
1
MEMORANDUM
Subject:
Input
from
the
Association
of
American
Railroads
Regarding
Locomotive
Fueling
Practices
From:
Jeff
Herzog,
Mechanical
Engineer
Office
of
Transportation
and
Air
Quality
To:
Environmental
Protection
Agency
(
EPA),
Air
Docket
A­
2001­
28
Date:
April
21,
2004
On
July
15,
2002,
I
received
input
by
E­
Mail
from
the
Association
of
American
Railroads
(
AAR)
regarding
locomotive
fueling
practices
(
attached).
On
April
8,
2004,
I
called
Robert
Fronczak
of
AAR
to
discuss
supply
of
fuel
by
pipeline
to
locomotive
fueling
facilities.
Mr.
Fronczak
related
that
he
was
not
aware
of
any
instances
where
a
locomotive
fueling
facility
received
fuel
directly
from
a
refinery
via
pipeline.
He
stated
that
he
believes
that
supply
via
pipeline
to
locomotive
fueling
facilities
discussed
in
the
attached
E­
Mail
pertains
to
pipeline
connections
from
common
carrier
pipelines.
2
Attachment
"
Rush,
Mike"
<
MRush@
aar.
org>

07/
15/
02
11:
18
AM
RE:
Diesel
Fuel
Used
in
Locomotives
To:
Jeff
Herzog,
EPA
and
AStrahan@
icfconsulting.
com,
"
Fronczak,
Robert"
<
rfronczak@
aar.
org>

Sorry
it
has
taken
so
long
to
respond
to
the
e­
mail
below.
Bob
Fronczak,
AAR's
environmental
guru,
collected
the
information
used
to
prepare
the
responses
below.
Bob
used
information
from
a
mid­
1990'
s
survey
of
fueling
practices
undertaken
for
unrelated
purposes
and
also
asked
AAR's
railroads
for
information
in
response
to
your
questions.
We
received
responses
from
seven
major
railroads,
including
the
four
largest
railroads
operating
in
the
U.
S.

The
answers
follow
your
questions.

Michael
J.
Rush
Association
of
American
Railroads
50
F
St.,
N.
W.
Washington,
D.
C.
20001­
1564
Ph:
(
202)
639­
2503
Fax:
(
202)
639­
2868
E­
mail:
mrush@
aar.
org
=================================================
­­­­­
Original
Message­­­­­
From:
Herzog.
Jeff@
epamail.
epa.
gov
[
mailto:
Herzog.
Jeff@
epamail.
epa.
gov]
Sent:
Wednesday,
March
13,
2002
2:
02
PM
To:
Rush,
Mike
Cc:
AStrahan@
icfconsulting.
com
Subject:
RE:
Diesel
Fuel
Used
in
Locomotives
Importance:
High
Thanks
Mike
....
Forgive
me
if
we
had
this
conversation
before
...

Can
you
help
me
out
with
the
following:
­
how
many
locations
there
are
at
which
locomotives
are
fueled
In
the
1995­
96
survey,
AAR
determined
that
there
were
698
sites,
245
fixed
facilities
and
453
direct
truck
to
locomotive
(
DTL)
facilities,
in
the
US.
At
that
time,
87%
of
the
fuel
was
issued
at
3
fixed
facilities,
and
13%
at
DTL
sites.
AAR
does
not
believe
fueling
practices
have
changed
significantly
in
this
regard.

­
how
many
of
such
locations
have
their
own
storage
tanks
(
and
some
idea
re
the
number
and
capacity
of
tanks)

AAR
believes
that,
generally,
fixed
fueling
facilities
have
fuel
tanks
and
DTL
fueling
facilities
do
not.
AAR
does
know
of
one
member
railroad
that
has
tanks
at
some
of
its
DTL
facilities,
but
that
member
accounts
for
only
22
DTL
facilities.
AAR's
survey
indicates
tank
sizes
range
from
10,000
gallons
to
5,000,000
gallons.
One
railroads'
fuel
tank
capacity
averaged
95,000
gallons
while
another
railroad
averaged
518,000
gallons.
The
average
of
the
four
railroads
providing
average
tank
size
information
is
approximately
325,000
gallons.
Based
upon
experience,
there
are
between
one
to
three
fuel
tanks
per
fueling
facility
­
extent
to
which
fuel
is
supplied
directly
by
pipeline
branch
off
of
a
main
pipeline
Three
of
the
railroads
have
no
location
where
they
receive
fuel
from
pipelines,
while
the
other
four
railroads
have
from
3
to
16
locations
where
they
receive
fuel
directly
from
pipelines.
The
total
number
of
facilities
where
the
four
railroads
receive
fuel
from
pipelines
is
35.

­
extent
to
which
locomotives
are
refueled
by
delivery
from
a
tank
wagon
directly
into
the
fuel
tank
See
response
to
#
1
above.

­
How
much
diesel
do
locomotive
tanks
hold?

AAR
members
have
locomotive
fuel
tanks
ranging
in
size
from
500
to
6,200
gallons.
The
smaller
fuel
tanks
are
normally
associated
with
switcher
locomotives
that
have
tanks
ranging
in
size
between
500
­
3,000
gallons,
while
road
locomotives
have
tanks
ranging
in
size
from
1,800
to
6,200
gallons.

­
How
far
do
they
travel
between
fill­
ups?

AAR
has
no
specific
information
with
which
to
answer
this
question.
However,
for
road
trains,
AAR
believes
railroads
generally
have
fueling
locations
spaced
to
correspond
to
the
locations
where
they
conduct
brake
inspections.
FRA
regulations
generally
require
that
railroads
conduct
brake
inspections
on
trains
every
1,000
miles.

­
How
many
rail
cars
are
used
to
transport
high
sulfur
diesel
fuel
(
or
failing
that,
how
many
are
used
to
transport
diesel
fuel,
or
failing
that,
the
number
used
for
refined
petroleum
products
AAR
was
not
sure
if
this
question
related
to
the
number
of
cars
used
by
the
railroads
for
internal
4
use
or
the
number
of
commercial
cars
used
to
transport
diesel
fuel.
While
we
cannot
provide
an
exact
number
of
commercial
cars
used
to
transport
diesel
fuel,
we
can
provide
an
estimate
of
the
number
of
cars
used
to
transport
refined
petroleum
products.
In
2000,
there
were
7,535
terminations
of
distillate
fuel
oil
(
Standard
Commodity
Classification
Code
(
STCC)
29­
113,
which
includes
#
1,
#
2,
and
#
4
fuel
oil).
On
average
a
tank
car
gets
about
8
round
trips
per
year.
That
would
mean
there
are
approximately
940
tank
cars
dedicated
to
the
transportation
of
#
1,
#
2,
and
#
4
fuel
oil.
Note
that
some
of
these
shipments
originated
in
Canada.

Regarding
rail
cars
used
for
the
internal
transportation
of
petroleum
products,
four
of
the
responding
railroads
do
not
have
tank
cars
they
use
to
transport
petroleum
products
for
internal
use,
while
the
remaining
three
have
a
total
of
813
tank
cars
used
for
this
purpose.
One
railroad
differentiated
between
cars
handling
low
sulfur
and
high
sulfur
fuel.
That
railroad
had
480
cars
handling
high
sulfur
fuel
and
100
cars
handling
low
sulfur
fuel.

thanks
~~

I
cc'd
this
note
to
Andrew
Strahan
of
ICF
...
so
that
we
don't
bug
you
more
than
we
need
to
re
the
nonroad
rulemaking
Jeffrey
A.
Herzog,
Mechanical
Engineer
United
States
Environmental
Protection
Agency
National
Vehicle
and
Fuel
Emissions
Laboratory
Assessment
and
Standards
Division
2000
Traverwood
Drive
Ann
Arbor,
Michigan,
48105
Phone:
(
734)
214­
4227
Fax:
(
734)
214­
4816
E­
Mail:
herzog.
jeff@
epa.
gov
