First, the site, a former municipal dump last used in 1962, will be completely cleaned up. The first phase of the project involves actually removing the waste from the site and properly disposing of it at Lancaster County's Frey Farm Landfill. Afterward, clean earth fill will be deposited and compacted to raise the grade to match the existing rail line. Though the removal of the old waste material adds several million dollars to the cost of the project, it is unquestionably the most responsible approach to cleaning up the site.
Second, based upon NS's current and projected customer activity, the additional rail capacity created by this project will divert approximately 55,000 trucks annually from Central Pennsylvania highways and roads. Put simply, fewer trucks means cleaner air for area residents and reduced highway maintenance costs for taxpayers. These benefits support the goal of reducing traffic on the region's overcrowded highway system and improving air quality conditions.
Third, moving freight by rail is a "greener" method than shipping by truck. A recent Wall Street Journal story noted: "Railroads say a load can be moved by rail using about a third as much fuel as it takes to haul it by truck. Railroads have friends among environmentalists, who see moving freight by train rather than truck as a way to reduce fuel burning and emissions. States have also started to climb aboard. In a 2002 report, the American Association of State Highway and Transportation Officials said transportation capacity could be increased more cheaply in some intercity corridors by adding railways rather than expanding highways."
Finally, NS predicts that because of the additional storage capacity that the new yard will create, the Farmingdale Road and Good Drive rail crossings will be closed for shorter periods of time. Currently, trains are sometimes switched on the main tracks, which, requires the closing of the crossings. By providing more yard capacity to store train cars, switching on these main tracks will be eliminated and the crossings will be closed for shorter periods of time. This means fewer traffic backups at these crossings and shorter delays when crossings are closed.
The environmental characterization of the former dump has been completed and its footprint determined. The Pennsylvania Department of Environmental Protection (DEP) must approve the waste removal plan before any work can begin, and afterward the DEP must certify that the clean up was completed properly.
The project will follow the federal National Environmental Policy Act (NEPA) because of the potential use of federal funds to complete the project. In November 2007, a scoping field-view was completed by representatives from the Pennsylvania Department of Transportation (PennDot) and the federal Department of Transportation. These officials reviewed the study area, discussed the proposed project and confirmed the level of NEPA documentation required. Studies will be conducted to characterize wetlands, streams, floodplains, threatened and endangered species, farmlands, historic structures, archaeological resources, hazardous or residual wastes, impacts to local businesses, and other concerns. The process has been started and the results will be submitted to PennDot for review.
At the beginning of the project, the College and Lancaster General committed to evaluating/assessing air quality, sound and vibration impacts. The scope has been expanded in response to questions raised by local officials and residents at our meeting in February. The College and Lancaster General will confirm that this project does not create an unacceptable health concern for the area before any work begins.
Initial air quality, sound and vibration studies also are underway and will be completed in May. The air quality model uses a standard methodology incorporating national standards for activities creating emissions, then comparing them with existing conditions and modeling their impact. In other words, the precise activity being introduced into an area is modeled to see whether it affects the existing environmental conditions. The results are then compared with federal and state air quality standards for risk assessment.
The sound and vibration studies will use standard methodologies that will be conducted in a comprehensive format with expanded areas of assessment not typically performed in such projects. Instruments will be used to capture existing conditions. Future sound and vibration levels will then be predicted using Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) models. This data is combined to determine projected impact and compare it with national standards.
First, NS will not be adding any additional locomotives as a result of this project. Thus there will be no new source of diesel emissions. Second, the current yard is so small that NS must move its rail cars three or four times to get them into the correct position for shipping. With the new yard this inefficiency will be eliminated because cars will have to be moved only once or twice during the process. Improving the efficiency of the operation should reduce air emissions from their current levels. Also, NS locomotives are equipped with technologies that reduce idling when not in use. Finally, the federal Environmental Protection Agency (EPA) recently finalized a three-part program that will dramatically reduce emissions from diesel locomotives of all types-including line-haul, switch and passenger rail locomotives. The rule will cut particulate matter emissions from these engines by as much as 90 percent and nitrogen oxide emissions by as much as 80 percent when fully implemented.
Because the number of locomotives will not increase and the locomotives already operate in the area, we anticipate no significant negative effect on air quality. Air quality modeling for existing and future rail yard locations is being performed to confirm this finding.
Both institutions are committed to mitigating noise created by the project through the installation of sound walls and/or landscaping buffers along the tracks. Even if not required by PennDot, these buffers will help protect nearby neighborhoods. Our engineers will use the results of the sound studies to recommend the most effective mitigation efforts.
1. Health Risks:
Some project opponents cite an EPA air quality study conducted in California and publicized in a 2007 National Public Radio story. A main subject of this study and story was a large facility near the Port of Los Angeles where trains, tractor trailers and container ships are located to form one of the largest (if not the largest) intermodal facilities of its kind in the world to distribute raw materials and finished products across the nation. The Los Angeles rail facility is approximately 900 acres in size and handles an estimated 100 trains a day. By comparison, the Dillerville Yard is not an intermodal facility. It is approximately 50 acres in total size and handles 10 trains per day. By any reasonable standard, it simply is misleading to compare the impact of the Los Angeles facility with the new Dillerville Yard consolidation.
NS has said that despite the additional rail cars that can be handled by consolidating the Dillerville facility, no additional locomotives, trains or crews will be added as a result of this project. Therefore, we do not anticipate a significant overall increase in emissions, or risk of cancer.
Like all internal combustion engines, diesel engines produce emissions with particulates that decrease the quality of air in any given area. Gannett Fleming's environmental study will incorporate a conservative human health risk assessment (HHRA). Since Pennsylvania does not have existing regulatory guidance/risk assessment standards for rail yard air quality parameters, the California Environmental Protection Agency (CAEPA) risk assessment guidelines will be utilized as a reference guide for this risk assessment. However, the California baseline approach cannot be used because Pennsylvania does not have baseline data equivalent to the California Air Resources Board (CARB).
2. Light from the New Yard
NS's rail yard activity in Lancaster involves the daily arrival and departure of one train from Enola, limited local train traffic, and the coupling and decoupling of rail cars for market sorting. These activities occur at very regular intervals, and the yard is actually without rail activity for long periods of time each day. Given the hours of yard activity NS anticipates that, high intensity lighting will not be required during evening hours. Streetlight poles with standard "cobra head" lamps will be installed at switch locations and along the service drive from Harrisburg Avenue and adjacent to buildings in the new Yard for the safety of the NS employees. The impact from these streetlights will be minimal.
3. Pollution from the New Rail Yard
This project is remediating a former municipal dump by removing waste material that has been present for more than half a century. As a result, construction of the new Yard will effectively eliminate this potential pollution source. The new Yard will be designed to collect storm water and prevent it from permeating the groundwater, thereby preventing remaining ground water contaminants from being quickly flushed from the site.
In addition, NS operations at the Dillerville Yard do not and will not create the pollution that some opponents claim. For example, diesel fuel is delivered by trucks and transferred directly into its locomotives; diesel full is not stored in tanks and piping systems on site. In addition, NS does not operate electrified locomotives that are associated with the common contaminant, PCBs. Finally, rail yard operations today are much cleaner than earlier generations because of stricter environmental regulations and operational best practices.
4. Rail Safety and Hazardous Waste Shipments
NS is proud of its network-wide safety record and in particular the Dillerville Yard's safety performance. Personnel are vigilant about monitoring activity on their property and removing trespassers. For the past 18 years (1989-2006) Norfolk Southern has been awarded the E.H. Harriman Gold Award for Outstanding Safety Achievement in the U.S. rail industry. Norfolk Southern's Harrisburg Division, which includes operations in Lancaster, typically has been among the safest of the 11 divisions in the 22-state NS system.
By federal law NS must handle customer orders for all types of materials, including hazardous substances. To be clear, these types of materials are handled now on existing tracks in and out of the Dillerville Yard. In accordance with NS policy, rail cars with hazardous materials are not permitted to sit in a yard for longer than 48 hours before being delivered to customers. Moreover, the quantity of this type of material handled by NS over the past 25 years has declined significantly to the point where it is less than one percent of total shipments handled in the Yard. Indeed, hazardous materials account for less than three percent of shipments system-wide.
The hazardous materials of greatest concern are called "toxic inhalation hazards" (TIH). NS transports approximately 15 to 20 TIH car-loads per year (chlorine for treatment of a local water supply) and the amount is not predicted to increase as a result of this project.
In the unlikely event of a hazardous material release, NS personnel are trained to contact and assist local HAZMAT professionals in emergency response protocols.
5. Decreased Property Values & Diminished Quality of Life
The College and Lancaster General believe that property values will not be affected because rail operations exist today adjacent to the neighborhoods and will not be greatly increased. The College also holds a vested interest in minimizing any negative effects of this project. Many of its faculty members and staff live in this neighborhood. Also the College's Baker Campus/Brickyard property is located between the neighborhood and the new rail yard.