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A Comprehensive Environmental Management Program with Regulatory Oversight for the Alameda Corridor Transportation Project
   

By Carl Peter Ripaldi, REA II
URS Corporation,
Los Angeles, Calif.

Background:

The Alameda Corridor Transportation Project (ACTP) is a consolidated railroad link between the Ports of Los Angeles and Long Beach (the Ports) and the regional and national rail systems linking the nation.  The ACTP is a 32 kilometer (20 mile) rail corridor, centered along Alameda Street, extending from downtown Los Angeles to the Ports, constructed with the intended purpose of providing express freight rail service to the Ports.  Such service is currently being provided by the Union Pacific/Southern Pacific (UP/SP) and Burlington Northern Santa Fe Corporation (BNSF) railroads.  The ACTP has been in development for over 14 years.  In 1985 an Alameda Corridor Task Force was formed which in turn led to the creation of a joint powers organization called the Alameda Corridor Transportation Authority (ACTA) in 1989.  A joint Environmental Impacts Report/ Environmental Impact Statement (EIR/EIS) was prepared for the project.  The Final EIS was issued in February 1996, and a record of decision was issued in May, 1996.

The initial design work and EIS/EIR preparation commenced in 1991.  A program management contract for work on the Alameda Corridor was issued to a joint venture team of four firms in the Los Angeles area. The Alameda Corridor Engineering Team (ACET) is a joint venture of these four engineering companies providing design engineering, environmental compliance, and construction management services for the project.

Need for the Project

The Ports together form the third largest port complex in the world, and the two largest in the United States.  Today, 25% of all U.S. waterborne international trade passes through the Ports of Long Beach and Los Angeles before reaching its markets.  This represents more than $116 billion in trade each year.  With the expansion of the Pacific Rim marketplace, this trade is anticipated to double by the year 2010.  Where currently  approximately 34 trains a day traverse the Alameda Corridor carrying goods to and from the ports, over 100 trains per day are anticipated by the year 2010.  This would result in massive traffic jams and gridlock along the entire 20 mile length of the Corridor if no improvements were constructed.

The Alameda Corridor will dramatically improve railroad and highway access to the Ports by consolidating over 90 miles of rail with 200 at-grade roadway crossings into a single, 20-mile high-capacity and fully grade separated rail corridor linking the Ports with the national railroad system originating near downtown Los Angeles.  The project will also widen and improve the truck route paralleling the rail facility to expedite truck traffic.  The Alameda Corridor will also mitigate the adverse impacts of additional growth including highway traffic congestion, air pollution, vehicle delays at grade crossings, and noise in residential areas.

From a national perspective, the Alameda Corridor provides the efficient and cost-effective transportation capacity necessary for the United State to capitalize on the economic growth of the Pacific Rim.  The cost of the Alameda Corridor is currently estimated at $2.43 billion.

Commencement of rail service along the Alameda Corridor is on schedule for April 2002.

History:

Trains have traveled along Alameda Street between downtown Los Angeles and the Ports for over 130 years.  Phineas Banning developed the first wharf in the San Pedro Harbor in 1854.  He soon realized that if he wanted to generate trade through his wharf that he needed to provide direct rail service.  In 1869, Banning completed the first railroad line along Alameda Street linking the Port with downtown Los Angeles.  Commerce developed and flourished in the Ports as the Los Angeles area grew.

In 1871, Congress appropriated funds to create a deep harbor in San Pedro Bay.  Southern Pacific Railroad gained ownership of the railroad lines in 1872.  In future years substantial development of the Ports spurned on economic development along Alameda Street forming an industrial corridor along its entire length.

The discovery of oil along the southern end of the Corridor spurned on the development of refineries and petrochemical plants in the areas just south of the present location of the San Diego freeway.

Design of the Corridor:

The Alameda Corridor Transportation Project is divided into three segments: the North End, Mid-Corridor Trench Section, and South End.  A description of the projects and contamination issues associated with each of these sections follows.

The North End:

The design of the North End includes railroad improvements and grade separations which will speed up the flow of railroad traffic and motor vehicle traffic through a heavily industrialized and congested section of Los Angeles just south of the Santa Monica Freeway (I-10).  The North End encompasses an area of approximately one square mile of industrial development.  In this area trains heading north along Alameda Street connect with the transcontinental lines of the UP/SP and BNSF railroads as well as commuter rail traffic from Amtrak and Metrolink trains.  There are 10 projects located within this North Area of the Corridor.  Completion of the construction work involves the acquisition of over 100 parcels of land for the construction of utility relocations, street improvements, and grade separations involving at-grade, below grade and elevated rail and roadway structures.  This includes parcels of contaminated industrial properties including rail yards, asphalt manufacturing facilities, former air conditioning manufacturing sites, foundries, and metals recycling facilities.

The Mid-Corridor Trench Section:

As the railway exits the “J-Yard” rail yards south of 25th Street it enters the Mid-Corridor Trench Section which continues for approximately 10 miles south to the Artesia Freeway (I-91).  In this section of the Corridor ACTA’s right of way varies from 30 to 100 feet in width.

The Mid-Corridor Trench is being constructed the entire length of this section with a width of approximately 50 feet and a depth of 33 feet.  Along the northernmost section of the trench, its configuration will be nearly that of a tunnel for more than a mile due to the narrowness of the right of way through this portion of Alameda St.  The trench accommodates two sets of railroad tracks and a service road with the possibility of accommodating a third set of tracks in the future.  The construction of the trench eliminates forty at-grade railroad crossings on which traffic is disrupted constantly during the day by trains heading north and south along the Corridor.  The trench is being constructed under a design/build contract awarded toTutor Saliba Corporation in October 1998.

Groundbreaking for the Mid-Corridor Trench occurred in December 1998.  The projected cost for this portion of the project is $750 million. At this time approximately 70 per cent of the trench section has been completed.  Environmental remediation efforts along this section of the corridor have entailed the removal and disposal of over 1 million tons of hazardous waste.  Hazardous levels of lead and arsenic were found in the upper two feet of soils along the entire length of this section.

Major petroleum pipelines and other utilities run parallel to or traverse the trench in this section and were relocated under agreements with the oil and oil-transport companies and the various utilities. Two significant plumes of fuel hydrocarbon contamination were encountered in this portion of the Corridor.  Volatile hydrocarbon contaminated soils associated with petroleum pipeline leaks cost several millions of dollars to clean-up.  Millions of gallons of groundwater generated during dewatering operations, with elevated levels of naturally occurring metals and salt contamination have had to be treated before discharge due to the discharge limitations imposed by the California Regional Water Quality Control Board (RWQCB).   This posed significant potential delays and major costs to the project.  Negotiations with the RWQCB resulted in a compromise requiring ACTA to treat the waters with chelating agents while conducting significant research and reporting results to a Committee of water quality scientists.

The South End:

South of the Artesia Freeway, the Alameda Corridor rises out of the trench to cross over Compton Creek and continues south through the Refinery Section. South of Carson, the Corridor continues to Henry Ford Avenue where it enters the Ports.  Construction work along the South End of the Alameda Corridor involves new bridges, grade separations, track construction and civil work.  In addition there are several other projects that are being carried out by the Ports.  These Port Access Demonstration Projects are being completed in a coordinated effort with the construction of the Alameda Corridor.  The South End of the Corridor is heavily industrialized with major refineries and petro-chemical plants bordering the rights- of-way. Here the at-grade tracks impact several refineries: Huntway, Texaco, TOPCO, TOSCO, Ultramar, and Wilmington.   The Long Beach Lead area contains many auto wrecking yards and other heavy industrial sites that will require significant clean-up efforts.

Environmental Management Program:

Environmental Investigations and Remediation:

Virtually all properties involved in the project required environmental assessments and site investigations.  This included over twenty miles of railroad rights of way and the acquisition of over 400 individual parcels.  The environmental investigations are a necessary precursor to the purchase of properties utilizing state and federal funds, so that all environmental liabilities have been identified and factored into the property transactions before the transactions are finalized.  Following the investigative stages, remediation efforts were completed on twenty miles of railroad rights of way and approximately 25% of the acquired parcels.  As previously mentioned the project has cleaned up over 1 million tons of hazardous waste and treated many millions of gallons of contaminated groundwater.

In order to accomplish this enormous task, ACTA established “on-call” contracts with two environmental engineering firms and four “on-call” environmental remediation services contractors. The contracts were competitively bid and negotiated to include unit prices and baseline schedules for all anticipated services.  In this manner, investigations for packages of various parcels could be awarded knowing the anticipated costs and necessary time to complete the investigations. Work was assigned geographically with parity in the value of the work assigned to each contractor.  The engineering firms completed Phase I and Phase II environmental assessments, workplans for remediation efforts, remediation oversight, and miscellaneous environmental investigations.  The “on-call” remediation services contractors completed lead-based paint removal, bridge demolition, asbestos removal, contaminated soils removal, contaminated groundwater removal, responded to field emergencies due to accidental spills or encounters with undisclosed environmental contamination, transport and disposal of hazardous waste.

Regulatory Issues:

Various regulatory agencies preside over the environmental aspects of the project. These include: The Federal Environmental Protection Agency (EPA), The California Department of Toxic Substances Control (DTSC), The California Regional Water Quality Control Board (RWQCB), the South Coast Air Quality Control District (AQMD), The Army Corps of Engineers ACOE), the County Hazardous Materials Management Division of the Fire Department (HMMD) and local Fire Departments and city agencies.

All environmental investigations, construction activities, and remediation efforts must comply with a myriad of regulations and are subject to the approvals and oversight by these agencies.  As a result, there was a high probability of schedule disruptions to comply with individual agency requirements.  In order to avoid such a set of circumstances and streamline the process, ACTA developed a set of guideline documents to direct all environmental work on the project, and sought a “lead agency” role amongst the various regulatory agencies.  The content of the guideline documents was agreed to by ACTA’s environmental committee consisting of representatives of the two Ports.  Once scopes were agreed to, the following guideline documents were prepared to cover:

  • The Mitigation Monitoring Program required under the Environmental Impact Statement and Report fulfilling NEPA and CEQA requirements
  • A Master Health and Safety Plan
  • A Master Quality Assurance/Quality Control Plan and Field QA/QC Plan
  • The Site Mitigation Master Plan
  • Chemical Release Reporting Guidelines and Chemical Release Reporting Field Manual.
  • List of Approved Landfill and Disposal Sites

Mitigation Monitoring Program:

This document compiled more than 60 mitigation measures required under Federal (NEPA) and State (CEQA) law as a condition for the approval of the project. The mitigation measures included such varied items as compliance with seismic design requirements, school crossing measures, dust control measures, notifications to affected businesses, etc.  A significant portion of the mitigation monitoring has involved archeological monitoring, paleontological and native american monitoring along the twenty miles of ACTA’s railroad rights of way.  Numerous Native American burial sites were encountered during excavation activities, necessitating special services and reporting. The mitigation measures apply to the design, construction and operational phases of the project.

Master Health and Safety Plan:

The Master Health and Safety plan addressed general health and safety issues for environmental contractors, but focused on emergency spill issues, chemical exposures and other environmentally related matters associated with the types of contaminants known to be present within the corridor. This plan was supplemented with individual site specific Health and Safety Plans prepared by the individual contractors awarded particular construction projects.

Master Quality Assurance/Quality Control Plan:

This plan presented standard procedures for field investigations, sampling, analytical work and even the formatting of reports, so that they would have a standard format.  The QA/QC plan was based on standards readily acceptable to the various regulatory agencies involved in the project.  Many of the procedures included were approved by the Federal EPA, the American Society of Tests and Measurements (ASTM) and State of California agencies.  All contractors were required to comply with these procedures.

The Site Mitigation Master Plan:

This document presented a comprehensive plan for all site remediation activities to be carried out in the project.  It addressed all regulatory compliance issues, the establishment of clean up criteria, hazardous waste characterization policies and procedures, sampling procedures, disposal procedures, hazardous waste storage requirements, soil re-use options, soil treatment options, risk assessments, transportation and disposal requirements.  The RWQCB reviewed this plan and approved it, authorizing ACTA to proceed with all site remediation activities through a self-directed effort; an authorization seldom granted by a regulatory agency.  This authorization has had a substantial beneficial impact on the costs and schedule for remediation activities in the project.  ACTA completes all investigations and clean ups under the plan and provides individual reports on each parcel and construction project to the RWQCB.  The RWQCB reviews the reports for compliance with the plan and issues closure letters on the parcels. 

Chemical Release Reporting Guidelines:

These guidelines are issued to each contractor at the time of award to provide them with guidance on what to do if they cause or encounter an emergency hazardous waste spill during construction.  These guidelines are “cookbook” in nature.  They clearly spell out procedures and chains of command should an emergency spill occur.

List of Approved Transport, Storage and Disposal Facilities (TSDFs):

There are lingering liabilities for hazardous waste generators associated with the disposal of hazardous waste.  Also there are substantial differences in the costs to transport and dispose of hazardous waste. In order to control the ultimate costs of transport and disposal and the final placement of hazardous wastes, ACTA developed a list of approved TSDF facilities.  All permits and certifications held by each facility were reviewed and approved by ACTA’s risk management firm.  Preferred rates for transport and disposal were negotiated with each facility. A 5% mark-up was allowed for each contractor.  This speeded up the removal and disposal of wastes once they were correctly identified and saved the project many millions of dollars.

In addition to these guideline documents ACTA maintains a status report of the more than 400  acquired properties on which environmental assessments, investigations and remediation have been completed.  This status report is updated every two weeks to assure that an accurate status of each parcel investigation is presented to management. 

A log of all hazardous waste activity is also kept.  It contains the manifest number of each shipment, characterization of the waste, tonnage, the transporter, and the receiving TSDF.  This is maintained in a data base so that it can be sorted as necessary to locate any shipment of waste from the project.  ACTA is required to keep this data base for three years after the project is completed.

Staffing:

A relatively small staff handled the management and implementation of environmental requirements for the project. All work was directed by Carl Peter Ripaldi, Environmental Manager for the Alameda Corridor Transportation Project.  There are three Environmental Engineers on the staff each assigned to a geographic area of the project; the North End, Mid-Corridor Trench, and South End.  They oversee all site investigations and clean up activities carried out by ACTA’s “on- call” environmental engineering and remediation contractors.  The team also includes a Mitigation Manager responsible for compliance with NEPA and CEQA requirements.  An Administrative Assistant handles all correspondence with the regulatory agencies, maintenance of a huge library of environmental reports, the bi-weekly parcel status report and the log of hazardous waste activity.  In addition, consultant staff support has been obtained through the “on-call” environmental engineering services contracts on an “as-needed” basis when the work load gets too heavy on a particular part of the project.

Lead Agency Agreement:

Under the Porter–Cologne Water Quality Control Act in California, a business or agency can elect a “lead environmental agency” to handle all environmental compliance requirements rather than having to deal with several different agencies.  The Act allows the agency to enter into an agreement for professional services that are reimbursed.  A “lead agency” agreement was entered into with the RWQCB in 1999 to enable them to oversee all environmental remediation activities for ACTA.  Under this agreement ACTA pays the RWQCB for staff support dedicated to the project effort.  ACTA provides the RWQCB with status and copies of all assessments, site investigations, and remediation activities.  ACTA completes all the work under the approved guideline documents and SMMP.  The RWQCB assigns dedicated staff to the review of ACTA’s submittals, coordination of site activities, establishment of sampling requirements, expedite necessary soil and groundwater investigations, coordination of necessary health risk assessments and the establishment of risk based clean up goals.  The RWQCB issues closure letters and “comfort letters” on the parcels once all work is completed.  In this manner ACTA avoids involvement of other regulatory agencies having jurisdiction over ACTA’s environmental activities.  The arrangement has allowed for maximum flexibility in the application of regulatory requirements.  The project has benefited tremendously without any significant time losses due to environmental compliance. 

Other Regulatory Agency Involvement:

Other regulatory agencies involved in the project included the State of California Department of Toxic Substances Control (DTSC), the Los Angeles County Fire Department Health and Hazardous Materials Division (HHMD), the City of Los Angeles Fire Department (LAFD).  The roles of these agencies were as follows:

The DTSC was mainly involved in the oversight of the investigation and remediation of:

  • A 22 acre property being acquired by ACTA that belonged to the State of California. They were also involved in oversight of remediations work completed at a TSDF being acquired by ACTA that held DTSC permits for the handling and processing of hazardous waste.
  • The HMMD has jurisdiction over several railroad properties purchased by ACTA from the BNSF railroad.
  • The LAFD had jurisdiction over the removal of underground storage tanks and the associated remediation activities on nine properties purchased by ACTA.

Summary:

ACTA has been successful in handling complex regulatory negotiations, environmental investigations and remediation during the course of construction of this $2.6 billion dollar mega-project.  Early development of environmental guideline documents, contracting for on-call engineering and remediation services, establishment of contract unit prices for investigations, remediation, transport and disposal services, coupled with the establishment of a lead agency agreement have all contributed to the success of the program.  The structure and management of the environmental program has been comprehensive and anticipated the various needs to successfully complete the construction of the ACTP without schedule delays. The success of this program demonstrates how careful planning, effective communications, comprehensive management, representative participation and skilled negotiations all contribute to an effective environmental management program for a mega-project.

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