Integrated Compliance Program
This Class I railroad is responsible for managing the operations of 22 rail yards and five intermodal facilities located across the state of California. These complex operations, with varying permit and compliance requirements, involve multiple contract operators providing diverse services at different facilities. A consultant, knowledgeable in the complex state regulatory environment, railway operations, and compliance reporting standards, was required to develop and implement an effective approach to minimize compliance issues across the facilities and contractors.
With compliance assessment and reporting needs touching on air quality, spill controls, hazardous materials and waste management, wastewater, and stormwater – as well as numerous safety aspects related to these issues – GES developed an approach to efficiently and consistently compile and evaluate related sampling data, site information, existing records, and reporting practices, and to identify any gaps at these diverse locations.
GES consultants met with the local health and safety managers and the operators’ regional managers to plan and implement a productive, streamlined approach. A dedicated team adhered to predetermined monthly schedules and travel routes to simplify task coordination and knowledge transfer activities. Working collaboratively with the client’s team, sites were prioritized based on stormwater sampling requirements and priority. Efficiencies came from pre-packaged lab sampling kits and by grouping services, including on-site corrective actions, concurrent with inspections.
Final deliverables encompassed air-quality permitting; spill prevention, control, and countermeasure (SPCC) plans; stormwater monitoring, reporting, and best management practices; inventory and preparation of hazardous materials business plans; wastewater management; and integrated compliance plans. GES professionals provided operators’ teams with safety training, including hazardous waste requirements.
The railroad achieved its environmental stewardship goals and improved its relationship with regulatory agencies and stakeholders ranging from the US EPA to the regional water quality boards, air-quality management districts, and local fire departments. This consistent, unified approach allowed the rail company to realize additional quality assurance and cost effectiveness, while also achieving greater operational efficiencies through a comprehensive compliance program. Non-compliance issues across the facilities, as well as any reportable quantity releases, have decreased significantly under this program.