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 active locomotive and rail car repair and maintenance shops. Montana Rail Link (MRL) is the current rail yard operator.
Previous rail yard operating practices led 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 identified how additional investigations would be implemented for some of the tasks required by the ROD. On April 17, 2006, DEQ terminated negotiations for the remaining cleanup tasks.
Since that time DEQ has required BNSF to develop the remaining work plans and schedules, and BNSF has been given the opportunity to implement the work. If BNSF chooses not to implement any future 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. Most of the Spring SOW activities are now complete.
The Livingston Restoration Group (LRG) was formed following settlement of a large lawsuit with BNSF. DEQ was not a party to the lawsuit and is not part of the LRG. The LRG is working with BNSF to address various tasks at the Facility and is also conducting independent actions.
Progress on several tasks is ongoing:
- BNSF has compiled a Comprehensive Interim Action and Confirmation Sampling Report and submitted it to DEQ. DEQ has used this information to determine what additional sampling and cleanup is 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 following sludge removal. Vegetation and drainage of the cinder pile is monitored annually. BNSF must maintain the Cinder Pile. Soil vapor samples collected in 2007 and 2013 indicated that sludges might remain within the Cinder Pile. BNSF and the LRG are conducting additional investigation required by DEQ. If chlorinated solvents are confirmed in the Cinder Pile, DEQ will require BNSF to evaluate cleanup options.
- Floating Petroleum Recovery and Bioventing - DEQ and its contractor, CDM Smith, developed work plans for the tasks of removing floating petroleum from the groundwater and bioventing petroleum-contaminated subsurface soils. BNSF chose to implement the work, described as Phases I and II in the ROD, and has cooperated in completing the work included in the work plans. In 2006, 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. In 2012, BNSF completed Phase II by installing recovery and bioventing wells south of Park Street to address the remaining extent of the plume. DEQ now estimates that over 50,000 gallons of petroleum have been removed or remediated and the system continues to operate. At the end of 2014, DEQ determined that the recoverable petroleum had been successfully removed. DEQ approved shutting down the recovery system and bioventing to address the residual petroleum. If groundwater monitoring identifies additional petroleum in the groundwater that could be removed, DEQ will require BNSF to turn the recovery system back on.
- Chlorinated Solvents in Alluvial Aquifer Groundwater – DEQ has required the installation of several monitoring wells and the sampling of all private or public wells within or near the groundwater plume. DEQ also approved pilot testing of sodium permanganate treatment of groundwater contaminated with chlorinated solvents. The technology appears promising and may be part of the final remedy for this contamination. Soil vapor extraction has also been implemented to address vapors beneath the railyard buildings. Finally, BNSF and the LRG have investigated the wastewater manways as potential sources of contamination.
- 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 developed final indoor air cleanup levels using EPA toxicity criteria. DEQ is not requiring the installation of mitigation systems in any buildings at this time. BNSF and the LRG are conducting long-term air sampling to verify the previous results.
- Surface Soil Investigation – BNSF completed a visual survey and surface soil sampling on the rail yard. DEQ required BNSF to clean up “hot spots” with elevated petroleum and polycyclic aromatic hydrocarbon (PAH) contamination on the railyard. DEQ also required BNSF to clean up PAHs and lead in a few yards located in a nearby mobile home park. This cleanup was conducted in 2013.
- Bedrock Aquifer Investigation – From 2010 to 2014, BNSF has installed several wells to investigate the bedrock aquifer to determine whether solvents have contaminated this groundwater. High levels of tetrachloroethene (PCE) have been found in three bedrock wells with the highest level at 55,000 µg/L. The PCE cleanup level defined in the ROD is 5 µg/L. DEQ will now require BNSF to evaluate cleanup alternatives and remediate the contamination.
- Other Tasks – During the surface soil investigation, DEQ discovered additional asbestos debris throughout the railyard. DEQ required BNSF to investigate and clean up asbestos found on the rail yard. The cleanup was completed in 2013. In addition, BNSF and Pacific Steel will have to investigate the C&P Packing property to determine whether cleanup is necessary for that area of the Facility. DEQ will also require that BNSF verify that the cleanup of the API Separator Ponds and the removal of the former underground storage tanks was adequate.
DEQ will continue to require BNSF to complete the remaining actions to investigate and clean up contamination at the Facility. Pursuant to the Comprehensive Environmental Cleanup and Responsibility Act and the 1990 Modified Partial Consent Decree, DEQ is billing BNSF for the costs it incurs in overseeing and implementing work.