As you recall, this was discussed at Staff Meeting with Phil Mullen. As long as the Yard Crew is standing by to handle the cars after the Road Power detaches, then it is OK. The yard crew cannot be performing other task(s) with “intention” of going to the other end of the cut. They must be standing by ready to attach or open the angle cock.

K. McReynolds

Supt Operating Practices


_____________________________________________
From: Stuhldreher, William C
Sent: Tuesday, February 24, 2009 8:10 AM
To: McReynolds, Kevin C
Subject: RE: FRA Guidance on closing angle cock "bottling the air"

What about a yard crew going to the opposite end after a road crew has cut away? That is practice in Belen. Is there a minimum time amount that they have open angle cock up?

William C. Stuhldreher

BNSF Railway

Terminal Superintendent II

* William.Stuhldreher@bnsf.com

( 505-864-5114


_____________________________________________
From: McReynolds, Kevin C
Sent: Tuesday, February 24, 2009 8:07 AM
To: Fitzgerald, Tyrone; Perez, Carlos A; Smith, Rick J; Stuhldreher, William C; Thomas, Paul F; 'Arthur Moffett'; Butler, John L; Charlie Anderson; Coker, Larry T; Dante Diaz; David D. Smith; Dick Kolomitz; Donny Nelson; Dwayne Tafoya; G. N. Harper (harpo@ctaz.com); Gary Edge; Gerald Woznick; Hynes, Gregory K; Jackie Horton; Jim Polston; Jimmy Johnson; jmcfather@comcast.net; Jorge Gomez; JP Lusk; Ken Kyer; Mark Marquez (utu-emarme@hotmail.com); Martin Luley; Mike Lee; Phil Black; Rick Spears; Rick Ziede; Robert Lambert; Ron Hrzich; Switzer, Rick D; Tom Pate
Cc: Mullen, Phillip M; Ness, Daryl S; Gomez, Luis R; Swartzfager, Patton W; Fox, John N; OPR DL Operating Practices SOP; Berryman, Ronald T (Travis); Eli, Brandon K; Hanzlicek, Brandon J; Kent, Theresa L; Maser, Jason S; McClellan, Bruce J; Medina, Felipe ; Miller, William C; Mraz, Sean M; Simpson, Shannon C; Soto, Anthony M
Subject: RE: FRA Guidance on closing angle cock "bottling the air"

As result of question posed by BNSF Team members in Phoenix, I am forwarding the information below outlining the FRA position on when the angle cock can be closed on the portion of cars left standing after a locomotive detaches.

The key criteria in complying with Federal Regulation is 1.) When the locomotive goes DIRECTLY to the other end and couples up OR, 2.) The angle cock is immediately opened on the other end of the cut of cars left standing.

K. McReynolds

Supt Operating Practices

_____________________________________________
From: Mullen, Phillip M
Sent: Tuesday, February 24, 2009 7:34 AM
To: McReynolds, Kevin C
Subject: FRA Guidance on closing angle cock "bottling the air"

FRA will not take exception to a train crew cutting away from a cut of cars, initiating an

emergency brake application on the cut of cars, and then closing the angle cock for the sole

purpose of taking the locomotives to the opposite end of the cut of cars to either: (1) couple

the locomotives to the cars; or (2) open the angle cock at the other end and leave the angle

cock open and vented to atmosphere as required under 49 CFR 232.103(n)(2). However, if

the locomotive cuts away from the cars and closes the angle cock without going "directly"

to the other end to either open the angle cock or couple the locomotives to the cars, the

railroad would be in violation of 49 CFR 232.103(n)(2). The emphases is "directly"

Because even though it may be the train crews intent to go “directly” to the opposite end of

the cars to take the appropriate action, if a train dispatcher, or whomever, directs the crew to

Perform another job task before they “directly” go to the opposite end of the cars, a

violation is committed. It is only with the understanding that the train crew goes "directly"

to the other end of the cars to take the appropriate action that FRA will permit this type of

activity.

Phillip M. Mullen

Director Rules & Field Support

O - (817) 352-1293

C - (817) 266-1871