General Discussion

 Railroad tunnels seem to be the dirtiest environments in the wilderness.  How do the railroads manage the pollution?  There's soot and other chemicals that get into the runoff.  The episode of Extreme Trains (whose whole season is finally out on DVD) that deal with tunnel drainage repairs really got me worried about the runoff coming out of those tunnels and how they affect the surrounding wilderness.

Over- reaction?

You have bigger issues coming out of sheetflow drainage out of farm fields than you do out of tunnels. Mineral content out of native seepage is a bigger problem than soot, silt fines and anything rail carried in the tunnel effluent.

Tunnel mileage in this country is incredibly small. I have yet to work in a "dry" tunnel.

Mostly, it's just . . . . . .

The soot and other chemicals aren't any worse there than what is emitted elsewhere along the tracks, or by trucks and other diesels elsewhere - it's just that it is concentrated in 2 or 4 discharge channels, so you point is well taken there.  And imagine how much worse it would have been back in the day of steam locomotives !

But even worse is the 'acid mine drainage'* or 'AMD' and similar effects, from the ground water leaching out = dissolving whatever minerals and chemicals are in the overburden mountain's rocks - typically at least sulphur, which makes for sulphruic acid* - plus anything else of a particulate or solid nature from those rocks that might get suspended in the water along the way - think sand or asbestos particles, for example.

* Look at the rails and fastenings that come out of such 'wet' tunnels, and you'll understand how corrosive those flows can be. 

However, as a practical matter, most of that drainage/ discharge is usually either diluted or dissipated by soaking into the ballast before it gets too far, maybe even before it leaves the railroad's ROW.  As long as the discharge isn't traceable or isn't having a noticeable or measurable effect on the nearby ground or waterways, the informal rule of ''No harm - no foul'' probabaly governs - there are far worse things to worry about.

But if not, then here in Pennsylvania at least you might have good grounds for a environmental lawsuit on that basis - under the Commonwealth's ''Clean Streams Law'', which is much tougher than and not pre-empted by the Federal laws - if the discharge that gets into a stream of any size is of an 'industrial nature' = other than pristine, and the railroad had not obtained an appropriate NPDES permit, etc.

Hmmm - maybe I ought to team up with gabe and see if we can garner a big fee or award to fund my retirement with . . .

- Paul North.

Environmental permitting is an arcane specialty.  Class 1s employ an environmental permitting and compliance department with people that are expert in the field, as well as spend substantial sums on consultants. It's a field I touch on almost daily but I am not expert in the slightest, so this is just general guidelines:

The legal:  In most cases, existing railroad tunnels are categorically exempt from the National Environmental Policy Act (NEPA). New tunnels will generally require an environmental assessment (EA) or Environmental Impact Statement (EIS) along with everything else on the rail line.  Maintenance work to existing tunnels is almost always categorically exempt, too.   NEPA pre-empts most state laws for railroad environmental except in California, because California enacted CEQA (California Environmental Quality Act) prior to NEPA, therefore is grandfathered. 

This doesn't mean you just blithely do whatever you want; you will want to hire an environmental permitting expert and consider whether you need to file Findings of No Significant Effect memorandums with the governing agencies.  For some recent tunnel work, we did this with the State DEQ, the tribes, the counties, the SHPO, and the Corps.

The practical:  Think about where the emissions from the locomotives go if there is no tunnel: into the air, from where it falls into the environment, and if soluble, it all ends up in the water sooner or later.  Air emissions are regulated for precisely this reason among others.  An argument that the rail tunnel somehow concentrates the emissions and then dumps them into a specific environment is certainly possible to make, but would it succeed?  Doubtful.

RWM.

aegrotatio:

 Railroad tunnels seem to be the dirtiest environments in the wilderness.  How do the railroads manage the pollution?  There's soot and other chemicals that get into the runoff.  The episode of Extreme Trains (whose whole season is finally out on DVD) that deal with tunnel drainage repairs really got me worried about the runoff coming out of those tunnels and how they affect the surrounding wilderness.

As a former forester for the Northern Pacific and later Burlington Northern, I find your comments interestingly out of touch with natural occurances in undisturbed or nearly undisturbed environments.  The normal definition of pollution has a human causitive that delivers undesirable or unhealthful effects on the humans or the environment.  But what about "natural" events that cause pollution?   Several things come to mind...(1) spring runoff that turns steams and rivers roily with mud, and (2) the yellowing and cloudy effects of tanic acid from western larch leaf drop.  Both are natural occurances and are seen in all the wildlands of Montana and Idaho, where I worked.

We drew  our water directly out of a stream not 5 miles from the Bob Marshall Wilderness, and although logging had taken place upstream from us many years ago, roily water due to mud was not much of an issue, but tanic acid from the larch was.  We had the only house (or ranch -- whatever -- nothing but USFS land was upstream).  There were no houses, settlements, grazing cattle, railroads, or anything else beside inactive logging roads above us.  Basically, there was no human activity whatsoever upstream.

Western larch is a deciduous conifer...it drops it's needles every fall and is leafless all winter.  The needles are high in tanic acid, a water soluable yellowish-brown substance. The leaves (needles) fall in late October, and when high water comes in late May, the leaves give up their acid to the high water, turning the streams a cloudy yellow.  To put it in persective, my bathtub was Cerulian blue, and in June I could not see the bottom when taking a normal bath.  Ya, a little was due to mud, but most was from western larch, a native tree species. 

On another note, this "pristine" stream we drew our water from could not pass a coliform test because of animal droppings upstream.  No cows remember, just deer, elk, bear, grouse, and the like.  So much for pollution!  The tunnel thing is super-overkill.  Sorry to pop you bubble. 

Don't fish live in water, and....ummm....do stuff?  Beavers are decidely aquatic.  The odd duck can be found in water.  Rotting logs, ground seepage, run-off at any time, but worst in the late fall.

Mining is absolutely necessary for our ways of life.  No mines, no computers or power generation.  They disturb the ground on a massive scale. How about foundries and steel mills?   They would rank right up there.  Nowadays, the places in Asia where young kids pick apart the innards of cell phones and computers..they gotta be getting pretty bad just about today.

I don't know if people can fathom it, but a lot of hard science says mankind produces an exceedingly small portion of what could be termed free pollutants or problem substances annually that nature doesn't produce in far greater quantities.  It certainly applies to CO2.

-Crandell

selector:

Don't fish live in water, and....ummm....do stuff?  Beavers are decidely aquatic.  The odd duck can be found in water.

My wife finds it interesting that in two canyons near here that are in the watershed for the Salt Lake Valley, dogs and other pets are prohibited--yet there is much wildlife in the canyons. If you go out of any of the buildings at Snowbird Ski and Summer Resort, you see warnings that you are entering an area with wildlife, some of which can be dangerous to you. We think that there are far more deer, elk, badgers, potguts (a variety of ground squirrel) and other animals in these canyons than there would be dogs, cats, or what other pets that would be brought up by visitors.

Johnny

Railway Man:

  [snip] The legal:  In most cases, existing railroad tunnels are categorically exempt from the National Environmental Policy Act (NEPA). New tunnels will generally require an environmental assessment (EA) or Environmental Impact Statement (EIS) along with everything else on the rail line.  Maintenance work to existing tunnels is almost always categorically exempt, too.   NEPA pre-empts most state laws for railroad environmental except in California, because California enacted CEQA (California Environmental Quality Act) prior to NEPA, therefore is grandfathered.  

I took the question to pertain to 'stuff' running out of existing tunnels - not the construction of new ones.  I haven't yet found a specific USC or CFR provision that says quite how existing tunnels and maintenance of them are exempted, other than the general principle that since they are 'existing' and can continue to 'exist' without needing a 'new' federal permit or approval, they are effectively 'grandfathered'. 

But that right to continue to exist may be different from the environmental rules that apply to the operations of the facility.  While I doubt that such operating rules could have the effect of shutting down a facility, I wouldn't count on them as allowing free rein for unlimited discharges of toxics or haz-mats from the operation, either - that's just practical and common sense in this day and age.  For example, a fueling station can't be allowed to have its spills and leaks get into a nearby trout stream, or into the underground groundwater aquifer - that was the fear of the Hauser litigants.  Likewise, the tunnel discharge won't be allowed to contaminate a stream and cause a fish kill that can be traced back to the railroad.  Look at what happened - clean-up costs and fines - to SP after the acid spill on the Cantara Loop about 10 or 15 years ago, or to NS after its derailment and spill into the Allegheny 2 or 3 years ago - and those had the potential defense of being extraordinary situations, not routine operations.

It seems that the STB has the power to decide what projects have to file an EIS - per the BNSF's Hauser, Idaho fueling station litigation.  That wasn't a new line, so the STB didn't require one - but I think it's clear that STB would require an EIS for new construction outside of an existing ROW, as RWM says above.  The rationale behind the Hauser case - 'modifications and improvements to existing facilities generally have such a small impact that they don't need and EIS' - is likely exactly how the tunnels are exempted.

Pennsylvania's Clean Streams Law goes back to the 1930's sometime - amazingly enough, for a state that was run for many years by the coal, iron/ steel, and railroad industries - and as such pre-dates all Federal Laws except the US Constitution and the Corps of Engineers jurisdictional law, which I believe dates from the 1880s or thereabouts.  So I would be surprised if it too isn't grandfathered the same as CEQA as referenced by RWM above.  I'll have to look that up sometime.

- Paul North.

selector:

I don't know if people can fathom it, but a lot of hard science says mankind produces an exceedingly small portion of what could be termed free pollutants or problem substances annually that nature doesn't produce in far greater quantities.  It certainly applies to CO2.

I recall reading some time ago that the thing that took the wind out of the sails of the great mercury scare was the discovery of a fossilized fish which contained levels of mercury comparable to what is found in fish today. 

That doesn't make it healthy, but, as you suggest, man isn't always the villian some folks would make him out to be with regards to pollution.

And there is a reason that outfits that sell camping gear carry water purifying kits....

selector:

  Don't fish live in water, and....ummm....do stuff?  Beavers are decidely aquatic.  The odd duck can be found in water.  Rotting logs, ground seepage, run-off at any time, but worst in the late fall.

Mining is absolutely necessary for our ways of life.  No mines, no computers or power generation.  They disturb the ground on a massive scale. How about foundries and steel mills?   They would rank right up there.  [snip] I don't know if people can fathom it, but a lot of hard science says mankind produces an exceedingly small portion of what could be termed free pollutants or problem substances annually that nature doesn't produce in far greater quantities.  It certainly applies to CO2.

-Crandell 

Somehow it's become an axiom of environmental science that pretty much the first thing you do is separate and classify the substances according to their source and what they are.  Thus, much of what has been mentioned above as occurring naturally is considered to be 'background' or 'off-site' or 'pre-existing' pollution, and hence is generally not the responsibility of a particular site owner/ operator. 

This often comes up now in the context of TMDL = ''Total Maximum Daily Loadings'' of 'stuff' for discharges into streams.  Specifically, for STP = Sewage Treatment Plant discharges, suppose the local environmental agency has said that to maintain acceptable water quality in a certain receiving stream, the TMDL for BOD = Biological Oxygen Demand - which is a measure of organic decompostion of a lot of the stuff that gets flushed down from toilets and garbage disposals, etc. - can't exceed a concentration of 20 PPM = Parts Per Million.  If the stream is presently at a BOD concentration of 15, then the STP can't release more BOD than would cause the total weighted concentration to go over 20 - depending on how much dilution occurs, the STP's actual discharge could have a concentration somewhat higher that the 20 BOD level.  But if 'non-degradation' = 'can't make the stream any worse than it is now' criteria apply, then the STP's BOD discharge can't be over 15 PPM.  And if the stream's present concentration is over 15 PPM, then the STP is out of luck - it can't discharge anything.  That has been and is going to be a major part of the pending environmental vs. development and jobs debates and battles in the next few years. 

But back to the tunnels.  What runs out of them is not a naturally occurring process like critter excrement, even if it is coming from the rocks - it's the activities of man have let those agents loose.  Here in Pennsylvania the Acid Mine Drainage is without question a major man-made problem, and it's real easy to tell the difference between the streams that have been impacted by it and those that haven't - there's no vegetation, fish, or small critters in them, and the rocks are often stained a uniform yellow or red.  Even the stream in the valley below the world-famous Horsehoe Curve - Burgoon Run / Glen White Run - was heavily polluted by AMD until recently.  I'll see if I can find a link for that, as well as the Lausanne Tunnel AMD Remediation project - it was something like a 6-mile long mine drainage tunnel - and for the Barnes & Tucker Clean Streams Law case, where a mining company was ordered to build and maintain a treatment plant for AMD in perpetuity - which was upheld by the Pennsylvania Supreme Court in the 1950s, if I recall correctly.  That was literally an earth-shaking event in the coal industry here back then.

- Paul North.

Link to Altoona City Authority's ''Case Study'' on Glennwhite Watershed (Horseshoe Curve).  Note that near the bottom of the narrative, mention is made of a using for this project a penalty that was assessed against ConRail, but no details are provided as to when, where, for what, etc.

http://altoonawater.com/water/watersheds/ws_case.html 

- PDN.

 Technical ionfo on AMD from the Wildlands Conservancy's 2008 Annual Report, page 5, at: http://www.wildlandspa.org/news/2008_annual_report.pdf 

Without remediation, the abandoned coal mines will continue to discharge metals, acids, and other pollution into the Lehigh River and its tributaries, negatively impacting our drinking water, habitat for wildlife and fish, and recreational opportunities for residents and tourists.  The Lausanne and Buck Mountain remediation projects have already greatly reduced the pollution from these abandoned mines.

 The Barnes & Tucker Coal Co. AMD remediation order case was from 1974, not the 1950s as I said above.  Here's a link to short article on it:

http://news.google.com/newspapers?id=j9wNAAAAIBAJ&sjid=_mwDAAAAIBAJ&pg=4192%2C3830542

And a link to a book article on it:

http://books.google.com/books?id=7X-LOd9uY0QC&lpg=PA148&ots=iXhd3-FxSu&dq=POLLUTION%20CASE%20supreme%20%22BARNES%20%26%20TUCKER%22&pg=PA148#v=onepage&q=POLLUTION%20CASE%20supreme%20%22BARNES%20&%20TUCKER%22&f=false 

Thanks for all that effort, Paul.  The results are both encouraging and reassuring. 

I have a closer-than-I'd-like connection to a gold mining project out west in your country that went bad.  I was not involved in any way, but my father was a consultant for the operation when it was being stood up.  Due to penalties and rigid contractual requirements imposed by lenders, the various construction elements were sometimes pressed during dangerous conditions.  One result was an unkown tear in a heap-leaching pond where cyanide was sprayed over gold-bearing material.  This was at 7-8K feet, where a lot of melt and ground water ran with gravity.  I am sure you can figure out the rest.

-Crandell

You're welcome, Crandell.  Wasn't too hard - mainly thinking about where I'd seen certain things, and then tying them together in a way that would make sense to a layperson.  I've seen the Lausanne Tunnel discharge point in person on one of may canoeing trips a few years ago - which was owned by the coal mining subsidiary of one of the anthracite railroads, I believe - as well as the Glennwhite Run at Horseshoe Curve in this past August.  Plus, I worked in that field for a few years, and still dabble in it.  Along the way I managed to corrupt my daughter, who now has a Master's Degree in Geology specializing in hydro-geology and geochemistry, is a P.G. = licensed as a Professional Geologist, and has and still does work for a couple of large multi-national environmental consulting firms, mainly on the clean-ups of various 'SuperFund' sites around the US.

Thinking about this a little further led to the following:  Shorter tunnels - like only a couple hundred feet long - usually don't discharge too much water, simply because there's not that much surface area or depth of overburden above them to capture and hold the water, and their length is so short that the exposed interior surface area is not too much.  However, logic and experience follows that the longer tunnels will usually produce much larger volumes of groundwater discharge, as well as the soot problem mentioned by the Original Poster.  Well, your country has a couple of the longest railroad tunnels in the world - CPR's Connaught and Mount McDonald Tunnels - which might be subject to this kind of thing.  In particular, Mount McDonald having been built in the modern age of environmental concerns - and right in the middle of a major Candaian National Park - got me to wondering if and how these concerns were addressed there.  For all of the trouble that CP had to go to during construction to minimize environmental impacts, I expect that these would have been identified and addresed by the Parks Canada review and approval and mitigition process, etc.  I searched briefly 'on-line', but have not yet found much of anything in that regard.  However, I did stumble across the following related excerpt: