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Guidelines for railroad spill containment compliance

Leaks and Spills

NOTE: The following question is to help the facility examine its operations relating to leaks and spills for compliance with environmental requirements:

This question appears in the following text and may be accompanied with a discussion of the preferred answer (indicted with a checkmark) for environmental compliance.

Are facility crews trained to detect and report all spills and leaks immediately?

If Yes - Facility trains crews to report all spills and leaks to the central dispatcher immediately upon detection.
If No - Facility does not train crews.

Does the facility inspect locomotive track areas for oil spills and leaks?

Regular cleanup of track areas should be conducted whenever visible contamination is detected. Even if no oil contamination is visible, conduct regular inspections for locomotive leaking. Whenever leaks are detected, the facility should take immediate action to minimize drippings. Actions should include engine maintenance, the use of absorbents, and regular emptying of drip pans installed under the locomotive idle and storage areas to catch drips of oil, fuel, and coolant.

Consult the SPCC plan in the event of a spill or leak. In addition, if any oil enters surface waterways and produces a sheen, notify the National Response Center (1- 800-424-8802) and state emergency agency immediately.

If Yes - Facility inspects these areas for oil spills.
If No - Facility does not inspect these areas for oil spills.

Compliance Tip:

It is a good idea for a short line railroad facility to have spill kits near areas where experience has shown leaks and spills likely to occur. Such spill kits may include kitty litter, organic-based absorbents and other tools for containment.

Absorbents/Track Mats

NOTE: The following questions will help the facility examine its operations relating to absorbents and track mats for compliance with environmental requirements.

This question appears in the following text and may be accompanied with a discussion of the preferred answer (indicted with a checkmark) for environmental compliance.

Absorbents

Cleaning up spills and releases of chemicals and petroleum products involves the use of materials such as kitty litter type substances (known as quick dry, speedi dry, or oil dry), clay absorbent, pads, pillows, booms, towels, and other such absorbent materials. Sawdust is also sometimes used as an absorbent. One must use the proper absorbent for the type of chemical spilled. Once used in a cleanup, the facility must dispose of these materials properly.

Does the facility use sawdust, soil, or other commercial absorbents for spills or leaks?

If Yes - Facility uses one or more of the above substances.
If No - Facility does not use any of the above substances.

Does the facility determine if used absorbents (e.g., track mats) are hazardous wastes before disposal? Absorbents are hazardous waste if:

1.  

they are contaminated with a hazardous material such as solvent or gasoline, or

2. 

they are characterized as hazardous by the facility. Although used oil is not considered a hazardous waste if it is recycled, it is a hazardous waste if it is disposed of in a landfill and has hazardous characteristics.

Thus, anything that absorbs used oil and is thrown in the trash could be considered a hazardous waste, even if it is not mixed with a hazardous waste. For more information regarding used oil regulatory requirements, refer to 40 CFR Part 279.

If Yes - Facility has determined whether used absorbents are considered hazardous before disposal. 
If No - Facility does not characterize its absorbents.
If N/A - Facility does not generate used absorbents.

How does the facility manage absorbents used for oil spills?

Note: The facility should determine whether used absorbents are hazardous before disposal.

Track Mats

Use Absorbent Track Mats For Effective Railroad Spill Containment

Some facilities use track mats as absorbents to protect the track and ballast area from locomotive leaks. The facility should test such absorbents to determine whether they are hazardous or not and managed accordingly. If the track mats are hazardous, then the facility must include them when determining its generator status. Some service companies will pick up contaminated track mats.

If sent to supplier or service company - Facility returns used absorbents to its supplier or pays service company to pick up used absorbents.
If burned for energy - Facility burns absorbents used to soak up used oil for energy recovery in a space heater with maximum heating capacity of less than 0.5 million BTU per hour.
If Disposed of as hazardous waste - Facility places hazardous absorbents in drums, labeled as Hazardous Waste, and disposes of them through a hazardous waste hauler.
If Nonhazardous and landfilled - Facility determined that the absorbents are a nonhazardous solid waste and disposes of them with regular trash.
 If Other - Facilitys method of management is not listed here.
If N/A - Facility does not use absorbents.

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