Blog   |   Dec 16th, 2014 Fuel System Audits Support Project Planning and Environmental Compliance for Railroads


Fueling and maintenance is a primary service at most Class I rail yards. Performing these operations thoroughly and efficiently saves money, limits downtime and impacts to the environment, and helps improve average train speed which is arguably the railroad industry’s primary benchmark. Traditionally, the industry has relied on local reports from individual rail yards or sporadic internal regulatory audits to identify compliance deficiencies and evaluate areas for improvement. This reactionary practice does little to identify and predict operational deficiencies before they happen, and can lead to project delays and cost overruns.

Implementing a proactive and predictive fuel system audit program, managed by independent experts, can help railroads consistently identify and respond to maintenance needs, plan capital projects and support compliance with Spill Prevention Control and Countermeasures (SPCC) regulations.

A successful fuel system audit will assess, score and rank individual pieces of equipment, systems and whole facilities. Because fueling facilities are similar across multiple sites, a master set of audit guidelines can be applied to help achieve congruence across a whole railroad system. Those guidelines should be sure to address any variables that may affect operations — type of fueling done onsite; weather considerations; presence of a fuel management system; correct valving arrangements; standard operating procedures; spill response and prevention plans; and training– and provide a ranking system to help prioritize facility upgrades and capital expenditures.

A standard audit should address the following areas:

  • Pump house buildings;
  • Diesel fuel oil (DFO), journal oil, lube oil, waste oil, and soap storage tanks (above ground/underground) with structural support design, concrete containment system (concrete), access systems, leak detection, and level controls;
  • DFO tank supply and fill systems;
  • DFO unload and delivery systems;
  • Electrical and lighting components;
  • Lightning and electrical grounding protection systems;
  • Truck unloading pad including accessibility of trucks onto the site;
  • Ancillary piping, drain and support systems managed by the locomotive servicing group such as industrial wastewater drains and treatment systems, waste or reclaimed oil systems, sanitary waste offloading, and fuel additive and rust inhibitor systems;
  • Best management practices including improvements needed to meet federal, state, and municipal regulations/standards, operating procedures, reconciliation, etc.;
  • O&M Manuals and record drawings;
  • Safety issues including incident reports related to the fueling system;
  • Adequate and efficient pollution control equipment is in place and in compliance with applicable regulations.

A thorough inspection of all mechanical systems associated with locomotive fueling and maintenance should include notes, photo documentation, and numeric scores for all equipment and systems.

While time consuming and complex to get off the ground, initiating and completing the process will:

  • Improve personnel safety by identifying poorly functioning equipment;
  • Improve efficiency and reduce waste by identifying and correcting potential pending breakdowns (which will also prevent product spills and SPCC compliance issues);
  • Support capital planning and budgeting for system maintenance and overhaul; and
  • Save money in the long run as resources will be allocated to the areas of most need.

Working with an independent, skilled auditor will save time and ensure a consistent evaluation across all fuel systems and facilities.

What are your rail yard fuel system challenges? Do you have an audit procedure in place to help support maintenance and planning? Please share your questions and best practices in the comments section below.

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Blog Author

Christopher Gunn

Christopher Gunn

Chris Gunn is a Project Manager in TRC’s Chicago office. His expertise encompasses fuel system evaluation, capital project planning and construction, Clean Water Act compliance, and site and utility design, planning, and construction. Chris is a registered professional engineer in the State of Illinois and collaborates with engineering and environmental teams across TRC’s geography and service offerings as well as supports the management of multiple Class I railroad accounts at TRC. Contact Chris at