.92 per hour.
Further information concerning this subject may be found in the Back-
ground Document.
    (b) The EPA    acknowledges  this incorrect estimate and has  in-
 cluded a  13. 7% increment in its current retrofit cost analysis.
    (c) The  Agency   has  reviewed  its  estimate of the value of a
"locomotive day" and has arrived at a revised estimated value of $560,
as opposed to the EPA's original estimate of $1257. Further informa-
tion concerning this subject may be found in the Background Document.
    (d) The  Agency  believes that  enforcement regulations  will  be
promulgated which will be sensitive to locomotive scheduling and there-
fore will avoid any major cumulative disruption of rail services.
    (e) EPA data  indicates that the some 1, 000 older Alco and Fair-
banks Morse locomotives  in question are currently being retired at a
rapid rate, indicating that virtually the  entire population of such loco-
motives would be retired prior to the proposed 4-year  effective date  of
the retrofit requirement.  However, this is no longer a relevant con-
cern due  to the fact that retrofit has been deleted from the regulation
as promulgated.
        (f) The EPA elected to use net  revenue as opposed to ordinary
net income in the Background Document's estimate  of the financial bur-
den of retrofit because the Agency believes that net revenue is a better
measure  of the firm's ability to meet short run operating expenses
of the type incurred in a locomotive retrofit program.
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Other Economic Comment
    The DOT estimated $153 million for retrofit as opposed to original
EPA estimates of $80 million to $100 million  dollars, and Donaldson
Company,   Incorporated,   indicated that muffler and accompanying
hardware costs will be  2  or  3 times  higher  than estimated in the
Background Document, with costs  depending  heavily on the amount
of auxiliary hardware  required to overcome space and backpressure
limitations.
    Retrofit largely involves  the phased addition of  mufflers to the
existing  locomotive fleet.  Several docket entries contained economic
and  technological     data    which    conflict   significantly   with
the EPA data which appears in the Background Document.   The prin-
cipal areas of conflict involve disparities in  determination of the "best
available technology"  as  it exists today and the resultant costs of its
application.   There exists a further complicating factor  in  that the
available space configurations existant within many locomotives  have
been altered over  the years  due to the addition and  modification of
various locomotive components such as dynamic  braking systems and
spark  arresters.   As a  result  of  this practice  there  exist  today
numerous and  diverse locomotive configurations, each possessing its
own specific peculiarities' which must be accounted for in  a retrofit
program. The  implications of this  diversity of locomotive configura-
tions  and   the  accompanying   disagreement  concerning  available
technology and the  cost  of its application (i.e.,  labor rates, capital
costs of  new facilities,  etc.)  have given rise to cost of compliance
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figures  which  range  from  the  EPA's  original  estimates   of
$80  to   $100   million   to   industry   estimates  approximating
$400 to $800 million.  Although the generation of additional information
concerning the availability  of  technology  may allow the Agency  to
reconcile these widely varying retrofit cost estimates, the collection
of such data would be a costly and time consuming process which may
produce  a  retrofit  cost  estimate  which remains substantially high
relative  to the public health and welfare benefits which would result,
especially in view of the fact that railroad noise has not been identified
as one of the major sources of noise in the environment.  For these
reasons  the  Agency  has decided to  remove  the  retrofit require-
ment   from the  regulation  being  promulgated  herein. Acknowl-
edging the uncertainties which currently accompany  the retrofit  pro-
vision,  the Agency may reconsider the retrofit issue and may promul-
gate a retrofit requirement should further information indicate that the
technology is  available  and  that  retrofit  compliance  costs  are
reasonable, relative to the  health  and welfare benefits to be accrued.
        (2) Economic Impact on Bankrupt/Marginal Railroads:
        The Association of American Railroads, Mr. R. Harnden, and
Mr. K. K. King, expressed concern that  the regulations as proposed
may have substantial  adverse economic impact upon the bankrupt and
marginal railroads.
   The Agency has  endeavored to anticipate and account  for all costs
which the bankrupt railroads specifically, and all railroads generally.
may incur as the result  of this  regulatory  action. Best and worst
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case estimates for the  sum of equivalent  annual  manufacturing costs
and equivalent annual fuel costs over 25 years, vary from $4. 59 million
to $4. 76 million for the entire  railroad industry. The fractional impact
of these costs  on  the marginal and bankrupt railroads  is expected to
be approximately  28  percent  of  the total  cost to the entire  railroad
industry,   with   such   costs not  seen   as  being  significant   in
comparision to other costs regularly incurred by such railroads.
    (b) Technical Considerations
       The Association of American Railroads (AAR), the Illinois Rail-
road Association  (IRA),  and Donaldson Company,  Incorporated, indi-
cated concern that mufflers may cause  excessive backpressure when
applied to locomotives, especially when  coupled with spark arresters.
The AAR,  and the Salt River  Project, of Phoenix, Arizona, indicated
that this backpressure increase will cause an increase in fuel consump-
tion, with the  AAR also warning of increased chemical and particulate
air emissions.
    Mufflers can be designed which are well within the manufacturer's
warranty backpressure specifications,  for both Rootes blown and turbo-
charged locomotives, for use both with or  without spark arresters.
Mufflers which are within these specifications   should  cause  only
 insignificant increases in atmospheric  pollutant   emissions  and  a
 minimal increase in fuel consumption.
    The Forestry  Department of the State of Oregon urged the EPA to
carefully consider the production and control of carbon particles  in
the locomotive exhaust, and the  Association of American Railroads
                             R-38

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(AAR) indicated that carbon collection in mufflers presents a potential
fire hazard.
    The EPA has given careful consideration to the production and
control of carbon particles and sees no indication that properly designed
locomotive mufflers will interfere with effective spark arresting.
    Harco Manufacturing Company,  a member of the muffler manufac-
turing  industry,  reinforced this  posture in  their  docket response,
expressing  their professional  opinion that  effective mufflers can be
designed to integrate with spark arresters, while keeping within avail-
able space limitations.
    Presently there is no substantial indication that carbon collection
in locomotive mufflers would  present a potential fire hazard.   Within
spark arresters which are currently found on  today's  locomotives,
carbon particles are gathered from the exhaust gases prior to the pas-
sage of those gases through the outlet section of the spark arrester for
discharge  through  the exhaust pipes. While it could be postulated that
hot carbon might conceivably collect within mufflers which are in tan-
dem with or are integrated into spark arresters,  it could also be pos-
tulated that  such carbon  collection  might just as readily occur at the
outlets of spark arresters or within exhaust pipes which  are presently
found on locomotives.   However,  no such  fire hazard due to carbon
collection  has been evidenced  at spark arrester outlets or in exhaust
pipes, and the Agency sees no indication that the installation of mufflers
will substantially increase the potential for  such a fire hazard.
     The Association of American Railroads  (AAR) indicated concern
that increased  railroad  rates  to cover  compliance costs may cause

                               R-39

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 diversion of traffic to more fuel intensive modes which also emit more
 atmospheric pollutants.
     Original Agency analysis of this issue indicated that retrofit costs
 would,  in themselves alone,  be insufficient to cause a major increase
 in railroad freight rates. This EPA estimation was largely attributable
 to the relatively low magnitude of retrofit costs  in comparison to total
 railroad costs and operating expenses.   A further contributing factor
 is the fact that  a  large and increasing proportion of  railroad tonnage
 involves the transport of bulk commodities and raw materials such as
 grain and coal  for which there is  generally  little  cross-elasticity
 between  the  major   land transport modes.  Further information on
 this subject may be found in the Background Document.
     The Association  of American Railroads  (AAR) indicated  that the
 application of mufflers will result in decreased reliability of the loco-
 motives both with respect to failure of the mufflers themselves and to
 other components  of the locomotives.
     Mufflers could be made out of  anti-corrosive, heat-resistant al-
 loys for a long  service life.   Also an important consideration is the
 fact that the  muffler would be within the carbody of the locomotive and
 would not be-exposed to  the elements,  thus extending its expected use-
 ful life.   Large industrial mufflers have been designed for a useful
 life of over  20  years  and it is expected that locomotive mufflers may
be designed for  a similarly long.life span. Also,  the  design and util-
ization of mufflers which are within manufacturers' backpressure spec-
fications, should preclude major adverse effects to other internal loco-
motive components.
                              R-40

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    Donaldson Company, Incorporated, indicated that they see little
problem with the retrofit of switcher  locomotives, but that a visibility
restriction,  however,  may hinder direct application of the muffler
to the switcher's hood.
    Donaldson further  indicated that  the retrofit of road locomotives
will be more difficult, with the retrofit of turbocharged locomotives the
most difficult of  all. They attributed this  difficulty to the lower back-
pressure  and greater space restrictions of turbocharged engines, ex-
plaining that these space restrictions are further complicated by the
fact that turbocharged locomotives require large size mufflers due  to
their large  air flow.   Donaldson stated that the necessary  technology
is available to retrofit turbocharged locomotives; however, consider-
able design ingenuity will be required  to ensure its successful  appli-
cation.
    Donaldson Company indicated its  agreement that mufflers can pro-
vide between  8-10 dB(A) attenuation  (locomotive exhaust noise at 101
ft., full throttle),  but  beyond that noise  reduction level,  other nois<
sources become  dominant.
    The Association   of  American  Railroads  (AAR) indicated tha
exhaust muffler manufacturers would have difficulty in designing muf
flers for  particular engines,  unless  they knew all the parameters o
the engines involved.    Donaldson  Company reinforced this opinion  b;
stating that they do not have the capability to develop muf fling/silencin
systems independently  of the railroads or locomotive manufacturers
    Since the  regulation is now applicable to only newly manufacture
locomotives,  the  Agency foresees no problem  with the coordinatio
of both locomotive engine and muffler design in order to achieve ne
locomotive compliance.
                                  R-41

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     3.  Health and Welfare.
     E.  Schmidt,  R. Harnden, K.K. King, and the City of Bloomfield,
 New Jersey,  indicated that the EPA did not provide adequate informa-
 tion as  to  the number of people impacted by railroad noise nor  the
 number to be benefited by the regulation.  The Association of American
 Railroads called  for information as to whether such people were ad-
 versely affected from a health and welfare  standpoint initially.
     The Agency included  in  the Background Document studies and data
 which  indicated that the number of  people exposed  to  various noise
 levels by railroad traffic are significant.   Such numbers  appear to be
 approximately 2.29 million people  at  an  Ldn  value  of  55 dB(A).
 Exposure to  such noise  levels for  extended periods of time has been
 determined to have an adverse effect  on the health and  welfare of
 those exposed, as indicated  in an EPA  report of March  1974 entitled
 "Information  on Levels  of Environmental  Noise  Requisite  to Protect
 Public  Health and Welfare with an Adequate Margin of Safety." In ad-
 dition the EPA is establishing this regulation as part of  a regulatory
 strategy that, according to Agency analysis, could eventually relieve
approximately 520,000 people from railroad noise levels in excess
 of 55 dB(A), Ldn.
    E.  Schmidt, R.  Harnden, K.K.  King,  and the Salt River Project,
 contended  that   the  health  and welfare  of people is  not affected
 by railroad equipment which operates  in sparsely populated or rural
 areas and that,  therefore,  the  regulation of such  equipment  is  not
 called for.
                             R-42

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    The Agency  has   determined  that  there   is   substantial mo-
bility of the use of railroad  equipment  not  only  within particular
railroad operating  regions but across  the nation as a whole, and that
such mobility is an important facet of the manner in which railroad
companies operate.   This mobility is evidenced by  the fact that rail
cars and locomotives are transferred from one area to another in order
to satisfy the fluctuations in required hauling capacity which take place,
and by the practice whereby old line locomotives are retired by trans-
ferring them to railroad yards to act as switchers. It has been found that
such mobility is increasing as evidenced by Railbox, a plan utilized
by a growing number of railroads whereby rail cars are pooled so that
their use  may be  shared anywhere within the operating regions of the
participating railroads.
    The Agency has determined, therefore, that the mobility of rail cars
and locomotives requires  that the standards be applied uniformly to
all such pieces of equipment.
                             R-43

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    4. Legal Considerations.
    The Association of American Railroads raised a number of legal
questions in its comments to the proposed regulation.   These questions
dealt primarily with the scope of the  Agency's  duties  and authority
under the Noise Control Act of 1972, and Section 17  in particular,  as
they apply to the Agency's decision not to regulate all railroad facilities
and equipment at this time,  and with the Agency's interpretation of the
preemptive effect of the regulation.
    The  AAR  indicated that  the  EPA has improperly exercised
its authority to regulate noise from the operation of railroad facilities
and equipment in that, as a matter of statutory interpretation, all rail-
road noise  sources  must be  regulated according  to the Noise  Control
Act of 1972.
    The Agency, after an analysis which considered the language of the
statute  as well as its legislative history, feels  that it does have the
authority to decide  and indeed should decide what priority should be
given to  the regulation  of various sources of railroad noise,  all of
which differ in  their impact upon the society  and the need for their
uniform  regulation.    The EPA does not take the position that there
are any sources of railroad  noise that it will not regulate.  The Agency
may consider the possible regulation of other sources of railroad noise
under Sections  6, 8, and 17 of the  Act,  and  may  regulate  such
additional sources as the need for and feasibility of such regulation
becomes established.
                              R-44

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    The  AAR   also  questioned   whether   the   Agency  has  the
authority to offer an opinion as to the preemptive effect of its regula-
tions, and in particular,  felt that,  contrary  to  the  Agency's stated
position,  the setting of Federal emission  standards  for  locomotives
and rail  cars preempts  every effort to control noise  from that same
equipment by local and State authorities, such as the required erection
of noise  barriers, or the regulation of overall rail road  yard noise.
    The EPA believes that the Noise Control Act of 1972 is clear in its
contemplation that Federal and State governments work together in the
control  of noise.   However, the Act also  provides,  in some  cases,
that the Federal authority be preemptive.  The Agency therefore feels
that it is  proper for it to explain the extent of its regulations and to
indicate  the point beyond which the States and local governments may
act; and  that it is not  prohibited from assisting  the State and local
governments by indicating ways in which the Agency believes they may
augment its regulatory efforts. In addition the EPA's analysis indicates
that, based  on legal precedents, subsections 17(1) and (2) provide only
for the preemption of State  and local regulations which set standards
on the noise emissions of Federally regulated  equipment or facilities,
or  which  have  that effect by  requiring  the modification  of  such
equipment or facilities, or the alteration of  their use.
    The  Illinois Railroad Association  indicated  that  State  and local
governments  do not have the inclination or  ability to  determine the
technical feasibility and  cost of compliance of noise regulations and,
therefore, the EPA is not  acting in accordance  with the instructions
of Congress by encouraging such local initiative.
                               R-45

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    The Agency  believes as stated above that the Congress did  intend
that the Federal and State authorities cooperate in the control of noise.
Certain  States,  in  particular California,  and Illinois,  have well
established environmental agencies and have enacted and are enforcing
comprehensive noise regulations. These States and others are clearly
not devoid  of technical  and economic expertise.    It appears  to the
Agency, therefore, that there is no fundamental reason why such  States
should not be permitted  and encouraged to  consider  the technology
available within relevant economic restraints to solve those noise prob-
lems peculiar to them that are not preempted by Federal regulatory
action.
                              R-46

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    5.  Measurement Methodology and Compliance Regulations.
    The National Rail Passenger Corporation (AMTRAK) and the DOT
recommended that the EPA specify the following sound measurement
parameters in the regulation:  wind velocity, humidity, ambient noise,
test site characteristics, test  equipment orientation, and test operator
location.   In addition the DOT and the New York State Department of
Environmental Conservation included suggestions  for types of test
equipment  that should be utilized, and the  New York D.E.C. also
requested the specification of error tolerances within the measurement
procedures.
    The proposed regulation did not  include a detailed measurement
methodology since it was contemplated that  such would be included as
part of the compliance regulation to be promulgated by the DOT.  Such
measurement  methodology, dealing  with the enforcement  aspects of
railroad noise measurement, will still be developed by  the Depart-
ment of Transportation.  The Agency, however, as a result of its own
further analysis and after consideration of the questions and suggestions
received during the public review process,  has decided to incorporate
additional measurement criteria into the standards as an added subpart
of the final regulation being promulgated.  Such measurement criteria
contain specifications  for ambient noise, wind noise,  test site  condi-
tions,  test equipment orientation,  and other parameters necessary for
the consistent and accurate measurement of the sound levels specified
in the regulation.
    This decision was made due to the complexity of the problem of
accurately and fairly performing noise measurements of railroad equip-
ment,  and because  the  Agency felt  it  necessary to ensure that the
                             R-47

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standards within the  regulation be fully and definitively specified so

that there be no question as to the standards promulgated.  The proper

and complete definition of  such standards is particularly critical  with

respect to railroad noise because there is no generally accepted meas-

urement scheme in use nationally or  throughout the affected industry

unlike  the situation in other   industries  subject  to   Federal noise

regulation.

   G.  W.  Kamperman indicated that  the  C  scale would be more

appropriate for this regulation than the A scale.

   It has been  argued that the A-weighted  sound level  discriminates

against low  frequencies   and,  thus,   should  be   replaced  by   the

C-weighted  sound level. Efpwever,  the ear also discriminates against
                          \
low frequencies so that at low frequencies the sound pressure level

must be  comparatively high before it can even be  heard.   Since the

correlations between A-weighted sound level and human response are

consistently better than that obtained with the C-weighted sound level,
                              \
the EPA believes that the measurement procedures  using the A scale

on which these regulations are based  are appropriate,  and therefore,
                                \
no change has been made.
                                  \
   The Cook County,  Illinois  Department  of Environmental Control
                                  \
and the New York State Department  of Environmental Conservation

expressed  concern over the 100 foot measuring distance and indicated

that the specificiation of a 100 foot measuring distance in the standards

is too far because such would require that too large an area be cleared

for the necessary measurement site.
                             R-48

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   The Agency believes from the analyses used to develop the regula-
tion and from its study associated  with the development of  measure-
ment   criteria   that the 100 foot measuring distance does not appear
to create significant problems with finding suitable sites for  the mea-
surement of the sound levels associated with any of the standards, and
has therefore not changed such distance.
   The DOT requested  more  than 270 days  to  develop compliance
regulations due to the complexity of the nature of railroad noise control
and because existing experience and expertise  in the field are  so
limited.
   The Agency is aware of the problems associated with the regulation
of railroad noise  and is concerned that adequate time be provided
so that comprehensive and effective compliance regulations may be de-
veloped.  While it has taken upon itself the development of detailed
measurement criteria which are being incorporated as part of the final
regulation,  the Agency recognizes the need of the DOT for adequate
time  to  develop the compliance regulation.  Therefore,  in direct re-
sponse to the request of the DOT,  the effective date of the Best Main-
tenance Practice Standards  has been changed from 270 days  to 365
days  from the date of promulgation.
    The Agency realizes that unforeseen difficulties may occur
and it will therefore attempt to work closely with the  DOT in the devel-
opment of the compliance  regulations  so  that appropriate measures
may be taken should such difficulties  arise.

                                 R-49

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6.  Special Local Conditions
    The City  of  DesPlaines, Illinois;  the City of Bloomfield, New

Jersey; and  the City of Chicago   Department of Environmental Con-

trol, all requested that local railroad  noise  regulations not be pro-

hibited by the EPA's regulatory action.   In addition. Citizens Against

Noise, the City of Bloomfield, New Jersey,  and  the City  of Chicago

Department of Environmental Control indicated that separate special-

ized noise regulations such as those that would control railroad noise

emissions in highly populated  areas, especially at  night, should be  in-

cluded in the  Federal regulatory strategy or allowed on the local level.

    The Agency recognizes and agrees with the language in the Noise
Control Act of 1972 which envisions a cooperative effort between local,

State and Federal governments in the control of noise.  All of the types

of regulatory action mentioned by the commenters will not necessarily

be prohibited by  this  Federal  regulatory  action.    The Agency has
explained the nature of the preemptive effect  of its regulations in  the

Preamble to the regulation and feels that such explanation should serve

as a guide to the  future  status  of such  State and  local  regulatory

efforts. As interpreted there  by the Agency,   State and local govern-

ments may exercise regulatory authority as  provided in section 17 (c)(2)

as well  as for equipment and facilities not  covered  by Federal regula-

tion, and are encouraged to do so,  so long  as such regulation is within

relevant technical  and economic  constraints  and does not impose a

significant  burden on interstate commerce.
    The City of DesPlaines, the Minnesota Pollution Control Agency,

J.  Palmer,  and the  City of  Chicago Department  of  Environmental

Control had  comments which dealt specifically with the interpretation
                               R-50

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of the provision in the Act for special local determinations.
    The Agency believes  that  Section  17(c)(2) is intended to provide
certain limited relief from a uniform national standard due to "special"
local conditions. However, Section 17(a) calls for such uniform national
standards and  these  could be  significantly diluted through an overly
broad interpretation of  what  constitutes special local conditions.  The
Administrator,  under Section  17(c)(2)  of the Act,  will make specific
case by case determinations which, in  his judgment, balance  the need
for national uniformity  against the need for exceptions to' the national
regulations in particular situations.
   The South Carolina Department of Health and Environmental Control
requested that the standards be reviewed periodically and  strengthened
as technological advances are made.
    The Agency fully  intends to continue to review the field or  railroad
noise control  and may propose revisions  to the regulations  as such
revisions become technically and economically feasible.
    The Illinois Railroad  Association indicated that local  governments
were free to make the Federal regulation meaningless by the exercise
of their non-preempted regulatory authority.
    State and local governments in exercising their non-preempted reg-
ulatory authority, as explained by the Agency under its discussion of
preemption,  may not issue regulations which set standards on the noise
emissions of Federally regulated equipment or facilities, or which have
that effect by requiring the modification of such equipment or facilities
or the alteration of their use,  and thus the Agency sees no  problem
with the Federal regulations being circumvented.
                              R-51

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    7.  Property Line Standards.



    The DOT and the City of Bloomfield, New Jersey, requested that



the EPA  impose property line standards on  railroad noise using an



L10 noise level standard.



    The use of property line  noise  standards  is  applicable primarily



to the regulation of noise from fixed facility and area noise sources.



In the regulation of railroad noise  such  sources include maintenance



shops, marshalling yards, humping yards, and terminals. Since EPA



has not covered these facilities in the regulation,  the use of such area



noise level standards in the regulation is  not appropriate.
                              R-52

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    8.  Background Document Data and Information.
    General Motors Corporation (GM) questioned the validity of the
6 dB(A) conversion factor for changing measurements made at 50 feet
to an equivalent 100 foot  value, due to the length of the locomotive.
    Agency analysis indicates that  any slight  inaccuracy which  may
exist in the use of the 6 dB(A)  conversion factor for the conversion of
locomotive noise levels measured  at  50  feet to 100 foot levels, is in
fact a conservative error which understates the actual noise level as
it  would  be   recorded  by  a  physical measurement  at 100 feet.
Accordingly, some of those locomotives whose noise levels have been
measured  in  this manner may emit  actual noise levels  at  100  feet
which are in fact  slightly lower than  those levels described  by EPA
data which were converted from 50  feet.  Such locomotives  may in  fact
require less quieting than is suggested by the 50 foot data, and as such
may be more easily brought  into compliance with the noise standards.
The Agency emphasizes that any inaccuracy inherent in using the con-
version factor is slight and has minimal  effects upon  the data so con-
verted.
    General Motors also stated that page  5. 3 of the Background Docu-
ment claims that mufflers will  provide 6 dB(A) reduction of all loco-
motive noise levels.   They further indicated that a 6 dB(A) reduction
is not always possible,  and that 87 dB(A)  at 100 feet would  be a better
statement than a 6 dB(A) reduction.
    The above GM comment is apparently attributable to an incorrect in-
terpretation of the Background Document.  The standards being promul-
gated by the EPA require an absolute noise level of 87 dB(A), not a net
                               R-53

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reduction of 6 dB(A).  Specifically, the Background Document states:
"Based on the considerations of available empirical data, an overall
 noise reduction of 6 dB(A) for the noisiest (emphasis  added)  seems
reasonable. Accordingly, the application of exhaust mufflers can be
expected to permit all locomotives to to achieve the following levels:
Idle - 67 dB(A) (now 70 dB(A)); Overall Maximum - 87 dB(A). "
   GM further indicated that based on the magnitude of the one-third
octave band levels, the measurements on p. 4-13,  Figure  4-2, appear
to have been made at closer to five feet than 55 feet as specified when
measuring the noise emissions of an EMD GP4O-2 locomotive.
   An investigation  of Figure 4-2 in the Background Document does
indicate  that the recorded  noise levels are inordinately high.   These
high readings are  attributable to the increased projection of fan and
casing radiated  noise due to open engine access doors during the test-
ing.   However,  the intent of this figure and its supporting discussion
was not to quantify the absolute noise levels due to fan noise, but to
demonstrate  that fan noise is in fact an appreciable noise  source.  To
quote from page 4-13 of the Background Document:  "Since it was nec-
essary to open the engine access doors during the measurements,  the
recorded levels are somewhat higher than would  be generated under
normal operating conditions.     However,  there is little doubt that
cooling-fan operation can contribute significantly  to overall levels."
Although Figure 4-2 does not purport to accurately quantify cooling-fan
noise levels  under normal  operating conditions, it does  succeed in its
primary  purpose which is to demonstrate the relative significance of
cooling-fan noise.
                              R-54

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9.  Statements of Support



    Of the 29 docket submissions received by the Agency,  the following



6 expressed general and often enthusiastic agreement with the proposed



regulations:  The Oregon Department  of Environmental Quality,  the



Illinois  Environmental  Protection  Agency,  the  Harco Manufacturing



Company,  the City of Chicago Department  of Environmental Control,



the South  Carolina Department of Health and Environmental Control,



and the Office of Environmental and Planning Studies of the University



of Illinois Law School at Urbana Champaign.



    In addition,  the Department of Transportation expressed agreement



with the standard for locomotive operation under moving conditions, and



the New York State Department of Environmental Conservation expressed



agreement with and gratitude for the inclusion of a detailed description



of the preemptive effect of the regulation in the preamble.
                              R-55

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 D.  SYNOPSIS OF COMMENTS FROM THE SPECIAL CONSULTATION
    MEETING   ON  THE  PROPOSED  RAILROAD  NOISE  EMISSION
    REGULATIONS
 Introduction:
    On August 14, 1974, a special  consultation meeting was held  in
 Des Plaines,   Illinois,  concerning the Proposed Interstate Railroad
 Noise Emission Regulations.  The transcript of the meeting is included
 as part of the  total body  of public  comment  received by  the Agency.
    Since all   of the comments raised  at  this  meeting have been
 addressed elsewhere in this document the following section will consist
 only of a listing of the particular comments received.
 Summary of Comments:
    Citizens Against Noise requested .that separate standards be prom-
 ulgated  for rural and urban areas, since the effects of railroad noise
 on people are so much  greater in  the  latter  than  the former.    In
 addition  the regulation or elimination of railroad acoustical warning
 devices was called for as well  as the inclusion  of subway and elevated
 trains in the regulation.
    M. Schiep requested that the 4 year  effective date of the regulation
 be reduced.
    The City of  Des Plaines expressed  concern that local ordinances
 that have produced meaningful noise control of railroad equipment will
 be eliminated by the preemptive effect of the Federal regulation.  Also
 called for was a delineation of the meaning of special local conditions
 as used in the Noise Control Act of 1972.
    General agreement with the proposed  regulation  was expressed by
the Illinois Environmental  Protection Agency.
                               R-56

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    The Minnesota Pollution Control Agency requested clarification of



how and why the EPA had preempted track and right of way without



at the  same  time  regulating  such.   In  addition clarification was



requested of the definition  of Interstate  Carrier as used  in  the Act.



    The City of  Bloomfield,  New  Jersey, indicated that property line



noise level  standards should be imposed  along with more strict noise



level  standards  for  locomotives and  rail  cars.   A  reduction of the



4 year time period for the application of the stricter standards was also



called for.



    R. Beauchard requested clarification  of how the measurement



methodology for the regulation would be promulgated.



    Kamperman  Associates, Inc.,  commented that they felt  the C-scale



was better suited to measure locomotive noise than the A-scale.



    The Cook County,  Illinois  Department of Environmental Control



expressed concern that the 100 foot measuring distance was  too far and



would require too much open area  for compliance measurements.



    The Harco  Manufacturing Company asked that EPA consider the



effects on the utilization of spark arresters  of the proposed  regulation.



    The City of  Chicago raised questions  with respect to the  extent of



Federal preemption in limiting the local and State governments from



enacting and enforcing noise regulations relative  to railroad noise..
                               R-57

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            INDEX OF WRITTEN DOCKET SUBMISSIONS
DOCKET NO.    PERSON OR ORGANIZATION
R001

R002


R003


R004

R005

R006


ROOT

R008

R009

R010

R011


R012

R013

R014

R015


R016

R017

R018

R019

R020

R021

R022
Mr.  B.  Leath

State of New York, Department of Environmental
Conservation, Albany

Association of American Railroads submission
of August 7, 1974

Shell Oil Company

ADM Company

Deleted EPA  Region Ill's Comment, which will be
considered apart from the  formal docket

Ritchies Furniture Company

Mr.  R.  Weinrich

Mr.  R.  Harnden

Mr.  E.  Schmidt

U.S. Department of Transportation (DOT)
Exhibits 1-2,  Attachments  A-C

Illinois  Railroad Association (IRA) Exhibits A-K

Association of American Railroads (AAR)

Harco Manufacturing Company

Department of Environmental Quality,  Portland,
Oregon

Fruit Growers Express Company, et al

Salt River Project, Phoenix, Arizona

National Railroad Passenger Corportation (AMTRAK)

Illinois  Environmental Protection Agency

Donaldson Company, Inc.

Minnesota Pollution Control Agency

University  of Illinois at Urbana/Champaign
             R-58

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DOCKET NO.
R023
R024
R025
R026
R027
R028

R029
PERSON OR ORGANIZATION
Forestry Department,  Salem,  Oregon
Town of Bloomfield, New Jersey
General Motors Corporation (GM)
Mr.  K.K. King
Deleted (irrelevant letter)
South Carolina Department of Health and
Environmental Control
City of Chicago, Department of
Environmental Control
                              R-59

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   INDEX OF

DOCKET NO.

5030


5031

5032


5033


5034


5035


5036

5037


5038

5039


5040


5041


5042

5043
SPECIAL CONSULTATION MEETING PARTICIPANTS

   PARTICIPANT

   Mr. Theodore Berland, President,  Citizens
   Against Noise

   Mrs. William Schiep

   Mr. Phillip Lindahl, Environmental Officer for
   the City of Des Plaines

   Mr. N. D. Povair, Supervisor,  New Jersey
   Environmental Protection and Noise Control

   Mr. Thomas Greenland,  Attorney for Chicago
   and Northwestern Railroad

   Mr. Robert Helwig,  Jr.,  for Illinois Environmental
   Protection Agency

   Mr. Al Perez,  Minnesota Pollution Control Agency

   Mr. John Steven Newman, City of Chicago,
   Department of Environmental Control

   Mr. DiLeonard, Counsel for City of Des Plaines

   Mr. Henry Sant'Ambrogio, for the Town of
   Bloomfield, New Jersey

   Mr. D.N. Trafalette,  for the Association of
   American Railroads

  Mr. Simtana,  Cook County Department of
   Environmental Control

   Mr. J.  Palmer

   Mr. G. W. Kamperman, Kamperman Associates
                            R-60

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