CTEH^®’s remediation services are under the direction of Mr. Mike Feamster, PE. Mr. Feamster is a professional engineer with over 20 years of experience. 18 years in environmental consulting, spill response, and remediation. He is experienced in geotechnical and environmental engineering and project and personnel management. He has been responsible for numerous large-scale site investigations and construction projects and has managed numerous spill response and abatement projects involving various chemicals and significant petroleum releases. His experience in environmental regulatory compliance includes the States of: Kentucky, Tennessee, North Carolina, Ohio, Florida, Georgia, Alabama, Indiana, Illinois and Michigan, interacting with Superfund, Emergency Response, and Waste Management regulatory personnel. He has prepared and supervised the preparation of numerous environmental assessment reports, corrective action plans, and remedial designs. In responding to our clients' requests and their changing needs, CTEH^® continues to add new personnel and programs providing value-added services outside the scope of most consultants. Our environmental group is one such program. With the addition of several experienced environmental professionals, CTEH^® has been able to provide rapid deployment of senior level environmental staff experienced with chemical emergencies, regulatory coordination, and technical support. This group additionally handles several environmental & liability management programs including third party access to railroad property for environmental issues and a program to perform environmental audits on properties leased from our railroad clients. Please read the following sections for more information about these programs.

Railroad Environmental Access Program (REAP)

Every major railroad operates track and facilities in industrial areas, bordering properties with serious environmental issues. In a large number of cases these properties have environmental impacts which have spread to railroad property. The Railroad Environmental Access Program (REAP) was designed specifically to protect the railroad’s interests by reducing exposure to these events while the cost is offset in fee recovery from licensees. This program is currently in successful operation with two major rail clients and is consistently reducing their exposure to liability while protecting their property.

This program operates by closely regulating and monitoring the outside parties that inevitably need to come onto your property to conduct environmental assessment or remediation. The program establishes a licensing procedure, tailored to your specific needs, allowing outside parties access to the property under specific guidelines and with the payment of application and annual fees designed to recover your cost in administering the program. CTEH® will establish an application procedure, review applications for legitimacy, need, and safety. We will coordinate with your engineering department or other internal railroad groups for additional reviews, as appropriate, to ensure that activities proposed by applicants do not interfere with the safe and timely operation of the railroad.

In approving an application for access to the property, a formal agreement is established which includes language requiring that the licensee have and document the appropriate safety training and insurance for your property, coordinate with your field groups prior to conducting work, and have all data and draft reports reviewed by CTEH^®, or a representative of your choosing, prior to submittal to outside parties or regulatory groups. These measures ensure that you maintain control over the process and specific knowledge regarding what appropriately trained and insured parties are conducting what work on your property at any given time.

CTEH^® will monitor the assessment or remediation activities through completion and closure. Our risk assessment professionals can evaluate proposed risk-based closure plans from the railroad’s perspective to protect your interests. In closing an agreement, we will ensure that all wells or structures are removed from your property by the licensee.

In managing this program for clients over several years we have encountered numerous examples of situations where the operation of the program was able to save our clients from potentially serious consequences, beyond merely recovery of their program cost. Some examples are:

• Drilling operations adjacent to active main line track without proper track authority or flag protection, FRA safety training, and railroad protective liability insurance
• Excavation for remediation within the failure slope of an embankment fill supporting main line track without plan review by railroad engineers
• Unreasonable and unsafe exposure assumptions for railroad workers used in risk assessments on adjacent property
• Assessment activities unnecessarily conducted on railroad property resulting in reporting to state regulators indicating railroad operations as a source of impact
• Encountering monitoring wells left on railroad property and not properly closed

Railroad Accident Technical Support (RATS)

CTEH^® initiated this program to provide fast, cost effective and cooperative assessment and cleanup at incidents with soil and surface water issues. The major goal of this program is to reduce long term remediation by addressing the major issues early on in a project. CTEH^® accomplishes this goal several ways. We interact and negotiate with regulators both on-site and off-site to insure that we are meeting their expectations as well as keeping our client’s interests in mind. Giving priority to the regulator’s issues promotes good will and makes work progress more smoothly.

This program promotes a more efficient use of contractor’s resources and ultimately cuts costs. Additionally, CTEH^® has a portable gas chromatograph/mass spectrometer (GC/MS). This instrument has been used successfully on several projects. We have the ability to perform laboratory quality work on-site. During a recent chemical emergency, a railcar containing vinyl chloride monomer (VCM) released a portion of its product into surrounding soils during a train derailment. CTEH^® conducted a survey of the potentially contaminated soils where the damaged car leaked and quickly delineated the affected areas. Field-screening techniques were performed using the Inficon HAPSITE^® GC/MS headspace unit using EPA Method 5021.

After the initial excavation, the field screening results of random soil samples collected from the excavation pits yielded vinyl chloride concentrations above guideline values. Based on these on-site analytical results, additional soils were immediately excavated. The final field screen using the GC/MS estimated potential vinyl chloride soil concentrations to be approximately 103-469 fold less than the initial on-site field screen. Conformation sampling using a third party laboratory was also conducted and indicated that only residual amounts of vinyl chloride remained in the excavated area. The use of on-site laboratory analysis techniques avoided unnecessary costs to our client by reducing the remediation time as well as providing immediate direction during the remediation phase.

Additionally, CTEH^® can provide assistance with segregation of wastes and identify economical disposal options. We will prepare technical closure reports and insure a smooth transition to the railroad’s long term environmental consultant if further action is needed.

Lease Environmental Audit Program (LEAP)

Major railroads represent the largest private property owners in the United States; however, much of this land, although owned by railroad companies, is leased and operated by other entities. In some cases the leasees adversely impact the environmental conditions of the property they lease. The reckless, willful or negligent actions conducted by leasees on your property might occur years or even decades before being brought to your attention by the regulatory community. In many instances, the environmental issues are not discovered until the leasee in question is no longer solvent. Waiting until the leasee is bankrupt and the site vacant leaves the property owner financially responsible for the remediation and/ or restoration of the environmentally impacted property.

CTEH^® has developed a program which is a great benefit to your railroad at a very low cost. The Lease Environmental Audit Program (LEAP) was designed specifically to protect the railroad’s interests by reducing exposure to these events, holding the leasee accountable for their actions, and recovering remedial and/or restoration fees.

This program is designed to proactively correct activities which adversely impact the environmental conditions of your property. By randomly auditing leased properties, CTEH^® can identify potential environmental problems and violations of lease agreements while the leasee is solvent and able to incur any associated remediation costs/fees.

Advantages of LEAP include:

• Review of leasee agreements
• Auditing leasee for activities detrimental to the interests of the railroad
• Holding leasees accountable for remediation and restoration
• Dictating appropriate corrective actions of leasee and providing over site of remediation activities through completion and closure
• Cost recovery from leasee
• LEAP easily fits within current railroad operational system
• Database of all leasee agreements, internal audit findings, corrective actions, deliverables, and follow-up schedule
• Proactively monitor leasees, particularly those leasees conducting specific activities having the potential to adversely impact the environmental conditions of your property such as fueling, hazardous material storage, etc.
• Coordination of random leasee audits with other projects to minimize cost