Riding the Rails to Environmental Compliance: A Railroaders Guide to Regulatory Requirements
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Antea Group consultants Dean Krebs, Phil Gilchrist, and Tim Larson presented and moderated a session on environmental compliance at the 2016 ASLRRA Connections Convention. Topics include EPA regulations, SWPPPs, FRPs, SPCCs, C-plans, air quality, and a case study.
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Riding the Rails to Environmental Compliance: A Railroaders Guide to Regulatory Requirements
- 1. Riding the Rails to Environmental Compliance A railroaders guide to regulatory requirements Presented by:
- 2. Agenda โขSafety Moment โขPanelist Introductions โขIntroductory Presentation โขCase Studies โขAudience Q&A โขCool Down and Audience Survey
- 3. Safety Moment โข In Case of Emergency โข Emergency Exits โข First Aid & CPR Training? โข AED is locatedโฆ โข Restrooms are locatedโฆ
- 4. Our Panelists Moderator โ Dean Krebs, P.E., Antea Group โข Presenter โ Philip L. Gilchrist, CEM, Antea Group โข Panelist โ Dave Buccolo, Central California Traction Company โข Panelist โ Tim Larson, P.E., Antea Group
- 5. Riding The Rails to Environmental Compliance โข Tree Huggers โข Recyclers โข Just a vendor โข Environmentalists What Environmental Consultants are notโฆ
- 6. Riding The Rails to Environmental Compliance Environmentalists want to save the planet from businessโฆ
- 7. Riding The Rails to Environmental Compliance Environmental Consultants want to save railroads from Environmentalists!
- 8. Riding The Rails to Environmental Compliance A GOOD Consultant isโฆ โข A Trusted Partner โข An Advisor โขHere to let you run your railroads!
- 9. Riding The Rails to Environmental Compliance Phil Gilchrist Consultant Antea Group
- 10. Riding The Rails to Environmental Compliance Just like driving a trainโฆ itโs easy to see the path to environmental compliance, right?
- 11. Riding The Rails to Environmental Compliance Or is itโฆ โข Stormwater Pollution โข Spill Prevention โข Facility Response Plans โข Due Diligence โข Release Assessment and Remediation
- 12. Riding The Rails to Environmental Compliance If you arenโt paying attention, things can start to go badโฆ
- 13. Riding The Rails to Environmental Compliance And pretty soon, it looks like thisโฆ
- 14. Riding The Rails to Environmental Compliance Do you REALLY know what you donโt know?
- 15. Riding The Rails to Environmental Compliance Did you knowโฆ The EPA considers most railroadsโฆ โข Complex Facilities โข Mixed transportation and non-transportation activities โข May require SPCC and/or FRP plans
- 16. Riding The Rails to Environmental Compliance Federal Environmental Considerations โขFacility Response Plans (FRP) โข Required for facilities which have 1MM Gallons of oil productsโฆ โข Transload Facilities โข Storage Facilities
- 17. Riding The Rails to Environmental Compliance Federal Environmental Considerations โขSpill Prevention, Control, and Countermeasure (SPCC) โข Required for facilities which have 1,320 gallons of oil productsโฆ โข Many railroad yards and maintenance facilities
- 18. Riding The Rails to Environmental Compliance What falls under the definition of petroleum storage? โข Stored in capacities of 55 gallons or more โข Fuel โข New and Waste Motor Oil and Trans Fluid โข Grease โข Plant Oils
- 19. Riding The Rails to Environmental Compliance Did you knowโฆ โข Failure to maintain a SPCC Plan, when required, can results in a maximum fine of $27,500 per day โข The maximum fine is $137,000 โข The EPA does periodic inspections of facilities suspected to require SPCC plans.
- 20. Riding The Rails to Environmental Compliance State Environmental Considerations โขStorm Water Pollution Prevention Plans (SWPPP) โข Required for most railroads that maintain or wash their locomotives and/or railroad cars โข Although generally administered at the State Level, generally authorized by the Federal Clean Water Act.
- 21. Riding The Rails to Environmental Compliance State Environmental Considerations โขOil Spill Contingency Plans (C-Plans) โข Some states like California and Washington require additional C-Plans from railroads transporting petroleum products โข Includes spill response plans on lines that threaten State waterways โข Includes โfinancial responsibilityโ requirements
- 22. Riding The Rails to Environmental Compliance Local Environmental Considerations โขLocal cities, fire departments, environmental health departments, etc. โขNon-transportation related environmental issues โข Hazardous materials business plans โข Underground storage tank compliance โข Air Quality Compliance
- 23. Riding The Rails to Environmental Compliance Local Environmental Considerations โขAir Quality โข Usually administered at a state or local district level, but authorized by the Federal Clean Air Act โข Locomotive Exhaust is only ONE COMPONENT โข UST/AST Compliance โข Generators โข Anything that has an exhaust or an emission!
- 24. Riding The Rails to Environmental Compliance Other Environmental Considerations โขDue Diligence โข Property Transactions โข Company Acquisitions & Mergers โข Regional Environmental Issues โขAssessment and Remediation โขHazardous Waste Disposal
- 25. Riding The Rails to Environmental Compliance Dave Buccolo General Manager Central California Traction Company
- 26. Riding The Rails to Environmental Compliance Famous Last Wordsโฆ โEnvironmental Consultantsโฆ Who needs โem? I can take care of this!โ Dave Buccolo, 2005
- 27. Riding The Rails to Environmental Compliance A Case Study of What Not To Doโฆ
- 28. Riding The Rails to Environmental Compliance Letโs set the sceneโฆ Before Dave was hiredโฆ CCT owned, operated, and maintained 3 USTs โข 1 Gasoline Fuel / 2 Diesel Fuel + Dispensing equipment and Piping โข USTs/Dispensers removed in 1998โฆ sort of โข No Permits / No Regulatory Involvement โข Monitoring wells installed incorrectly โข Leaking 600-700 gallons per month for ???
- 29. Riding The Rails to Environmental Compliance And on Daveโs 2nd Day at CCT???? Someone was going to jailโฆ
- 30. Riding The Rails to Environmental Compliance Resolutionโฆ. โข 20 Months Later โข 1,000 tons of soil removed โข Estimated Cost $2,000,000
- 31. Riding The Rails to Environmental Compliance What we SAVED doing it ourselvesโฆ โข Numerous Safety Concerns โข Haz Mat Safety โข Excavation Safety โข Remediation took twice as long doing it ourselves โข Estimated Cost $2,000,000 was likely 2X more than it would have cost
- 32. Riding The Rails to Environmental Compliance Lessons Learnedโฆ โขDo Not Do This Alone โขHire the RIGHT Consultant โขDue Diligence is critical BEFORE you buy a railroad
- 33. Riding The Rails to Environmental Compliance Tim Larson Consultant / Senior Engineer Antea Group
- 34. Riding The Rails to Environmental Compliance SPCC Plan Applicability (40 CFR 112) โข 1,320 gallons or more of โOilโ storage (ASTs), OR 42,000 gallons underground storage (USTs) โข Includes Tanks, Containers, Oil-Filled Equipment (hydraulic jacks, transformers) 55 gallons or more โข โOilโ โ petroleum based, animal fats, vegetable oils, used oil, oil mixtures (oily water) โข Allows self-certification for Tier I (<10,000 gallons) โข States may have rules more stringent than federal requirements (EPA)
- 35. Riding The Rails to Environmental Compliance SPCC Plans โข Regulated Activities Common at Rail Facilities โข Storage โข Transfers (Truck/Rail Car to Tank and visa versa) โข Consumption (Genset) โข Also applies to production, refining, and distribution
- 36. Riding The Rails to Environmental Compliance SPCC Plans โข Exemptions โข Tanks/containers under 55 gallons โข Motive Power (Locomotives) โข USTs subject to 40 CFR part 280 or 281 โข โPermanently Closedโ containers per EPA guidelines โข Tanks exclusively used for WW treatment (except for used/recovered oil tanks)
- 37. Riding The Rails to Environmental Compliance SPCC Plan โ Common Violations โข Inadequate Secondary Containment for Tanks, Transfers, or Oil Filled Equipment โข Lack of Tank Overfill Protection Equipment โข Insufficient AST Inspection Program โข No program at all โข Inspections not conducted as described in SPCC Plan โข Program does not follow Industry Standards โข Lack of recordkeeping NOTE: Inspections by regulators may be conducted by EPA Regional Inspector and/or state agencies
- 38. Riding The Rails to Environmental Compliance State AST Programs โข May apply to tank owner/operators regardless if SPCC Plan is required for the facility โข Applicability varies from state to state โข Varies by capacity, contents, function โข Administered by various state agencies
- 39. Riding The Rails to Environmental Compliance Stormwater Pollution & Prevention Plan (SWPPP) INDUSTRIAL FACILITIES โข Under the National Pollutant Discharge Elimination System (NPDES) Program โข EPA and authorized States issue NPDES general permits to regulate stormwater discharges from industrial activities to prevent pollution โข NPDES permit coverage required for stormwater discharges from many types of industrial activity โข Transportation facilities that have vehicle maintenance
- 40. Riding The Rails to Environmental Compliance Stormwater Pollution & Prevention Plan (SWPPP) CONSTRUCTION SITES โข โฆClearing, grading, and excavating activities that disturb one acre or more โข A Construction SWPPP may be called many things. Your state may use terms like: โข Construction Best Practices Plan, Sediment and Stormwater Plan, Erosion, Sediment, and Pollution Prevention Plan, Erosion Control Plan
- 41. Riding The Rails to Environmental Compliance Stormwater Pollution & Prevention Plan (SWPPP) A typical SWPPP includes the following elements: โข Stormwater pollution prevention team; โข Site description; โข Summary of potential pollutant sources; โข Description of control measures (BMPs); โข Schedules and procedures; โข Documentation; and โข Certification of the SWPPP.
- 42. Riding The Rails to Environmental Compliance SWPPP โ Common Violations โข No SWPPP developed or maintained on site โข Control measures described in SWPPP not used โข Stormwater pollution prevention team not up-to- date โข On-site staff not familiar with SWPPP NOTE: Inspections by regulators may be conducted by EPA Regional Inspector and/or state agencies
- 43. Riding The Rails to Environmental Compliance Audience Q&A What do YOU think?
- 44. Riding The Rails to Environmental Compliance Cool downโฆ Audience Survey โข Was this helpful? โข Requested topics for next time? โข Breakout Sessions at the Regional Meetings?