Railroad Environmental Conference
Tuesday 12 October 2004
Jump to a topic:
Energy Emissions and Air Quality
Pollution Prevention and Noise and Vibration
Environmental Management Systems
Risk and Liability Management
Storm and Waste Water
Ongoing Revisions on the National Ambient Air Quality Standards, and Implications for the Railroad Industry
Mark Weitz - The RETEC Group, Inc.
David Seep - Burlington Northern and Santa Fe Railway
The National Ambient Air Quality Standards for Particulate Matter (PM NAAQS) continue to undergo significant changes. In 1987 a new Standard was implemented for airborne particles smaller than 10 µm, known as PM10. In 1997 an additional Standard was added for smaller (fine) airborne particles, known to as PM2.5.
PM2.5 is created primarily from combustion sources, and in combination with natural atmospheric processes; versus PM10 which is created primarily from the abrasion of the earth's crust (e.g. road traffic, wind blown dust). Fine particles typically have much longer lifetimes in the atmosphere, and are transported over longer distances. Local topography and meteorology have significant influences on the impacts from various source types, and thus on air quality in a given airshed.
Based on extensive study over the past ten years, EPA and the air quality community now recognize that coarse and fine particles are different types of pollutants, with different impacts on public health. Under a Consent Decree, EPA is now currently in the process of reviewing the PM NAAQS, and is scheduled to issue public notices for proposed and final rulemaking in March, 2005 and December 2005, respectively. During 2004, several important milestones regarding scientific assessment, and public review and comment are scheduled.
Current indicators are that the PM NAAQS will be modified, with a tightening of the Standards expected. Revisions in the PM NAAQS have the potential to impact the railroad industry.
This paper will present the scientific and regulatory state-of-the-art of the PM NAAQS as of late 2004. Potential implications for the industry, and opportunities for industry input will be provided. New technologies and operational strategies to address potential revisions in the PM NAAQS will be discussed.
A Customer Perspective - Railroad Greenhouse Gas (GHG)
Lori Sonnier - Toyota Motor Sales, USA, Inc.
Todd Cort and Connie Sasala - Cameron-Cole, LLC
As companies continue to look for ways to reduce their Greenhouse Gas (GHG) emissions, all aspects of their value chain are being considered, including transportation of their products by third parties via road, rail, air or water. They are analyzing ways to improve the management of their logistics, and are considering shifts between modes of transport based on their relative GHG emissions. This is relevant to railroads, as business from these companies make up a significant portion of their revenue stream. According to Union Pacific Railroad (UPRR)1, the automotive sector alone contributes approximately 11 percent (%) of their commodity revenue. This paper examines how one customer, Toyota Motor Sales, U.S.A. , Inc., is working with rail carriers to evaluate efficiencies in rail transportation that could lead to measurable GHG reductions in their value chain.
Toyota Motor Sales, U.S.A. , Inc. (TMS), is the affiliate of Toyota North America that is responsible for sales, marketing, distribution, service and parts support for Toyota , Lexus and Scion products in North America2 . As stated in their 2003 Environmental Report2, "Our logistics operation is complex, involving shipment of both fully-assembled vehicles and individual parts and components by road, rail, ship and air transport systems. we are now evaluating established environmental activities where GHG-reduction targets will be most effective."
Concurrently, AAR is looking for ways to meet the voluntary commitment to reduce the intensity of greenhouse gas (GHG) emissions by 18 percent by 2012, as part of President Bush's "Climate VISION" initiative. According to the Bureau of Transportation Statistics3, from 1997 to 2002, truck transportation increased 28.1% while rail transportation increased 14.4%. TMS is currently planning a fact-finding meeting in March 2004 with major rail carriers to learn about initiatives being undertaken by the rail carriers, including fuel efficiency measures, fleet replacement, GHG emissions tracking, and other environmental initiatives.
- Union Pacific Railroad News Release, January 21, 2004 , http://www.uprr.com/notes/investor/2004.
- Toyota North America Environmental Report, 2003, pages 43 - 49.
- Bureau of Transportation Statistics (USDOT) and U.S. Census Bureau, 2002 Commodity Flow Survey, Preliminary United States Data, December 2003, Table 2b.
Trading Credits for Mobile Sources Francisco J. Acevedo - Environmental Protection Agency
EPA will discuss currently available methods for quantifying and using emission reductions from locomotive idling projects in the state and local air quality planning process. Specifically, emission reductions that are appropriately generated from reduced locomotive idling in switchyards can be used in State Implementation Plans and as offsets for New Source Review. EPA will address the specific criteria which must be met in order to take advantage of this innovative new guidance. Additionally, EPA will discuss the results and progress from locomotive idling demonstration projects from around the country.
Hybrid Technology for theRail Industry
Frank Donnelly and Raymond Cousineau
Railpower Technologies Corp .
This paper discuses a true hybrid locomotive entering the extensive North American rail yard switching operations which utilize about 10,000 locomotives and rail car movers. Battery-dominant hybrid technology allows the 2,000 horsepower Green Goat® and the smaller, 1,000 horsepower Green Kid to operate while cutting oxides of nitrogen (NOx) and dangerous particulates by 80-90% (98% with post-treatment options), Greenhouse Gases by 50+%, and diesel fuel use by 50-80% when compared to conventional locomotives of similar power ratings. Each features a small, Tier 2 compliant genset of up to 285 horsepower (200kW), depending on the anticipated workload. The lead acid batteries, with a conservatively targeted lifespan of about 7.5 to 10 years, are substantially recyclable. They are manufactured by 'recycling' aging locomotives that are either close to the end of their service life or have already been scrapped. Of additional environmental benefits are the ultra low noise footprints of both hybrid switchers which can be operated on battery power alone in sensitive areas such as close to neighborhoods, offices and in tunnels.
NOx Standards and Technology for Locomotives
David E. Brann - General Motors Corporations
Locomotive engines have reduced emissions farther, faster, than any other class of regulated engines. For example, locomotive engine NOx emissions, with the effectivity of the Tier 2 standards, have reached a percentage reduction five years after first regulation achieved by on-highway truck engines only after eighteen years of emissions regulation.
Standards and technology cascade from on-highway trucks to nonroad machinery to locomotives and marine vessels. However, emissions-reduction measures successful in truck engines often do not transfer well to locomotives. Technology transfer is further hampered by a lack of commonality between truck and nonroad engine manufacturers and locomotive manufacturers; locomotive manufacturers do not build truck and nonroad engines, and vice versa.
An example of technology transfer in which the governing parameters change radically is air-to-air aftercooling. In truck applications, high power is generally used to go fast, and the cooling airflow is provided by the truck's motion through the air. In locomotives, high power is generally used to move heavy cargo slowly, and the cooling airflow must be moved by fans, limiting the effectiveness of aftercooling in fuel consumption and emissions reduction. Further, in a truck application it's always clear which end will be the front, while in locomotive operation either end can be forward. Finally, tunnel operation can result in total loss of the air-to-air portion of the aftercooling, while trucks don't have to contend with that.
The effectiveness of aftertreatment on locomotives will be limited by space constraints. Locomotives are already as high, wide, long, and heavy as they can be, and the space available is that taken up by the exhaust silencer, about the size of an office desk. Standards should be designed to budget the use of this space most effectively. Additional considerations in the design of aftertreatment systems are shock loading on locomotives and flexing of the locomotive due to operational stresses.
Stringent NOx standards may not be desirable. Recent work analyzing the "weekend ozone effect" in urban areas indicates that stringent NOx standards are counterproductive and that the most effective measure to reduce ozone is to reduce hydrocarbon emissions. Particulate reductions, e.g. by oxidation catalysts that also reduce hydrocarbons, should be given precedence over NOx reductions.
Diesel Emissions - Heavy Duty Truck vs. Locomotive
Roy Primus - General Electric Global Research Center
Tackling Rail Diesel Emissions in Europe - For New and Existing Fleet
Mads Berendorff - International Union of Railways (UIC)
The environmental benefit demonstrated by the railways over other modes of transport is a vital precondition to ensuring social and political support for this mode of transport. Despite the general improvement in ambient air quality in European urban conurbations over the last decades, there is still evidence of air pollution in these areas that is critical to health. A large proportion (showing a falling tendency) is attributable to transport activities. Road transport is considered to be the main polluter, but despite their small numbers, the emissions from diesel-powered locomotives and railcars are increasingly attracting the attention of public and authorities alike - not just on a local level, but also on a European scale.
The European Parliament and the Council agreed in first reading on amendments to Directive 97/68/EC. The scope of the new Directive 2004/26 will be extended to cover all new diesel engines for railway vehicles, this means that limit values for new engines for railway use will be provided by legislation at European level.
In addition, the European Commission (DG Energy and Transport), in direct contact with the CER, called for initiatives from the railways in the field of diesel exhaust emissions, with particular emphasis on the existing railway fleet. As a result, the UIC CTR decided in October 2003 to produce the UIC Diesel Action Plan advocating pro-active measures to reduce diesel exhaust emissions. First results from some preliminary investigations have been compiled as a basis for a European sector study.
POLLUTION PREVENTION NOISE AND VIBRATION
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Report on International Railway Noise Research from IWRN
Carl Hanson - Harris Miller Miller & Hanson Inc.
The International Workshop on Railway Noise (IWRN) is held at various locations in the world every third year and is considered the best forum for exchange of information on railroad noise and vibration. Leading researchers from railroads, research laboratories and consulting firms gather for three days of informal presentation and discussion on the latest developments in noise and vibration issues. Typically the Workshop is limited to about 50 original papers on all subjects relating to railroad noise - noise sources, prediction tools and theoretical models, now noise reduction technology and ground-borne vibration. After a thorough peer review, the papers are included in a dedicated issue of the Journal of Sound and Vibration, a leading technical publication from the UK.
Dr. Hanson has served on the International Organizing Committee for IWRN for the past three workshops and will be present again at this year's event to be held in England on September 8 - 11. He will give a summary of the latest noise and vibration research with a special focus on applicability to US railroad operations.
Risk Analysis of Transporting Environmentally Sensitive Chemicals by Rail
Pooja Anand and Christopher Barkan - University of Illinois at Urbana-Champaign
Railroad tank cars transport a wide variety of hazardous materials and the type and degree of hazard varies greatly for different products. Tank cars are designed to contain products during normal transportation and be resistant to damage in the event of an accident. For safety and economic reasons, the damage-resistant design of tank cars is commensurate with the degree of hazard posed by the product they are intended to transport. For most of the 20th century, the principal concern was acutely hazardous materials that are flammable, explosive, toxic, or corrosive. However, as understanding of environmental impacts of chemicals has increased, so has railroads' concern about the design of tank cars transporting products with the potential to cause environmental damage. In the early 1990s the AAR conducted research that determined that it was cost-effective to transport certain environmentally hazardous chemicals in more robust tank cars. These cars are more expensive to build and operate but this is offset by the reduced risk of environmental cleanup expense. The AAR research led to changes in the regulations specifying tank car design for certain products. Since then, environmental cleanup requirements have become more stringent, thereby increasing the financial risk posed by chemical transport. Railroads have had several derailments that resulted in expensive cleanups. We will describe the results of current research sponsored by AAR that will enhance railroads' ability to assess the safety and environmental benefits of using more robust tank cars for transportation of chemicals potentially harmful to the environment.
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Options for Improving the Energy Efficiency of Intermodal Freight Trains
Yung-Cheng Lai, Chris Erickson, and Christopher P.L. Barkan - University of Illinois at Urbana-Champaign
Larry Milhon - Burlington Northern and Santa Fe Railway
It is ironic that the fastest freight trains tend to have the poorest aerodynamic characteristics. Because of constraints imposed by equipment design and diversity, intermodal trains incur greater aerodynamic penalties and increased fuel consumption compared to their general freight counterparts. Consequently, improving the design of these trains has the potential to reduce emissions and improve railroad fuel efficiency. Using a model developed for the AAR to analyze car and train aerodynamics, we have identified two ways to improve intermodal train energy performance. Preliminary results indicate several options worthy of further consideration. First, matching intermodal loads with cars of an appropriate length reduces gap length between loads, thereby improving airflow. Second, filling empty platforms with empty containers or trailers reduces aerodynamic resistance and improves energy efficiency, despite the additional weight penalty and consequent increase in bearing resistance. Although the last option appears to offer the most benefit it also introduces new logistical challenges.
Evaluation of Energy Efficiency Technologies for Railways
Jessica Ahrens - Deutsche Bahn AG
Improving the energy efficiency of railways further is one of the challenges for railways in the 21st century: cost efficient operation is crucial, the availability of fossil energy resources is decreasing and rail transport is the most important component on a way to sustainable mobility, the competitive advantage with other transport modes must be kept.
There is a large potential to reduce energy consumption further with energy efficiency technologies but railway energy experts are rare and often very specialized, the exchange of knowledge and experience among railways is not sufficient yet.
Therefore, the International Union of Railways (UIC) initiated the projects EVENT and EVENTComTool: In the project EVENT current information in the field of energy efficiency technologies and projects for Railways was being collated and present and future technologies were being evaluated for railway purposes with a close contact to the European Railways and the industry.
More than 120 technologies and measures, which can lead to better energy efficiency of rolling stock and train operation of railways, have been evaluated by using different criteria, e.g. the technological applicability of the measure on railways, advantages, disadvantages, necessary frame conditions, economic and environmental effects. Most promising technologies have been identified and recommendations for lanes of action for the UIC and the railways were derived.
Key aims which could be achieved with the EVENT project:
- providing a global state-of-the-art overview over energy efficiency technologies relevant for both rolling stock and train operation
- providing an overview over existing experiences and projects with railway applications - evaluation of the technological, economic and environmental potential of energy efficiency technologies - identification of the key success factors and impeding factors for the implementation and application of these technologies in railways
- development of guidelines and recommendations for implementation strategies and lanes of action.
The results of EVENT have been published with an interactive, user-oriented communication tool, designed and programmed in the project EVENT ComTool. With this internet-database it is possible to search for and display specific results by using technology criteria as well as supplementing and updating the existing technologies. It enables the user to have an overview of the energy- efficiency potential as a percentage, given a fleet of wagons, locomotives and trainsets and the improvements decided (available at the UIC-web-site www.railway-energy.org).
The results of EVENT and EVENTComTool provide now the basis for the new energy efficiency strategy for future projects of the International Union of Railways.
ENVIRONMENTAL MANAGEMENT SYSTEMS
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Railroads and the American Chemistry Council Responsible Care Management System
Rick Nath - CSX
The chemical industry and railroads have cooperated in development of a new and expanded Responsible Care Management System (RCMS) for the railroad industry. The new system will impose some additional requirements on environmental and hazardous materials management organizations in the railroad industry. The presentation will cover these additional requirements and the railroad industry's program to respond to these new requirements.
A representative of the American Chemistry Council's Responsible Care program along with one or more representatives of the railroad industry will present the elements of the RCMS for railroads. The revised system includes the use of third party audits and certification of management systems and facilities. The paper will discuss the gap analysis to be conducted by the railroads in order to implement the revised management system requirements.
Elements of the RCMS include the following
- Policy & Leadership
- Planning (PLAN)
- Implementation, Operation & Accountability (DO)
- Performance Measurement & Corrective Action (CHECK)
- Management Systems Review (ACT)
The presentation will cover these steps and the processes and procedures that the railroad industry has in place to address these four steps.
How Do We Measure Progress?
Lanny Schmid - Union Pacific Railroad
Category - Environmental Management Systems
Typical questions frequently asked by Corporate Management with regard to the status of environmental programs include
"How do we know that we are making progress"?
"Are we doing what is necessary"? and,
"How do we measure improvement?
Over time, we have developed, improved, and re-evaluated the measures for the major programs - air, water, waste and earth. We normally identified one or two high level indicators for use in the overall Company Business Objective matrix, and attempted to then provide additional program specific indicators which supported those high level indicators. Often those measures were often 'stand alone' indicators that did not provide a broad perspective for all of our programs.
As we have continued to upgrade our environmental audit process, incorporate Total Quality Management Systems principles into daily work routines, and begin building an Environmental Management System, the inter-relationships between programs became apparent. There are 4 phases to consider. The basic corporate values influence program drivers, which subsequently lead to performance indicators, and ultimately to measurable, key results.
The model is comprised of a visual aid which links to a simple spread sheet that summarizes the details. These tools now capture basic information, and can be expanded to tally more specific facts as our program continues to mature. The goal is to present data that is meaningful for everyone from the Chairman to those fueling locomotives on the ground.
Four Years of Environmental Audits at Amtrak: The Good, The Bad, The Ugly?
Roy Deitchman and Robert Noonan - Amtrak
Starting in 2000, Amtrak was required to conduct comprehensive environmental audits at all of its large and medium facilities throughout the United States as part of a Consent Decree agreement with the U.S. Environmental Protection Agency (EPA). Initially this covered 50 facilities with large sites having annual audits and medium size facilities audited every three years. Thus, each year about 22 audits per year were conducted. Under the Consent Decree all potential violations had to be self-disclosed to the EPA and corrected within 60 days. The Consent Decree requirements were completed in 2003 and Amtrak has continued to perform the audits in a similar fashion.
This presentation will review the lessons learned in conducting the audits and developing corrective action plans. Looking back, we will discuss early implementation concerns, significant audit findings and how the program has matured.
Exploration of an Effective Audit Program
Alden Anderson - The RETEC Group, Inc.
Your company's environmental performance is of interest to a broad set of both internal and external stakeholders. Typically, environmental performance data is gleaned from environmental compliance audits' review of current operations. Compliance audit programs record detailed findings and subsequently track those specific findings to closure. In addition, findings are tallied up and tracked through time to establish trends. How can audit results be communicated to upper management, board of directors and the public in a meaningful, consistent manner?
This session will explore potential (and often realized) down falls of audit programs, such as unclosed and improper closure of findings, poor communication of results, lack of management support, and improper audit focus.
Wednesday 13 October 2004
RISK AND LIABILITY MANAGEMENT
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Use of Statistics to Assess Compliance with Michigan Part 201 Cleanup Criteria
Bradley Johnson - Golder Associates Inc.
Sarah Hession - Michigan Department of Environmental Quality
The Michigan Department of Environmental Quality (MDEQ) has developed a "Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria" (S 3 TM) to provide guidance on sampling of environmental media for various sampling objectives under Part 201 ( Michigan 's principle environmental cleanup regulation). The S 3 TM also helps determine when it is appropriate to use statistics and which statistical methods to use for comparing data to Part 201 cleanup criteria. The MDEQ has developed a statistical interface (P201 STATSOFT*) for Part 201 evaluations, which is an on-line, user-friendly tool for statistically comparing data to Part 201 criteria and background.
The S 3 TM guidance and P201 STATSOFT were used to re-evaluate existing facility characterization data collected at a Grand Trunk Western (GTW) rail yard in Detroit , Michigan by calculating "representative concentrations" of constituents of concern. The GTW rail yard was used historically for passenger and freight locomotive servicing and fueling. Historic facility characterization activities included drilling 36 soil borings (14 of which were completed as permanent monitoring wells), excavation of 25 test pits, and collection of 13 surface soil samples. Exceedances of Part 201 Industrial/Commercial criteria for relevant exposure pathways were identified. Several Part 201 exceedances were eliminated through statistical risk assessment. This paper discusses: the applicability of statistics for relevant exposure pathways at the site; selection of appropriate data sets (existing characterization data vs. additional random samples); and selection of the appropriate statistical method. Statistical risk assessment procedures are supported by many other state regulatory programs.
*The intended users of P201 STATSOFT are the staff of the MDEQ and members of the regulated community involved in Part 201 evaluations.
Strategic Planning for Railcar Cleaning
Bob Schmidt and Steve McNaughton - Union Pacific Railroad
Jim Gorley - Cameron-Cole, LLC
Railroads and Railcar leasing companies provide railcars as a service to their Shippers for the daily movement of over 25,000 commodities. Consignees (the receivers of the shipment) are responsible for emptying the cars. Occasionally, cars are refused when they reach the next Shipper because the interiors are not clean. The Railroad or Railcar leasing company must then ship the non-revenue empty to a cleaning facility. Close oversight of these facilities is required to assure that the residuals, wastes, runoff and emissions from the cleaning activity are controlled to eliminate environmental impact.
In 2003, Union Pacific embarked on a strategic initiative to evaluate its car-cleaning network and to identify the optimum locations for car cleaning facilities. Through the use of economic modeling techniques and impact studies Union Pacific is in the process of reducing car cleaning facilities to ten major switching yards. These efforts are structured toward lowering overall costs of cleaning railcars, making more cars available for loading, and creating facilities that have minimal impact on their surroundings.
Our presentation will provide specific examples of the challenges faced by Union Pacific under this railcar cleaning project, and the strategies Union Pacific is using to "plan-in" environmental protection from the start.
When Good Analytical QA/QC Isn't Good Enough for the Regulatory Community
Fred Closmann and Craig Niedermeier - The RETEC Group, Inc.
Robert Werner - Burlington Northern & Santa Fe Railway
This paper summarizes an innovative approach that The Burlington Northern and Santa Fe Railway Company (BNSF) applied to develop a response to questions from a regulatory agency regarding uncertainties in analytical data, and how to quantify those uncertainties using quality assurance/quality control (QA/QC) data. BNSF developed a statistical methodology to assess uncertainties or low bias in "flagged" metals data using matrix spike recovery data. BNSF's approach allayed all concerns with data uncertainty expressed by the regulatory agency and eliminated the need to re-sample the site, saving the railroad significant investigation costs.
Nearly every state regulatory agency has implemented risk assessment guidelines to be used by the regulated community in developing remedial strategies that are protective of human health and the environment. As a part of the guidelines, regulators are ensuring that the supporting analytical data are generated with an adequate and defensible level of supporting QA/QC data. The purpose for these QA/QC protocols is to ensure an understanding of the limitations and uncertainties associated with data being used to make remedial decisions that protect the health of every stakeholder. Sometimes, however, that supporting data raises more questions than it answers.
On behalf of BNSF, RETEC was contracted to perform site characterization activities and develop a remedial strategy for a railroad site located adjacent to a former zinc smelter in Oklahoma . Surface soils over a portion of the site were determined to be impacted with arsenic, cadmium and lead above pre-determined remedial criteria. Industry standard investigation practices were utilized to characterize and delineate impacted soil. Samples collected during the investigation were submitted to a certified laboratory, and rigorous data validation was performed using the National Functional Guidelines (EPA, July 2002). In doing so, RETEC determined that a subset of site data required qualification due to matrix interferences and sample heterogeneity, resulting in the assignment of "J" qualifiers. Typically, this qualified data would be accepted at value as positive data, but the acting regulatory agency requested a better assessment of the uncertainty in the data before allowing BNSF to make remedial decisions and proceed with site clean-up. RETEC and BNSF were successful in developing a statistical approach that quantified the uncertainty of the J flagged data and provided the agency the level of comfort they needed to allow us to proceed with development of a remedial strategy for the site.
Pacific Northwest Rail Corridor: Rail Operation Planning and the Environmental Process Working Hand-in-Hand
Linda Amato - The Resource Group Consultants, Inc.
Thomas White - Transit Safety Management, Inc.
The "Purpose and Need" of a rail project is effectively the commercial requirement (for both passenger and freight rail) that the project meets. These requirements must be determined before operation planning begins. The environmental documentation and approval process is facilitated by thorough and detailed operation planning that accomplishes the commercial requirements without infrastructure that needlessly exceeds the requirements.
Developing an infrastructure plan and associated operating plan to meet the commercial requirements is only the first step in the association with the environmental documentation, however. The need for every element of the project must be clearly conveyed to all readers. Thus, the environmental documentation must provide a translation for the technical explanation. The document preparer and the operations planner must work closely to ensure that every element of the infrastructure plan can be understood by the general public and that the translation does not change the meaning of the description.
The Washington State Department of Transportation (WSDOT) has completed the Environmental Impact Statement (EIS) for one major project and has finished a significant portion of another using these principles. The process includes the inclusion of a "Railroad 101" section that explains the basic requirements of rail transportation in common terms, and detailed reasons for the need of individual components at the specified locations, again, in common terms.
The close association between operation planning and environmental document preparation has been useful in successfully:
- educating resource agencies and the public about passenger and freight rail;
- justifying the selection of the incremental approach versus building a new rail corridor;
- applying NEPA concepts of independent utility, segmentation, and logical termini to a 400-plus mile rail corridor; and
- planning for a 20-year horizon while the property owners (railroads) only plan for two or three years into the future.
The Strengthening Role of Institutional Controls in "Brownfield" Property Transfers
Randall Smith and Pawan Sharma - Camp Dresser & McKee
So you've got a 30-acre parcel you no longer need, right in the path of encroaching gentrification. You know the history, and you have enough subsurface data to realize you won't get it cleaned up well enough for an unrestricted use, liability-free sale in your lifetime. Can you sell it and risk losing management of institutional controls (ICs) (e.g., zoning restrictions, deed notices, covenants, utility notifications, etc.)? Or should you retain ownership and forfeit the cash your company needs now?
The role of ICs in the remedy for impacted sites has been highlighted through recent "Brownfield Amendments" to the Federal Superfund law. In addition, Federal, State and local initiatives are underway regarding information systems to manage ICs, as well as establishment of legal tools to shift more responsibility to purchasers and property occupants. These programs can now provide reliable assurances to sellers, buyers, and lessees of impacted properties.
This presentation provides an overview of ICs, their increasing strengths, as well as their remaining limitations. Application of ICs to the transaction of a fictitious inactive, industrial property will be discussed.
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Review of Current Railroad Environmental Issues
Robert Fronczak - Association of American Railroads
The Association of American Railroads (AAR) represents the freight railroads in North America . AAR members include the railroads that operate 76 percent of the line-haul mileage, employ 90 percent of the workers, and account for 93 percent of the freight revenue of all railroads in the United States; and Amtrak. AAR also represents the Canadian railroads through the Railway Association of Canada, and three Mexican railroads including Ferromex, Ferrosur, and TFM. This presentation will discuss current regulatory, legislative, environmental awareness, and pollution prevention initiatives at AAR . Regulatory activities include the construction and development effluent guidelines, off-road diesel fuel regulation, as well as recent developments in the area of spill prevention control and countermeasure plans. On the legislative front, AAR has been tracking the energy bill to make sure research funding is authorized for locomotive emission and energy research. Environmental awareness activities include the John H. Chafee North American Railroad Employee Environmental Excellence Award, and the award for professional railroad employees. Voluntary programs include the Smartway program, and a voluntary commitment to the White House Council on Environmental Quality to reduce greenhouse gas emission intensity by 18% by 2012. The re-registration of creosote is also something that EPA has in the works for 2004.
SPCC Compliance Evaluation Process
Steve McNaughton - Union Pacific Railroad
Ken Rose - Cameron-Cole, LLC
On July 17th, 2002 , EPA issued a final rule amending the Oil Pollution Prevention regulation promulgated under the authority of the Federal Water Pollution Control Act (Clean Water Act). This rule addresses requirements for Spill Prevention, Control and Countermeasure Plans (SPCC Plans). The new SPCC rule as presented in 40 CFR Part 112, addresses these revisions and became effective August 16, 2002 . EPA published a final rule on April 17, 2003 that extended the deadlines by which facilities must amend (or, for new facilities, prepare) and implement their SPCC plans. The compliance deadline as specified in the SPCC rule requires that SPCC plans be amended by August 17, 2004 and facility changes to achieve compliance be implemented by February 18, 2005.
This presentation summarizes the process established at UPRR to achieve and maintain compliance with the changing SPCC regulations. In the course of this effort, a step-wise process was utilized, and included:
- Regulatory Review - evaluation of the current and revised SPCC rule;
- Budget Appropriation - capital improvement, testing and plan re-certification;
- Resource Planning - team building, corporate, facility and technical support;
- Facility Inspection and Testing - API 653, secondary containment;
- SPCC Plan Revision and Re-Certification - database adaptations, PE certification;
- Verification and Documentation - maintained at both the corporate and facility level.
Panel Discussion of Federal Permits Required for Railroad Construction Projects
John Morton - HDR Engineering
Victoria Rutson - Surface Transportation Board
Frequently a railroad construction project triggers the need for one or more federal authorizations. For example a new bridge over a navigable river, a capacity project that impacts wetlands, or a new competitive build-in each may require federal approval before construction can commence. It is critical that the railroad industry understand the federal rules and processes that affect construction activities.
This would be a panel presentation from three Federal Agencies along with a railroad representative that discusses several of the federal laws and regulations that may affect railroad construction activities. The panel would consist of the representatives from the Surface Transportation Board, the U.S. Coast Guard, and the Corps of Engineers, along with a rail industry representative. The Surface Transportation Board would discuss the environmental review process associated with new rail line construction projects. The Coast Guard would discuss the rules relating to the construction of a bridge over a navigable water. The Corps of Engineers would discuss the Section 404 permit program and when a rail construction project may require a permit. Representing the agencies would be the following individuals, all of whom have agreed to make presentations:
Roger Wiebusch - United States Coast Guard
Chandler Peter - U.S. Army Corps of Engineers
David Seep - Burlington Northern and Santa Fe Railway
Team Approach and Agency Coordination are Keys to Successful Environmental Permitting - BNSF Bridge 235.66
Michael Madson, Michelle Bissonnette, Sarah Emery, and Shannon McCauley - HDR Engineering, Inc.
Ken Jennison and Jim Cunningham - Burlington Northern and Santa Fe Railway
Burlington Northern Santa Fe Railway (BNSF) plans to replace their existing railroad bridge over the Wisconsin River with a new bridge located 23 feet downstream of the existing bridge. The proposed project consists of realigning and reconstructing 2,100 lineal feet of track, adding additional siding and replacing the existing railroad bridge over the Wisconsin River . The project site is in floodplain wetlands at the confluence of the Wisconsin and Mississippi Rivers, located south of Prairie du Chien, Wisconsin , and the property is adjacent to the Upper Mississippi River National Wildlife and Fish Refuge, State land, and Wyalusing State Park.
HDR and BNSF worked with the multiple agencies to secure approvals and permits for project construction. The Wisconsin Department of Natural Resources (WDNR) required an Environmental Assessment, Bridge Permit, Water Quality Certification, Miscellaneous Structures Permit, Dredging Permit, and Grading Permit; the US Fish and Wildlife Service (USFWS) required a Special Use Permit for temporary site use during construction; the U.S. Army Corps of Engineers (COE) required a Section 404 Permit; and the Lower Wisconsin State Riverway Board required a permit. HDR and BNSF worked together with these agencies to provide information, discuss alternatives and construction options, and coordinate permitting decisions.
After agency authorization and permitting was received, BNSF determined that site access would not be allowed from the rails. The selected contractor recommended a north access road and a 3,000-foot temporary bridge within BNSF right-of-way to access the remote site. It was determined that the proposed upland route was within an area of archaeological significance, possibly containing prehistoric burials. HDR and BNSF worked with the COE (Section 106 lead agency) and met with the Wisconsin State Historic Preservation Office (SHPO) and representatives of the Ho-Chunk Nation. Through site survey, engineering controls, contractor education, and construction monitoring the project was able to proceed through the preferred area while minimizing impacts to resources.
Cathodic Protection 101
Mike Stanfill - Burlington Northern and Santa Fe Railway
Lou Koszewski - US Tank Protectors, Inc.
SPCC regulations require that buried piping installed or replaced on or after August 16, 2002, have a protective wrapping and coating, and be cathodically protected. These regulations also require each aboveground container must be test for integrity on a regular schedule following an appropriate industry standard such as API 653. The frequency of these inspections is based on the corrosion rate of the floor or shell. Extending this inspection interval will save large amounts of money for the tank owners.
So how do cathodic protection systems work for ASTs and pipelines? What needs to be done to inspect and maintain the systems?
Facility Assessment Compliance Evaluation (FACE), 2004 Results
Christoper LoRusso - Amtrak
Amtrak's Facility Assessment Compliance Evaluation (FACE) program was designed to assess environmental compliance at approximately 120 railroad facilities that have limited environmental impact and because of their size and limited industrial activities are not included in the Amtrak Environmental Auditing Program (EAP).
While Amtrak's Environmental Department manages the program, facility/field level staff conducts the assessments. This puts the responsibility for compliance at smaller facilities in the hands of facility and division staff. The program allows for constant monitoring, continued improvement, and promotes environmental stewardship and educational outreach.
The FACE program incorporates six key functions:
- Review the status of compliance with applicable federal and state environmental laws and regulations, and conformance with company environmental policies, procedures and recognized industry standards at each Amtrak facility
- Identify significant environmental risks and impacts at the facilities
- Assess the integrity of the environmental management practices and processes employed at the sites
- Increase awareness of environmental requirements and company expectations at the facility level
- Enhance each facility's ability to design and implement solutions to environmental problems through root cause analysis and timely corrective action
- Provide environmental due diligence.
"Surface Water TMDLs - An Impending Storm for US Railroads?"
Ole Mersinger and Paul Putzier - The RETEC Group, Inc.
Charlie Duffy - Canadian Pacific Railways
As some of the largest private property holders in the U.S. , railroads may be more exposed than any other industry to regulations involving surface and storm water management. Total Maximum Daily Load (TMDLs) requirements originate from a little enforced provision in the Clean Water Act requiring documentation of impaired water bodies and development of TMDLs to restore and maintain water quality. TMDL is a calculation of the maximum amount of a pollutant, from all sources, that may be introduced into surface water, and still assure that applicable water quality standards are achieved. Determination of a water body's TMDLs can be highly charged and controversial process. Consequently, only a limited number of TMDLs have been developed and primarily for constituents such as nutrients, fecal coliform and suspended solids. However, it is probable many water bodies will have TMDLs for a wide range of organic and inorganic compounds in the future.
Although the direct impact of TMDLs on railroad operations at this time is unclear, recent developments in Minnesota may provide insights into what the future holds. The current approach in Minnesota is development of a state law that addresses impaired waters, the restoration of impaired waters, and the development and implementation of TMDLs through a multidimensional stakeholder process. As a stakeholder, railroads may find themselves involved in watershed discussions involving the development of TMDLs. During the development and subsequent enforcement of TMDLs for specific water bodies, it is possible point source and non-point source discharges will come under scrutiny. TMDL development may also limit future railroad expansion in a given watershed. Additionally, industrial growth (railroad customers) in some watersheds may be similarly impaired. While the TMDL focus is primarily for non-point sources, the implementation of TMDLs will ultimately affect some of the business decisions that are necessary to operate the railroad of the future.
STORM WATER AND WASTE WATER
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Capital Improvement Project Delivery Methods: Successes and Challenges
Randall Smith - Camp Dresser & McKee
Paul Kuhlmeier - Kansas City Southern Railway
Kansas City Southern Railway (KCS) procured three of four process water treatment projects using a design/build approach. All project expenditures had to be disbursed in 2003, and the bidding process didn't yield a selected firm until late April. As with many old rail yards, particularly yards transferred through historical acquisitions, there was little documentation on existing conditions. Otherwise, the plans were simple: segregate contact storm water from non-contact storm water, route contact water through an oil/water separator, and discharge the treated water to the receiving ditch through the existing discharge permit.
This is a story about controlling storm water at sites in southeast Texas , southern Louisiana , and eastern Mississippi , where "100-year" storms hit the site 4 times during the 7 weeks of construction. Where a local subcontractor evens an old score with his concrete truck. Where snakes, turtles, and alligators get to keep their homes. Where some up-front design flexibilities allow for unanticipated retrofit benefits.
Design/build project delivery isn't always pretty, and it requires a strong relationship between the client and the engineer/ constructor. The contractual emphasis is on the performance, not on the details. For all the challenges, Design/Build project delivery returns timely, flexible solutions.
This presentation will discuss the potential advantages of design/build project deliver - the general types of project best suited for design/build; its advantages in terms of cost, sequencing, and overall timing. The presentation will also touch on areas of caution, where improper management and differing expectations can lead to project failure.
Design/build project delivery may be appropriate for your next project.
Designing and Building a Compact, Multi-Level and Multi-Purpose Wastewater Treatment Plant
Rory Mullennex, David Schaad and Lohman Thompson - Marshall Miller and Associates, Inc.
Kevin Hauschildt - Norfolk Southern Railway Company
The Norfolk Southern Railway Company (NSRC) constructed a new wastewater system to treat runoff from a locomotive fueling platform located at one of its Midwestern Rail Yards. The process flow conveys the water first through a grit-chamber located at the fueling platform, then through a dual-purpose equalization basin (combination retention area, grit chamber and oil water separator), which can be operated in series or parallel flow configuration. The process water is then dosed with a chemical coagulant and pumped into a dissolved air floatation (DAF) unit, where it is further conditioned with flocculants. After being processed through the DAF, the water continues through a tertiary treatment of mixed media carbon-clay filters. The system was designed and constructed with major components installed at different elevations to allow for gravity flow as much as possible and to ease maintenance issues. Additionally, by constructing the plant vertically, the horizontal footprint of the facility was minimized. Enhancements have been added to the system to minimize labor requirements while maximizing fail-safe controls and redundant processes within the system. The plant was designed to attenuate the fifty-year storm event and have a maximum treatment capacity of approximately two hundred gallons per minute.
In addition to the industrial wastewater treatment plant, the system utilizes an in-line baffle/skimmer system to intercept and treat the water flowing through the non-contact storm water system.
By using these two systems, the water discharging from the facility is in compliance with prescribed regulatory limits.
Walnut shell Filtration for the removal of free oil and suspended solids: A Case Study on Railroad Transportation
Wastewater Treatment System Design
J. Gregory Menniti - Chester Engineers, Inc.
John Calhoun - CSX
In 2000, CSX Transportation, Inc. (CSXT) decided to construct a new mainline fueling facility for their northern rail route between Chicago and Boston . CSXT chose to construct the new facility east of its Collinwood Yard in Euclid , OH.
The site selected for the fueling facility is a long narrow strip of property bounded on the west by 222nd Street , which runs beneath the railroad tracks via a viaduct, and on the north by a service road of Interstate 90. On this space limited site, CSXT needed to install the fueling facility, tank farm, pump house and wastewater treatment and equalization systems.
There are both sanitary and storm sewer systems in the area. The sanitary collection system terminates at a publicly owned treatment works (POTW), and the storm sewer system flows into Lake Erie.
During discussions with the City of Euclid , the City stated that their sanitary sewer system did not have the capacity to handle the flow from the fueling facility. The City also took issue with the flammability of the diesel fuel in the waste stream due to the processes employed at their wastewater treatment plant (WWTP). The City's refusal to permit the discharge of the waste stream into their sanitary system necessitated a NPDES Permit to discharge to the storm sewer system. The final NPDES discharge limit was 9 mg/l of oil and grease due to the accepting waters being Lake Erie . With such a low discharge limit, additional treatment beyond a standard baffled or skimming type separator was required.
- The process begins at the locomotive track containment system, where drips, leaks and spills of petroleum (product) are captured in a containment system. When a storm event occurs, the product is washed from the containment into the equalization system. The equalization system consists of four (4) 5-foot diameter manholes that are connected by a 36-inch pipe network to provide the volume to contain a 25-year, 1-hour storm event. The pipe network is sloped to provide gravity flow to the wastewater treatment facility (WWTF).
- Wastewater flows by gravity from the equalization system to the influent sump located inside the WWTF building. The inlet sump is fitted with an underflow baffle and belt type oil skimmer. This oil skimmer is for pretreatment to remove free oil, minimizing the loading on the rest of the system. An air diaphragm pump moves the oil collected by the belt skimmer to an oil decant tank. The process water in the sump is pumped directly to a coalescing plate interceptor (CPI) unit using progressive cavity pumps. From the CPI, process water flows to a filter feed/effluent tank where two low shear centrifugal pumps transport the process water to a walnut shell filter for final treatment. The treated water then flows to the effluent side of the Filter Feed/Effluent Tank prior to discharge into the storm sewer system and ultimately to Lake Erie.
- The walnut shell filter was selected over a dissolved air floatation (DAF) unit for the treatment of the wastewater due to its size, capital cost, minimal operator intervention requirements, and because it is a mechanical separation process that requires no chemicals addition.
- Walnut shell filtration was developed as a more suitable method of filtering free oil and suspended solids in applications where sand filters were conventionally used. Walnut shell filters remove 90%-95% of free oils and 95%-98% of solids greater than 2 microns in size. The walnut shell filter chosen for the project contained a deep bed of 100% black walnut shells. Black walnut shells have excellent surface characteristics for coalescing and filtering oil from wastewater and have superior resilience to attrition. The filter was designed with a nutshell bed depth of 66-inches. This large depth gives excellent effluent quality, long filtration runs between backwashes, and exceptional throughput efficiency. The walnut shell filter was designed to use the raw process water for backwashing, which lowers the capital cost of the project by eliminating the need for air scour, stand-by filters, and additional storage tanks. Walnut shell filtration technology is commonly used to treat oilfield produced water, refinery wastewater, steel mill direct spray and caster water, ethylene plant quench water, copper concentrate decant and cooling water. However, the process had not been used for locomotive fueling facility wastewater treatment.
- During the filtration cycle, the raw process water passes through the filter from top to bottom. As the raw process water passes through the black walnut shell media, free oil and suspended solids are removed.
- After 24 hours of filtration, the raw process water is redirected to the bottom of the vessel to fluidize the media bed. A short vent step of approximately 30 seconds frees the filter of any accumulated free oil and gas in the top of the vessel. The media scrub pump is then turned on, which causes the black walnut shells to exit the vessel and circulate through the pump and media scrubbing vessel. It is the shearing action of the media passing through the impeller of the specially designed media scrub pump that positively cleans all of the media during each backwash cycle. A media clearing step insures that all of the black walnut shells are cleared from the scrub system prior to force setting of the media bed and the return to on-line filtration.
- The facility operates in the manner that it was designed, in that it requires far less operator intervention than a DAF system and is considered a success. Walnut shell filtration technology has proven to be a more suitable method of filtering free oil and suspended solids in applications where sand filters are conventionally used and should be considered for use at other new and existing wastewater facility installations.
Electronic Preparation of DMRs - An Alternative to Piles of Paper
Dillon L. Magers - Burlington Northern and Santa Fe Railway
AdriAnn T. Smith - Environmental Works, Inc.
John L. Williams - Pace Analytical Services, Inc.
Timely and accurate preparation of Discharge Monitoring Reports (DMR's) is an important element in complying with NPDES and similar permits. Coping with numerous outfalls at multiple facilities can tax the most efficient of managers who rely upon manual tracking of laboratory reports and hand completion of the DMR forms. Use of a database to track permit and outfall specific analytical data and to prepare the DMR's can greatly reduce the time required and the opportunity for errors.
Start-up activities required of the permit holder and the analytical laboratory will be discussed. Benefits, problems and common pitfalls will be highlighted. Critical factors that must be considered for success, such as client/laboratory communication will be presented. Additional items of discussion include chain-of-custody forms and electronic data delivery.
The difficulties, as well as the solutions, in using a database to complete DMR forms from the permit holder and the compliance consultant's perspective are considered. Topics include data management, report preparation and quality control. Program specific (local, state and Federal) DMR's are discussed.
Thursday 14 October 2004
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A Self-Sustaining Energy Source for High Vacuum Dual-Phase Extraction System
David Abranovic and Doug Shenk - ERM
Edwin H. Honig - Union Pacific Railroad
Extensive investigation at rail facilities in southern Arizona revealed a large scale free-phase fuel oil plume within a perched groundwater system approximately 70 feet below the surface. Several free-phase recovery technologies were pilot tested at the site, and a hybrid high vacuum dual-phase recovery system, consisting of bioslurping and pneumatic pumps, has been installed at the site. Currently six extraction wells are producing approximately 100 gallons of free-phase fuel oil per day.
The high vacuum dual-phase system requires approximately 40-horse power, resulting in significant energy costs. Utilizing the recovered fuel oil as an energy source for continued remedial activities has significantly reduced these cost. The recovered fuel oil is conditioned and used as fuel for a 100-kilowatt electric generator that powers the high vacuum dual-phase system. Several filtration steps, to remove suspended solids and water, are necessary to recondition the fuel oil prior to use. Although additional operation and maintenance (O&M) is required, this approach has reduced the energy cost by approximately 70 percent and eliminated all free-phase fuel oil disposal costs. A simple site evaluation procedure has been developed to evaluate the feasability of this approach at sites impacted with free-phase hydrocarbons. The factors that must be considered are: free phase composition and condition; system power requirements; sighting and permitting; and potential free-phase recovery rates over the life of the project.
Utilization of recovered free-phase hydrocarbons as an energy source not only reduces O&M costs, but is a conservationist approach to remediation that provides a substantial public relations benefit.
Use of Hydrocarbon Baildown Tests to Estimate the Recoverable Volume of Free-Phase Hydrocarbons in the Subsurface
Andrew Kirkman - The RETEC Group, Inc.
Judy McDouough - Burlington Northern Santa Fe Railway
Designing and selecting the most efficient remediation technology for subsurface free-phase hydrocarbon impacts at environmental sites requires an accurate estimate of the volume and recoverability of the free-phase hydrocarbons. Recovery estimates can also provide the basis for life-cycle predictions used in the cost/performance evaluation of technology alternatives. Estimating the volume and recoverability of free-phase hydrocarbons typically involves drilling and core analysis to obtain the site- specific parameters needed to model free-phase hydrocarbon distribution and behavior. These methods are relatively costly and may not be justified depending on the scope of the impacts.
Hydrocarbon baildown tests are a quick and inexpensive means of obtaining in-situ hydrocarbon transmissivity data. These data may be used to predict the mobility and initial recovery rate of free-phase hydrocarbon. However, estimates of recoverable volume require an additional parameter called the specific free-phase hydrocarbon yield. Specific free-phase hydrocarbon yield is analogous to the specific yield or storativity parameter used in groundwater hydrology (i.e., the volume of free-phase hydrocarbons yielded by a unit volume of soil). Site-specific fluid and core data are used to calculate this parameter.
RETEC recently completed a series of nine baildown tests at a facility with a range of free-phase hydrocarbon thickness. Specific free-phase hydrocarbon yield values derived from the baildown tests displayed a linear correlation with the free-phase hydrocarbon thicknesses measurements. Furthermore, site-specific fluid and capillary pressure soil core data were collected from this facility. The values of specific free-phase hydrocarbon yield obtained from core analysis were in close agreement with the baildown test results. This suggests that baildown tests may be a cost-effective alternative method of estimating the volume and recoverability of free-phase hydrocarbon in some circumstances.
Management of Impacted Soils During Reconstruction of a Rail Transportation Corridor
John Cavanaugh and John Moe - ERM
Alan Nye - CTEH
Michael Grant - Union Pacific Railroad
TBD - Peninsula Corridor Joint Powers Board (Caltrain)
Reconstruction and expansion of existing rail corridors often involves the disturbance and handling of large quantities of degraded ballast and subballast. In many instances, this material may be impacted with several chemicals of concern, including petroleum hydrocarbons, polynuclear aromatic hydrocarbons, and metals, primarily lead and arsenic. The presence of impacted material has cost, safety and schedule implications. The Caltrain/UPRR CTX project represent a typical reconstruction project.
A soil management plan (SMP) was devised for the CTX project to allow for the reuse of soil and ballast impacted with lead, arsenic, PAHs and petroleum within a 40-mile long right-way spanning 25 cities and three counties. Reuse values are based on risk calculated for several exposure scenarios. The SMP provides a legal basis for reuse within the context of California Title 22 regulations (hazwaste) and allows for the reuse of material that, if considered waste, would be characterized as hazardous waste. In the context of CTX project alone - allows for the reuse of 90 percent of the 150,000 tons to be disturbed, greatly reducing project cost and increasing the flexibility of the project schedule. Upon completion and implementation the SMP was considered a model plan by the RWQCB and DTSC, the oversight agencies.
A RBCA Approach to Derive Site-specific LNAPL Clean-up Criteria
David Abranovic and Doug Shenk - ERM
Edwin H. Honig - Union Pacific Railroad
A risk-based corrective action approach (RBCA) was developed to address light nonaqueous-phase liquid (LNAPL) in soil and groundwater. Because the LNAPL was shown not to pose a risk to human health, the objective of this work was to determine site- specific remedial standards for LNAPL based on criteria such as beneficial resource preservation and technical practicality. 40 CFR §280.64 stipulates that LNAPL must be removed to "the maximum extent practicable" and "in a manner that minimizes the spread of contamination to previously uncontaminated zones". These requirements are consistent with this approach to derive site-specific LNAPL cleanup criteria based on contaminant mobility and recoverability considerations.
A conceptual model of LNAPL migration was formulated which allows LNAPL to spread until it reaches an equilibrium condition, in which the gravity forces (head) causing the spreading of the LNAPL are balanced by the resistance offered by the non-wetting fluid entry pressure of the formation. Capillary pressure models presented by Charbeneau and Chiang (1995), Parker and Lenhard (1989), and Schiegg (1984) predict that there is a minimum thickness of LNAPL which must be added to a monitoring well before the LNAPL has sufficient head to enter the formation. This minimum monitoring LNAPL thickness, or LNAPL entry pressure, was calculated based on the physical properties of the LNAPL and project site conditions to determine a site-specific target monitoring well LNAPL thickness. Results indicated that LNAPL would cease spreading on this site when monitoring well LNAPL thickness is reduced to 0.5 foot. Diminishing return predictions for LNAPL recovery were made using a series of spreadsheets programmed with analytical solutions to radial multiphase flow equations, published by API (1999). LNAPL properties and site- specific soil properties were used as input values for the multiphase flow model, and a point of diminishing return for LNAPL recovery was predicted to occur when monitoring well LNAPL thicknesses were reduced to approximately 1 foot.
Although these results indicate that LNAPL removal to "the maximum extent practicable" at the site may be quantified as a reduction in LNAPL monitoring well thicknesses to approximately 1 foot (based on the diminishing return considerations), in order for the clean-up criterion to be protective of unimpacted media, the prevention of LNAPL spreading was given precedence over the diminishing return considerations. The clean-up criterion for this site was therefore recommended to be a permanent reduction ofLNAPL thicknesses in all site monitoring wells to 0.5 foot or less.
Free Product Recovery Without the Wait and Cost
Chuck Cline - Marshall Miller and Associates, Inc.
E.W. Chambers - Norfolk Southern Railway Company
The design and subsequent installation of a passive free product recovery trench at an active locomotive fueling facility was funding primarily through the "coupling" of the project with a planned storm water piping project. Due to the success of this project, a total of four free product recovery trenches have been installed at four separate locomotive fueling facilities.
At the original site of installation, replacement of the aging storm water piping system provided an opportunity for installation of a simple but effective passive free product recovery trench. The recovery trench was designed to capture free product from both perched and deep water-bearing zones and gravity feed it to an existing wet well and water treatment plant.
The recovery system captured over 8,000 gallons of free product in the first year of operation. The success of this project inspired the installation of three additional free product recovery trenches at three separate rail yards, one of which also involved capital funds, and one which resulted from an emergency response action. Each application of the technology presented unique challenges that required modifications which ultimately resulted in success. Measurable free product has been eliminated at three of the four yards where this technology has been employed within the first year of operation. Free product recovery trenches are currently being designed for two additional locomotive fueling facilities, one of which will be in conjunction with a fueling pad and storm water piping capital project.
The realized cost savings have been most significant when coupled with capital projects; however, the cost-effectiveness and technical feasibility of the free product recovery trench technology does not necessarily depend on the involvement of capital improvements. Although the merit of this approach differs based on site conditions (as is the case with any remedial technology/ approach), case studies show a cost savings of up to 75% when compared to alternative technologies, often with the elimination of measurable free product in a fraction of the time.
Biological Treatment of PAH-Contaminated Groundwater: A Rail Yard Case Study
Christine Guay and Helene Richer - Golder Associates, Ltd.
Denis Rho - Biotechnology Research Institute
Stella Karnis - Canadian National Railway
Remediation of groundwater aquifers contaminated with diesel in rail yards is often achieved using Multi Phase Vacuum Extraction (MPVE) systems. Typically, the liquid and gaseous effluents generated by these systems, even after the removal of the free phase product by an oil-water separator, are treated using expensive and short-lived activated carbon filter beds. We hypothesized that, through the substitution of these activated carbon beds by a biotreatment unit, the operation costs could be reduced and the treatment effectiveness (i.e., biodegradation vs. adsorption) could be improved.
The objectives of this research and development project are to demonstrate the effectiveness of a biotreatment unit associated with a MPVE system and to perfect its design to treat the highly charged effluents at a cost similar or lower to currently available treatment options, in a sustainable development perspective.
This three-phase project was comprised of several laboratory tests to study the characteristics of various types of organic and inorganic materials; the operation of a pilot-scale biological treatment unit; and the design and operation of a large-scale biological treatment unit linked to an existing MPVE system.
A peat-based filter bed was developed based on the physical/hydraulic performances of various types of peat and other mineral/ organic materials tested in laboratory. The biological performances of seven mixes having optimal physical / hydraulic properties were then tested using 10-L lab-scale bioreactors operated in parallel during a 4-month period. The bed showing the best overall performance was retained for the next testing phase, the operation of a pilot-scale biotreatment unit.
The 750-L pilot-scale unit was installed as part of an existing MPVE system at a rail yard in Montréal to determine on-site the optimal operating conditions. The performances of this unit were evaluated under various organic loads and hydraulic residence times. Significant reduction (i.e. > 95 %) of the petroleum hydrocarbon C10-C50 and polycyclic aromatic hydrocarbon (PAH) concentrations were measured in the aqueous effluents treated by this biological treatment unit over a trial run of four months. This pilot-scale test also confirmed that not only adsorption of the hydrocarbons to the peat moss occurred, but that biodegradation was the main process involved in the treatment, thus extending the removal capacity and the life expectancy of the bed.
The third phase of this project is currently under way and its objectives are to perfect the engineering of the air and liquid distribution systems and to validate the effectiveness of the biological treatment unit under real operating conditions and over several months of operation. The gaseous effluents treatment performance will also be determined during this phase of the project. A large-scale biotreatment unit (30 m3) has been designed and built on an existing MPVE system and its performance is currently being evaluated.
This Golder - BRI project was made possible by the contribution of the CN, the Centre d'excellence de Montréal en réhabilitation de sites, and the Fonds d'action québécois pour le développement durable and its financing partner, the Québec government.
Benefits of Bioslurping
Rhonda Gibson and Ted Lietzke - Earth Tech
A bioslurp system designed to recover free-phase diesel fuel has been in operation for over 5 years with much success. The plume, which covered approximately 2 acres and was measured up to 4 ft thick in wells, is essentially gone. Approximately 32,500 gallons of product have been recovered to date.
Product thickness and recovery are affected by fluctuations in the groundwater elevation, however in areas that have become product free, minimal residual effects are observed. Fluctuations in the groundwater mobilize product formerly trapped in the soil below the top of the water table causing product to reappear. Groundwater samples taken from wells formerly in the plume, that are now product free, have shown little to no dissolved phase petroleum constituents. Methods used to achieve these reductions will be discussed.
After five years the run time has been reduced from 24 hours a day originally to 2 hours a day. Further reductions of the operating time are expected in the near future. Agency negotiation strategy will be overviewed on achieving goal of closure and shutdown of the remediation system.
Remediation of a Rail Car Maintenance Facility
Frank Myerski and Robert Rittmeyer - ENSR International
J. Jay Grove - GATX
CERCLA Remedial Design and Remedial Action
Saegertown Industrial Area Site
General American Transportation Corporation (GATX)
A 100-acre site formerly utilized as a rail car maintenance facility was found to contain a large deposit of coal tar and related materials. PAH and PCB were identified as compounds of concern. The remedy selected for the site was on-site incineration of coal tar sludge and contaminated soil. In order to expedite remediation of the site in the most cost-effective manner possible, the following actions were taken:
- Obtained two modifications of the remedy (ESDs) that allowed for off-site use of coal tar sludge and heavily contaminated soil as supplemental fuel at a cement kiln and a utility boiler, and lightly contaminated soil as raw material substitute at a cement kiln. This resulted in lower unit disposal costs for excavated materials.
- Negotiated a Statement of Work that detailed procedures to be followed to satisfy performance standards specified in the Record of Decision. Included was a soil column approach to demonstrating compliance with the soil standard, which reduced the amount of soil excavated. Also included was a statistically designed sampling program that reduced the required number of confirmation samples.
- Prepared the Remedial Design on an expedited schedule. The 60% design deliverable was eliminated. Rather than modifying submittals to respond to EPA's comments, the comments were discussed by the design team (EPA, PADEP, ACOE and ENSR), an approach to address them was agreed upon and implemented in the following submittal. This reduced design costs and compressed the schedule. The project went from ESD to the field in 4 months.
- Negotiated Natural Resource issues associated with on-site wetlands. Prepared delineation and habitat assessments to value wetlands that would be disrupted by remediation. GATX reached a cash settlement with DOI/EPA whereby wetlands were replaced at another location. This saved $300,000 relative to on-site mitigation costs.
- Provided support to the EPA community relations plan, and implemented a parallel program to ensure proper representation of GATX's interests.
- Secured EPA's approval to collect confirmatory samples from the bases of excavations through standing water. This reduced the amount of water that needed to be pumped and treated.
- Secured EPA's approval to discharge water collected in excavations approved for closure directly without treatment. This reduced water treatment costs.
- Successfully petitioned EPA to reduce the parameter list for post-remediation groundwater monitoring based on the results.
- The cost for site remediation was reduced from the Feasibility Study estimate by 45 percent.