The railroad industry must contend with a variety regulatory and environmental compliance challenges. Construction permitting and emissions inventories remain an ongoing concern, as facilities must comply with state air quality regulations for stationary operations and maintenance equipment. Regulated equipment includes sand handling systems, fuel storage tanks, combustion engines, cleaning equipment, miscellaneous paint usage, and other units. The rail industry must also comply with a variety of MACT standards, including the Miscellaneous Metal Parts Coating MACT, the Reciprocating Internal Combustion Engines MACT, the Industrial/Commercial /Institutional Boilers and Process Heaters MACT, and the Site Remediation MACT. All of the regulations require significant recordkeeping and reporting activities in order to demonstrate compliance. Finally, rail yards must also inventory and quantify air emissions to determine Title V applicability.
"Hot Topic" - Climate change is emerging as a critical environmental management issue for railroads today. Railroads are faced with rapidly evolving state, regional, and federal regulatory framework in the United States. Moreover, railroads face added pressures from stakeholders, shareholders, and the general public to respond to broader issues such as business sustainability and corporate social responsibility. Accordingly, many railroads are choosing to be proactive in devising a corporate strategy for climate change and sustainability.
Regulatory Round Up
- Surface Coating of Miscellaneous Metals Parts and Products MACT – On January 2, 2004, the U.S. EPA promulgated Maximum Achievable Control Technology (MACT) standard MMMM for surface coating of miscellaneous metal parts and products. Miscellaneous metal parts and products include metal components of the following products as well as the products themselves: motor vehicle parts and accessories, railroad cars, heavy duty trucks, steel drums, industrial machinery, metals pipes, and other industrial, household, and consumer products. Railyards that are major sources of hazardous air pollutants (HAPs) and perform surface coating of miscellaneous metal parts and products are potentially subject to the emission limitations, operating limitations, work practice plan, recordkeeping, and reporting requirements of MACT MMMM.
- Stationary Reciprocating Internal Combustion Engines NSPS and MACT – The U.S. EPA promulgated NSPS Subpart IIII for Stationary Compression Ignition Internal Combustion Engines (CI-ICE) on July 11, 2006 and NSPS Subpart JJJJ for Stationary Spark Ignition Internal Combustion Engines (SI-ICE) on January 18, 2008. EPA has also promulgated MACT Subpart ZZZZ for Stationary Reciprocating Internal Combustion Engines (“RICE MACT”) which regulates HAP emissions from stationary, reciprocating internal combustion engines at major and area sources of HAPs. CI and SI engines subject to NSPS Subpart IIII or JJJJ are either exempted from requirements under the RICE MACT or must comply with the RICE MACT by meeting the requirements of NSPS Subpart IIII or JJJJ.
Many previously unregulated smaller engines, including those designated for emergency use, are now subject to federal regulation, including emissions standards and associated control, monitoring, testing, recordkeeping, and reporting requirements.
Due to the complex applicability and testing requirements of the rules, we recommend that railyards: (1) review each new and existing stationary engine for NSPS and NESHAP applicability, (2) confirm that fuel vendors will be able to meet the fuel sulfur requirements, (3) train personnel on the importance of maintaining certified engines according to manufacturer’s instructions, and (4) create a compliance tracking and recordkeeping system for engines subject to the NSPS or NESHAP.
- Gasoline Dispensing Facility MACT – On January 10, 2008, EPA promulgated MACT Subpart CCCCCC for gasoline dispensing facilities. A gasoline dispensing facility is defined as a stationary facility which dispenses gasoline into the fuel tank of a motor vehicle. MACT Subpart CCCCCC is applicable to gasoline storage tanks and equipment necessary to unload product from cargo tanks into gasoline storage tanks. Many railyards with gasoline tanks for filling yard vehicles are potentially subject to emission limitations, management practices, testing and monitoring requirements, and recordkeeping and reporting requirements, depending on the monthly gasoline throughput.
- Paint Stripping and Miscellaneous Surface Coating MACT – On January 9, 2008, EPA promulgated MACT Subpart HHHHHH to address emissions of HAPs resulting from paint stripping activities that involve the use of methylene chloride and from miscellaneous surface coating operations at area sources (i.e., sources that are not major sources). Miscellaneous surface coating operations include those that involve the application of coatings to miscellaneous parts and/or products made of metal or plastic, or combinations thereof, including brakes, engines, freight cars, and locomotives. The HAPs of concern resulting from miscellaneous surface coating operations include cadmium, chromium, lead compounds, manganese compounds, and nickel compounds. Emissions controls, personnel training, recordkeeping, and reporting requirements may be applicable to miscellaneous surface coating operations at railyards.
- Trinity has completed air emissions inventories and regulatory applicability studies for several railyards associated with a Class I railroad. These reports document regulatory authorization for equipment, Title V status, state and federal regulatory applicability, and emissions inventory requirements.
- Trinity has completed several construction and operating permit applications, including revisions and renewals, for individual pieces of equipment, as well as sitewide permit applications and permit amendment applications for a variety of railroad clients.
- Trinity has assisted railroad clients with compliance assistance tasks ranging from checklists and watch lists to an Environmental Management Information System (EMIS) project for a Class I railroad. The EMIS was implemented at two pilot facilities.
- Trinity has performed environmental audits at railyards and helped pursue corrective actions to the findings from the audits. Trinity has analyzed whether air emissions reduction projects at railyards merit consideration as sources of emission reduction credits.