Burlington Northern Livingston Shop Complex CECRA Facility
The Burlington Northern Livingston Shop Complex, which includes an active rail yard, is primarily located in Livingston, Montana. The Facility is approximately 2 miles long and 0.5 miles wide, and includes locomotive and rail car repair and maintenance shops. Montana Rail Link (MRL) is the current rail yard operator.
Previous rail yard operating practices lead to contaminated soils and groundwater. Primary contaminants include chlorinated solvents, petroleum hydrocarbons, and asbestos. After completion of a remedial investigation, a risk assessment, two feasibility studies, and several interim remedial actions, DEQ issued a Record of Decision for the Facility in September 2001. The selected final remedy includes several remedial actions and additional investigations.
In September 2004, DEQ initiated negotiations with BNSF Railway Company (BNSF) to implement the Record of Decision (ROD). Those negotiations resulted in the August 9, 2005 Spring Statement of Work (SOW). The SOW identifies how additional investigations will be implemented for some of the tasks required by the ROD. On April 17, 2006, DEQ terminated negotiations for the remaining cleanup tasks. DEQ will develop the remaining work plans and schedules, and BNSF will be given the opportunity to implement the work. If BNSF chooses not to implement the work, then DEQ will complete the remedial actions itself. DEQ has been directing and providing oversight on activities at the Facility since the late 1980s and is now directing and overseeing both Spring SOW and non-Spring SOW related activities.
Progress on several tasks included in the SOW and outside the scope of the SOW is ongoing:
- BNSF has compiled a Comprehensive Interim Action and Confirmation Sampling Report and submitted it to DEQ so that DEQ can determine what additional sampling and remediation may be necessary related to the interim actions conducted at the Facility in the 1990s.
- Cinder Pile - The 6.6-acre pile of cinders, sludges, and other solid wastes, including asbestos, was capped and fenced. Vegetation and drainage of the cinder pile is monitored annually. BNSF must maintain the Cinder Pile.
- Floating Petroleum Recovery and Bioventing - DEQ and its contractor, CDM, developed work plans for two of the remaining tasks: removing floating petroleum from the groundwater and bioventing petroleum-contaminated subsurface soils. BNSF chose to implement the work, described as Phase I in the ROD, and has cooperated in completing the work included in the work plans. First, BNSF installed several soil borings and monitoring wells to further define the petroleum plume, which was found to be larger than previously suspected. BNSF then conducted prototype well testing to evaluate pumps, well designs, and recovery technologies. Over 400 gallons of petroleum were removed from the ground during the testing conducted between October and December 2006. During 2007 and 2008, BNSF installed 40 multi-use wells that can be used to recover petroleum or biovent and 7 additional bioventing wells in two phases. DEQ now estimates that over 27,000 gallons of petroleum have been removed or remediated and the system continues to operate. Phase II will consist of a permanent system to recover free product throughout the entire plume to the cleanup level, relying on information gained in Phase I and new technology advances.
- Chlorinated Solvent-Containing Alluvial Aquifer Groundwater – DEQ required the installation of several new monitoring wells and the sampling of all private or public wells within or near the plume. DEQ also approved pilot testing of sodium permanganate treatment of groundwater contaminated with chlorinated solvents. The technology appears promising and further testing will be conducted to determine whether DEQ will propose it as an alternative remedy.
- Indoor Air Monitoring – Several rounds of air sampling have been completed as part of an investigation of compounds potentially migrating indoors from the contaminated subsurface. BNSF has provided DEQ with sampling results. DEQ is not requiring additional investigation or the installation of mitigation systems in non-railyard buildings at this time.
- Surface Soil Investigation – BNSF has completed a visual survey and surface soil sampling on the rail yard. DEQ will evaluate the data and determine what additional actions will be necessary.
- Bedrock Aquifer Investigation – During 2010 and 2011, BNSF will investigate the bedrock aquifer or aquifers to determine whether solvents have contaminated this groundwater. If contaminants from the Facility are in the bedrock groundwater, DEQ will require BNSF to evaluate cleanup alternatives and remediate the contamination.
- Other Tasks – BNSF will have to investigate and remediate asbestos found on the rail yard. In addition, BNSF will have to investigate the C&P Packing property to determine whether remediation is necessary for that area of the Facility.
Once the SOW investigations are complete, DEQ will prepare work plans for all necessary remedial actions that are not under the SOW. BNSF will be offered the opportunity to implement all DEQ work plans. If BNSF chooses not to implement the work, then DEQ will complete the required actions. Pursuant to statutory language and a 1989 Modified Partial Consent Decree, DEQ is billing BNSF for the costs it incurs in overseeing and implementing work.