Committed to Environmental Protection
Norfolk Southern has internal controls and procedures in place to ensure that we meet or exceed environmental regulations that apply to the company and its operating facilities. The company complies with an array of federal environmental statutes and programs delegated to state and local governments. Among relevant laws and regulations are the Clean Water Act, the Clean Air Act, the Oil Pollution Control Act, and the Resource Conservation and Recovery Act.
The railroad’s formal corporate environmental policies and procedures follow industry best-management practices. To ensure programs are robust and up-to-date, we regularly compare our efforts with those of other Class I railroads and Fortune 500 companies.
Employees charged with administering and managing environmental policies are an integral part of the railroad’s Operations Division, working alongside operations employees across the system to ensure facilities are functioning in accordance with applicable permits, rules, and environmental laws. The decision to integrate the company’s Safety and Environmental Department into operations reflects our belief that adhering to safety and environmental policies is essential to the railroad’s business success.
Ultimately, Norfolk Southern believes that each employee is responsible for safety and environmental compliance. All employees have access to the company’s environmental management program on a corporate intranet site.
Dedicated Staff Leads Performance
Norfolk Southern’s environmental protection group, headed by a system director, administers the railroad’s environmental management program. The group, part of the Safety and Environmental Department, is divided into subgroups that focus on environmental operations, environmental engineering, remediation, compliance, and hazardous materials.
Environmental operations: Field personnel in this group provide “boots on the ground” to help implement environmental compliance programs. In addition to providing guidance to operating departments on compliance issues, they offer 24/7 emergency preparedness and response to spills and releases. The group manages approximately 80 wastewater-treatment facilities and provides field management of solid and hazardous waste programs.
Environmental engineering: This group manages design and construction of pollution-control equipment to ensure that infrastructure such as wastewater-treatment plants and secondary containment structures meet or exceed applicable environmental regulations. The group also helps monitor performance of these facilities with an eye toward upgrades or new construction needed to ensure compliance as requirements evolve and become more stringent.
Environmental remediation: This group is responsible for ensuring that environmentally impacted company-owned properties are remediated in the most practical and expedient manner, coordinating most projects with state regulatory agencies under voluntary programs. Along with a team of environmental attorneys and accountants, this team tracks, estimates, discloses, and reports on corporate environmental liabilities associated with environmentally impacted company-owned properties.
Environmental compliance: This group is responsible for monitoring and managing the company’s compliance with various air and water permits and plans. Among other things, employees on the team conduct regular environmental audits of operating facilities and other properties, and design, develop, and distribute environmental awareness and employee training programs.
Hazardous materials: This group manages risks associated with rail transport of hazardous materials. The group ensures compliance with Federal Railroad Administration and U.S. Pipeline and Hazardous Materials Safety Administration regulations regarding hazmat transport, including designing and administering training programs for employees, industry members, and first responders. The group also prepares security and High Threat Urban Area plans, audits customer facilities that pose potential safety risks to railroad employees, and helps train approximately 5,000 emergency responders annually in communities we serve to enhance emergency preparedness and response capabilities in the event of a rail hazmat incident.
Investments for environmental protection
Norfolk Southern makes significant investments in environmental protection initiatives to minimize the impacts of business operations and to ensure compliance with environmental laws. In 2013, the company invested $7.8 million in environmental capital projects such as wastewater-treatment plant upgrades, aboveground storage tank dike liners, tank-car spill pans, and other improvements to enhance environmental performance. In addition, the company spent more than $20.8 million to support environmental compliance initiatives and remediation activities.
Self-policing and outside inspections
Norfolk Southern’s policy is to ensure that facilities and operations comply with applicable environmental laws and regulations. We routinely perform self-audits on operations to ensure compliance and to identify and resolve potential compliance issues.
Federal, state, and municipal agencies inspect company facilities on an ongoing basis. In 2013, environmental regulatory agencies conducted 43 inspections at Norfolk Southern facilities. On occasion, inspectors for those agencies note exceptions that can result in fines. In May, the Altoona Water Authority issued a notice of violation involving a wastewater pretreatment system at the Juniata Locomotive Shop in Altoona, Pa. The AWA alleged that the wastewater system in late 2012 and early 2013 had violated new metal effluent permit limits issued by the authority. The corporation’s Norfolk Southern Railway Company subsidiary entered into a settlement agreement with AWA and paid a penalty of $11,000 to resolve the alleged violations.
State-of-the-art discharge treatment
Systemwide, we have 166 water discharge permits that govern the quality of our water discharges and protect the environment. Typical water discharges from railroad facilities include treated washwater, water from repair and maintenance operations, sanitary water, and stormwater.
The company continues to upgrade and install state-of-the art wastewater treatment systems to ensure that we meet or exceed wastewater discharge standards applicable to our operations.
Restoring a property to productive use
Norfolk Southern earned recognition in 2013 for a project in Loudon County, Tenn., to restore a 100-acre “brownfield” property to productive use. The Loudon County Economic Development Agency presented Norfolk Southern with its 2013 Economic and Environmental Sustainability Award for our project to remediate a property that previously had housed a railcar manufacturing facility.
During the two-year project, Norfolk Southern has worked cooperatively with the Tennessee Department of Environment and Conservation’s Division of Remediation to address the environmental concerns associated with foundry slag on the property.
With guidance from the state agency, Norfolk Southern developed a strategy that will make around 80 acres available for future industrial development. The project is scheduled for completion in mid-2014. Employees with Norfolk Southern’s industrial development group are marketing the property to potential rail-served customers in coordination with state and county economic development officials.
From 1893 to 1985, foundries, machine shops, and, later, Lenoir Car Works, used the site to manufacture railroad freight cars and components. The car works operations produced metal slag and foundry sand that contained trace amounts of lead and arsenic. It once was acceptable practice to use slag and sand to fill in low-lying sections of the property. Current state environmental laws require that these materials be safely managed and contained.
Southern Railway, a Norfolk Southern predecessor railroad, bought the property and operations in the 1920s. The site now is owned by Southern Regional Industrial Realty, Inc., a Norfolk Southern subsidiary. Norfolk Southern hired an environmental contractor to perform the cleanup in compliance with state-approved plans and has paid all the costs.