Circumstance or Product Guidelines

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This guide is designed as a quick reference describing some of the procedures followed by UPRR employees when coming in contact with circumstances or products which can be harmful to our environment if mishandled. These guidelines are merely a brief recap of UPRR's Environmental Policies and Procedures manual and are not to be considered "all encompassing."

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Absorbent Materials (Track Blankets, Diapers and pads)
Collect used absorbent material and place in leak proof container. Blankets can not have excess oil dripping from material. These wastes generally can be disposed of at a landfill. In addition to federal regulations, this waste is a "hazardous waste" in California and a "regulated waste" in Texas; in both states this waste will require special handling, manifesting and recordkeeping. Contact a Manager-Compliance Measurement in EMG. See Waste: Petroleum and Spills.

Aerosols
Obtain products in aerosol containers from Supply Department and follow label instructions before disposal in trash. Ensure container is emptied of product and propellent. In Oregon the container must be punctured.

Antifreeze
Drained antifreeze should be placed in clean containers for recycling and proper disposal. Do not mix with any other liquid or spill onto the ground. Provide container for storage of spent product. Work unit supervisor or manager is to arrange for recycling or disposal.

Asbestos
Contact EMG to perform an inspection before remodeling or demolition work begins. Training is required for employees who may contact Asbestos Containing Material (ACM) during custodial or maintenance work. ACM may be present in pipe or duct insulation, fireproofing, roofing material, floor tile, transite pipe or sheet goods, ceiling tiles, wallboards, plasters, and fire doors. Only state certified contractors are permitted to repair or remove ACM.

Asphalt Waste
Recycle asphalt waste through asphalt companies, if possible, or send to landfill. EMG is authorized to approve waste disposal/recycle facilities.

Batteries: Lantern, Flashlight & Small Batteries
Establish a collection point. If the volume of batteries does not warrant an individual collection point, local managers should establish and coordinate a central point and provide instructions to local employees. Generally these batteries can be discarded with normal industrial waste. However, in California, Lantern batteries are a Hazardous Waste and require special handling and manifesting.

Batteries: Lead Acid Batteries
Recycle by transporting to the Supply Department. Handling instructions are available in MOP 6-15 accessed through the PZ function in TCS.

Batteries: Radio Batteries
Spent rechargeable nicad batteries should be collected in a separate and labelled container then disposed of as a hazardous waste. See Waste: Hazardous.

Batteries: Signal Batteries
All spent alkaline signal batteries are considered to be Hazardous Waste. EMG has arranged for disposal by an approved Battery Disposal Contractor. Managers-Signal Maintenance must ensure signal batteries are disposed of properly; they have detailed instructions.

Cleaners & Solvents
Keep in clearly labeled containers, recycle when possible, do not pour into drains, onto ground or in a landfill. Certain cleaners and solvents may be hazardous, check label instructions. Review Material Safety Data Sheets (MSDS).

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Drums or Barrels
Reduce usage where possible. Must be clearly labeled, stored upright, slightly tilted, and tightly closed when not in use. When possible, return unopened, unused products to Supply department. If product is not known, it must be tested and disposed of properly. Do not use damaged drums. Empty drums should be de-headed, flattened and disposed of as scrap metal. Dispose through ongoing maintenance operations.

Dust
Use dust control when dust from operations impairs visibility or causes a nuisance to surrounding properties, especially when cleaning tracks, hauling fill and grinding rail. F

Filters (Fuel or Oil)
Collect material in a lined or leak-proof container. Allow oil to drain from filters for at least 24 hours. Dispose all waste oil properly. When appropriate, dispose of at a railroad waste water treatment plant or an approved waste oil facility. Drained filters made of metal, paper or cloth can be appropriately scrapped. In addition to federal regulations, this waste is a "hazardous waste" in California and a "regulated waste" in Texas; in both states this waste will require special handling, manifesting and record keeping. See Waste: Petroleum.

Fire Prevention & Inspections
UPRR facilities are governed by fire codes with local ranking fire marshal or chief having enforcement authority. Employees spotting fires should call 911 or summon local fire department or contact the train dispatcher with location. Train dispatcher will summon appropriate fire department. Establish working relationship with all local fire prevention agents on territory. Local managers will arrange for fire equipment maintenance and for routine inspections. EMG will arrange for and manage annual facility fire safety inspections.

Floor Dry
Collect used product and place in leak-proof container. Type of disposal, whether hazardous or non-hazardous, is based on what the floor dry was used to clean up. See Waste: Hazardous or Non Hazardous. In addition to federal regulations, this waste is a "hazardous waste" in California and a "regulated waste" in Texas; in both states this waste will require special handling, manifesting and record keeping. See Waste: Petroleum and Oily Soil.

Freon
Intentional venting of freon into the atmosphere is a violation of the law. This is true under all circumstances, whether maintaining in-use equipment, or retiring freon-containing equipment prior to scrapping or disposal. Work unit manager must acquire recovery equipment and training or use licensed contractor. EMG will provide information covering certified freon-recovery equipment and availability.

Fueling & Fueling Stations
Take extra precautions during fueling activities. Report all fuel spills to Harriman Dispatching Center if any amount contacts the ground or enters a water way or storm drain. Immediately clean up spills by removing contaminated soil, placing on plastic, and/or disposing at landfill. Contact HazMat Special Agent, Manager Chemical Transportation Safety, or EMG for disposal options. Keep drip pans and sewer systems clean. Dispose of contaminated sand and other pan waste. Repair leaking components. Routinely inspect sites for evidence of previous spills and then clean up. See Oily Soil.

Gasoline
Surplus or wastes must be placed in leak-proof containers, be properly labeled, and disposed of as hazardous waste. DO NOT dispose at waste water treatment plant or in waste oil tanks. See Waste: Hazardous.

Herbicides
See Pesticides I

Inspections by Government Regulators
Contact EMG prior to inspection. Conduct inspections with authorized government agency field personnel. Require proper identification. Have knowledgeable personnel accompany the inspector. Only communicate information that is required for the inspection. Allow access to and copying of pertinent records. Local UPRR personnel must take same samples as regulator and cooperatively obtain copies of photographs taken, notes, and copy of the regulator's inspection report. Provide information to EMG.

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Light Bulbs
See Waste: Non Hazardous

Lube Oils

See Waste: Petroleum and Spills

Oily Soil
Soil contaminated with petroleum products (diesel, lube oil, gasoline, etc) must be disposed of or treated in an approved manner. Options include Recycling, Landfilling, Bioremediation and other technologies. EMG will approve treatment or disposal facilities In addition to federal regulations, this waste is a "hazardous waste" in California and a "regulated waste" in Texas; in both states this waste will require special handling, manifesting and record keeping. Contact a Manager-Compliance Measurement in EMG. See Waste: Petroleum and Spills.

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Paints
Oil based paint wastes must be handled as hazardous wastes (see Waste: Hazardous). However, if there is less than 1 inch of dry residue in the container, it may be sent to a landfill. Water based paints are non-hazardous. See Waste: Non Hazardous.

Pesticides
It can be a violation of the law to not use pesticides according to its label.

Restricted-Use:
Persons who buy or use restricted-use pesticides (herbicides and insecticides) must be certified and competent applicators or must be directly supervised by a certified applicator.
Nonrestricted-Use:
When UPRR personnel apply pesticides, only approved materials (i.e., aerosols, bug sprays, etc.) obtained through the Supply department will be used. Engineering Services will support contractors' movement while applying herbicides along right of way, manages vegetation control along UPRR right of way.

Smoke from Locomotives
Report excessively smoking locomotives to the Train Dispatcher. Train Dispatcher to provide information to a manager at the Locomotive desk in the Harriman Dispatching Center. Locomotive Manager is to refer the locomotive for maintenance at next scheduled shopping and advise EMG. EMG to report to regulatory agency, if necessary.

Spills & Leaks (From Freight Cars)
To prevent contamination of UPRR property, all employees should observe freight cars for any leaking product. Car number and position in train should be noted to the Yard Master or a Manager in the Transportation Department. Managers should take action to prevent additional leakage and identify shipper. Containment and clean up action should be implemented. All outlet gates, covers, etc., should be closed at all times (on empty cars as well as full.)

Spills & Leaks (Fuel Oil)

Common Causes of Leaks or Spills:
Derailments, collisions, objects from the track puncturing the tank or fuel line, tank or fuel system failure, etc.
First Response:
Without endangering personal safety, first responders should control, contain and report the spill or leak.
Containment:
If the fuel tank is not completely empty and continues to leak, an attempt should be made to plug the hole with rags, wood, or other material . If pooling of fuel occurs an attempt should be made to construct a dam with soil or other materials to prevent spread of the fuel.
Reporting:
Spills and leaks must be reported to the Harriman Dispatching Center immediately.
Clean Up:
Clean up should be implemented immediately by the first responders. When practicable, soil should be removed and stockpiled on thick plastic liner or placed in drums. When help arrives, further attempts should be made to accomplish these steps. Final clean up should be coordinated with the Chemical Transportation Safety Group or EMG.

Storm Water Pollution Prevention
Storm Water permits are required at facilities where equipment is maintained and related materials are stored. A Storm Water Pollution Prevention Plan (SWPPP) must be implemented and managed locally by a SWPPP Team. All employees at the facility must follow "Best Management Practices" and "Good Housekeeping Practices," acquire training, and contact their supervisor for guidance. EMG will obtain permits, develop SWPPPs, and train SWPPP team members.

To assist employees at facilities with a SWPPP all drains and covers will be color-coded and identified. The scheme will be as follows: Blue - non contaminated storm water routed to outfall; Yellow - oily process water routed to waste water treatment plant; Brown - sanitary sewage routed to local sewer system; Green - potable water supply; Red - electrical or communication utility.

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Tanks: Above Ground
Tanks with over 660 gallons of petroleum product stored must have secondary containment and Spill Prevention Control and Countermeasures plan (SPCC) posted near the tank. The person designated in the SPCC plan will train employees. Facilities with over 1,000,000 gallons of storage capacity may require additional emergency response plans and containment. Contact EMG for advice. Some states require permits for fuel storage tanks. Contact EMG for permitting requirements. Evidence of tank leakage and overflow should be reported to the designated person. Retire tanks that are not needed.

Tanks: Underground
Report all underground tanks found on UPRR property to EMG; provide location, description and contents, if known. Local manager should implement inventory controls, maintenance practices, record keeping, and arrange for upgrades for tanks that are to remain. EMG will provide and manage removal of unnecessary or outmoded USTs.

Ties (Spent)
Spent ties can be disposed of by gathering, sorting and loading onto company material gondola cars. Ties should be loaded as tight as possible and below the top of the car. They are to be billed to a designated end user, instructions may be obtained from EMG. The end users will accept wood material only; any debris should be properly disposed of. To arrange for sale or contract removal of used ties, contact Supply department or Contract Services in the Operating Department in Omaha. Generally the ties that are picked up by a contractor cannot be sold by UPRR, they belong to the contractor.

Tires
Do not send to landfill. Return tires to distributor for recycling. Tires are a hazardous waste in Louisiana.

Transformers
Store transformers upright on pallets or totes and protect from rain with cover. Transformers must be tested for PCBs and labeled accordingly prior to disposal; tests kits are available from Manager - Electrical Maintenance. PCB transformers must be properly labeled and inspected periodically. Transformers not tested must be considered PCB contaminated. Spills must be reported to EMG. Provide inventory of disposal and replacement of all to Manager - Electrical Maintenance and maintain required records.

Washing Equipment
Care should be taken to prevent any contaminated wash water from contacting the ground. To collect residue, absorbent materials should be used under the equipment being cleaned. The absorbent materials will capture grit and oily particles. In addition to federal regulations, this waste is a "hazardous waste" in California and a "regulated waste" in Texas; in both states this waste will require special handling, manifesting and record keeping. Whenever practicable, refrain from using soaps. High pressure wash water is recommended. Local managers should be aware of facility's Storm Water Pollution Prevention Plan when determining site to wash equipment. EMG will advise and support work unit personnel regarding methods and sites where equipment should be washed.

Waste Garbage Dumping on RR Property by Unknown Sources

Note location as accurately as possible.
Note general type of debris; industrial waste, drums, batteries, household garbage, etc.
Contact local special agent, convey above info. Agent will examine material and attempt to locate source of material.

If material appears to be normal waste arrange for cleanup and disposal by contacting Manager Track Maintenance. If waste material consists of batteries, drums or other environmentally sensitive material, EMG will assist by providing disposal options.

Waste: Hazardous
A waste is considered hazardous if it is ignitable, corrosive, reactive (explosive) or toxic (poisonous). An unidentified waste is considered hazardous until test results show otherwise. Any material or waste mixed with a hazardous waste will also become a hazardous waste. Significant requirements for the disposition of hazardous waste include: keeping records, using appropriate shipping containers, labeling and storing containers, manifesting shipments, and training employees to handle and dispose of wastes. Generators will dispose of Hazardous Waste from operations, maintain manifests and disposal records. Hazardous Waste must be disposed of within 90 days. EMG must approve all hazardous waste disposal facilities and complete annual EPA reporting.

Waste: Non-Characterized
Determine appearance and whether the substance is a soil, concrete, gravel, liquid (is it like water? oil? grease? clear? milky? etc.) or solid. Abandoned containers containing a material should not be disposed of or recycled without testing or proper verification of content. Personnel should contact trained and qualified personnel for guidance or EMG for assistance in characterizing waste prior to disposal. EMG will provide advice concerning testing, handling and disposal.

Waste: Non-Hazardous
The materials (e.g., crossties, soil, cardboard, concrete rubble, etc.) must be characterized as non hazardous by landfill operator or recycler prior to disposal. Any receipts, trip tickets, inventory lists, etc., provided by the landfill operator should be retained by work unit manager.

Waste: Petroleum (Oil & Grease)

Put into properly labeled, non-leaking or lined containers. Contact EMG for advice on appropriate disposal or recycling. If available, dispose at waste oil tanks at UPRR wastewater treatment facility. Some local gas/service stations or a local oil recycler can be an authorized collection location. Each work unit must arrange for proper disposal of used oil from on going operations. EMG will authorize approved waste disposal/recycle facilities. In addition to federal regulations, waste oil is considered to be a hazardous waste in California and Missouri. It is a regulated waste in Texas. In all three states this waste will require special handling, manifesting and record keeping. See Waste: Hazardous.

Waste: Track Cleaner
Type of disposal, whether hazardous or non-hazardous, is based on what kind of materials have been cleaned up. See Waste Hazardous or Waste Non-Hazardous and Dust. Engineering Services will arrange for proper disposal of track cleaner wastes and provide schedule of track cleaning projects to EMG & Work unit managers. EMG will arrange to have wastes characterized and disposal plan developed.

Waste Minimization
Local Safety, Health and Environment committees or functional task teams have been asked to identify ways to prevent and minimize wastes. Each Waste Minimization Pollution prevention team will develop and implement pollution prevention processes aimed to reduce, recycle or reuse waste in their work area. Waste Minimization programs must be developed and implemented at large quantity generator locations or other state regulated sites.

Waste Water Treatment Operations
Industrial waste waters from maintenance operations are collected, treated and discharged through UPRR plants. Most facilities are designed to only treat oily waste water. Plants are NOT designed or intended for disposal of paints, cleaners, solvents, gasoline, other hazardous wastes or wash water from car washing operations. Local personnel should minimize quantity of waste water and waste oils discharged to the industrial sewers. EMG will operate plants to ensure compliance with discharge permits.

Water Well Protection
Water wells should be decommissioned according to state laws if not in Use. Real Estate department must be notified about all new or operational wells. Wells owned by UPRR that supply drinking water must be tested on a regular basis to verify that it is acceptable to the consumers. Work unit personnel who find wells not in use should advise Real Estate or EMG and provide location of the well. Wells should be properly maintained and test arranged. EMG will manage well abandonments and well inventory.

Wetlands
Areas inundated or saturated by surface or ground water but able to support vegetation are considered to be wetlands. Contact EMG for appropriate agencies and permitting requirements prior to beginning any construction work on wetlands.

Wire
See Waste: Non Hazardous

Wood Preservatives
All preservatives should be stored in closed, upright and properly labeled containers. Any unused or spent product should be sent to the supply department for proper disposal.

Creosote and 50/50 mix is no longer used for field application purposes.

Copper Naphthenate cannot be landfilled or dumped on the ground. Spills must be cleaned up. This product is no longer used on UPRR property. Contact Supply Department or EMG for disposal options.

Environmental Management

Circumstance or Product Guidelines