Short Line Connector - Fall 2016 - 31


LINESIDE

PREPARING A SHORT LINE
STORMWATER POLLUTION
PREVENTION PLAN
BY DEAN KREBS AND TINA COX, ANTEA GROUP

F

ederal stormwater regulations
require various industrial personnel, including railroad owners and
operators, to take action to eliminate or
minimize pollution levels. Depending on
Standard Industry Classification codes and
their risk of stormwater exposure, facilities
might need coverage under the General
Industrial Stormwater Permit to avoid
regulatory violations or fines.
Some facilities are required to prepare
a Stormwater Pollution Prevention Plan
(SWPPP) that is, in part, a collection
of Best Management Practices (BMPs)
that serve as pollution control measures.
In addition, many states have their own
requirements that must be accounted for
with an SWPPP, which is precisely why
an environmental health and safety (EHS)
professional has become a go-to resource
for understanding these intricacies.
The Need for Specialized Expertise
The EPA, in addition to numerous states,
provides a template for facilities to follow
when creating a plan. To assess a facility,
railroad operators must identify all areas
that could be a source of pollution, including areas where dust might generate; railcar
loading and unloading locations; fueling,
cleaning and maintenance locations;
material storage; waste storage, treatment
and disposal; yards surfaced with gravel or
crushed rock; and roofs.
By carefully examining activities, not
just the types of materials being handled
at their facilities, SWPPP developers form
a comprehensive overview of potential
pollution areas.

Because of the numerous regulations
and factors that must be monitored,
facility operators benefit by having
experts assist with the development of an
SWPPP. In even more complex cases, a
stormwater program for operators with
multiple facilities in several states can
also be developed with the guidance of
EHS professionals. If a plan is already in
place, updates and sampling for permit
compliance must be completed, and in
some cases certain requirements must be
performed by a certified professional. For
example, a Qualified Industrial Stormwater
Practitioner is now required in California
for certain activities under the industrial
general permit.
As stormwater-related problems arise,
facilities with an established SWPPP will
see the benefit of the updated plans and
practices that resulted from the guidance
of their EHS partner.
Reducing Future Risk
If your facility does not have a spotless
history, experts can help ensure that prior
violations do not lead to more serious
consequences in the future. In 2015, the
EPA found that a Massachusetts railroad
did not minimize the impact of stormwater leading to nearby surface waters. The
agency fined the organization more than
$150,000. In this instance, BMPs were not
in place to address debris; more guidance
and oversight could have saved the railroad
time and money. An EHS expert could get
the right plans and processes implemented,
showing that the company is truly committed to making improvements.

Other violations that can result in
fines include failure to conduct monthly
or annual stormwater inspections or
failure to monitor the pollutant levels
of runoff. With ever-changing variables
such as regulatory and facility changes
and erosion affecting pollution risks,
regulatory compliance might be met one
year, but not the next. It is vital to have a
trusted partner who can ensure facilities
remain compliant amid the changing
regulatory environment.
Next Steps
In most cases, federal regulations will mandate an efficient and productive SWPPP
for Class II and Class III railroad facilities.
Rail line operators must be proactive and
consult with experts to fully understand
the requirements and EHS issues that
affect them most.
An experienced professional can
design BMPs to save the railroad money
and can help select the most appropriate
BMPs. Such professionals can also offer
guidance on proper equipment installation and maintenance. This approach can
also help facilities stay current on new
technologies and eliminate the need to
do (and spend!) more than is necessary.
Short line operators who seek outside
consultation will see a payoff on their
bottom lines. —
Dean Krebs, senior environmental engineer
and program director, leads Antea Group's
Railroad Segment. Tina Cox has more than
12 years of professional experience in environmental consulting.

FALL 2016 // SHORT LINE CONNECTOR

31



Table of Contents for the Digital Edition of Short Line Connector - Fall 2016

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Short Line Connector - Fall 2016 - Cover1
Short Line Connector - Fall 2016 - Cover2
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Short Line Connector - Fall 2016 - 2
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Short Line Connector - Fall 2016 - Cover3
Short Line Connector - Fall 2016 - Cover4
http://www.nxtbook.com/ygsreprints/ASLRRA/summer19
http://www.nxtbook.com/ygsreprints/ASLRRA/spring19
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http://www.nxtbook.com/ygsreprints/ASLRRA/spring2016
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