The Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix T

Voluntary Reduction of Emissions from Railyards in Metro Atlanta RegionVoluntary Reduction of Emissions from Railyards in the Metro Atlanta Region

Introduction: The Georgia EPD has spent a significant amount of time analyzing the source and impact of emissions of ozone an d fine particulate ma tter precursors from railyards in the metro Atlanta area. Table 1 lists railyards located in the metro Atlanta area as of April 22, 2005. While the use of railroads for shipping has a lower overall impact on air quality when compared with moving equivalent tons of cargo by trucks,

railroad-related emissions of NO

x are an important contributor to ozone concentrations in many of Georgia’s nonattainment counties. Cost-effective options are available to significantly reduce NO

x from locomotive engines, however federal regulations do not currently require nor allow stat es to require their use. In addition, recently proposed federal regulations for these engines would not significantly reduce their emissions to the level possible for many years.

Table 1 Metro Atlanta Railyards

County Operator Railyard Name

Cobb Georgia Northeastern

Railroad

CSX Railroad

Norfolk Southern Railroad GNRR Yard

Bolton Yard

Whitaker Yard

Fulton CSX Railroad

CSX Railroad

CSX Railroad

CSX Railroad

CSX Railroad

Norfolk Southern Railroad

Norfolk Southern Railroad

Norfolk Southern Railroad

Norfolk Southern Railroad Howells Yard

Tilford Yard Hulsey Yard

Fairburn Yard

Bellwood Yard

Inman Yard

Armour Yard

South Yard Industry Yard Clayton Norfolk Southern Ra ilroad Forest Park Yard

DeKalb CSX Railroad Portion of Hulsey Yard

While estimates of emissions from locomotiv es have a high level of uncertainty, the likely levels of NO

x emissions from locomotives in th e Georgia nonattainment counties is significant. For example, while stationary facilities emitting 25 or more tons of NO

x per year in the ozone nonattainment counties are regulated under the Title V requirements of the Clean Air Act, eleven of the twen ty-three nonattainment counties in 2002 hadestimates of greater than 50 tons of NO

x per county emitted from yard locomotives 1
alone. One county (Fulton) had emi ssions greater than 380 tons of NO

x per year from yard locomotives alone. Statewide, line-h aul locomotives were estimated to emit 23,671

tons of NO

x per year and railyard locomotives were estimated to emit 3,062 tons, levels comparable with emissions from 32 million Tier 2 automobiles 2

.

The Georgia EPD has undertaken a number of activities to better understand and reduce railroad-related emissions, including submitting three proposals for funding assistance from the Georgia Department of Transpor tation under the Congestion Mitigation for Air Quality improvement program (CMAQ) to retrofit railyard locomotives with much lower emitting engines and to analyze emissions contributions to very high monitored ambient ozone and PM2.5 concentrations near large, ac tive railyards, and work ing with a group of 23 states to prepare be tter railroad-related emissions inventories. To initiate these activities, a Technical Working Group Meetin g titled “Air Quality and Railroads in Georgia” was held in A tlanta by the Georgia EPD on March 21, 2007. The meeting brought together Georgia Class I and Shortline Railroad representatives with members of the EPD and other Georgia agencies to discuss issues related to air quality and emissions

from railroad-related activities. The meeti ng was well attended and participants have continued to be cooperative a nd interested in our air quali ty management efforts.

In particular, representatives from Georgia’ s two Class I railroads (Norfolk-Southern and CSXT) have subsequently shared some engi ne and operations data and have discussed the possibility of collaborative emissions re duction projects. Representatives from the two Shortlines operating in nonattainment counties, the Chattooga & Chickamauga Railway and the Georgia Northeastern Railroa d, attended the meeting have completed a questionnaire designed to collect engine and operations data needed for estimating emissions and have provided feedback on the design of the questionnaire. Shortline railroads, which account for approximately 27% of track route mileage in Georgia, are not required to submit equipment or operations data and their emissi ons are therefore not currently included in the emi ssions inventories. More de tails of this meeting and a general plan related to impr ovement of the railroad-relate d emissions inventory and air quality modeling analysis can be found on a website at http:// www .georgiaair.org/ , under “Hot Topics”, “Railroad- Related Activities”.

The EPD has been awarded funding based on three submitted railroad-related proposals submitted to the Georgia Department of Transportation 2007 CMAQ solicitation. All three of the projects proposed to retrofit switchyard locomo tives (a.k.a. switchers), which generally utilize one powerful, old, high-emitti ng engine, with a set of 2 or 3 currentmodel nonroad diesel engines (e.g., those used in new construction and farm equipment) per locomotive. Most switcher locomotives are believed to operat e 24 hours per day 365

1 Locomotives are divided into three categories, (1) yard locomotives (“switchers”) which are used to assemble and disassemble trains in railyards, (2) line-haul locomotives which are used to pull freight over long, generally intercity or interstate distances, and (3) road locomotives which are used both as switchers and for local hauling generally by Class III (‘Shortline’ ) railroads. These categories of locomotives have different engine types, operation patterns, and normal speed ranges.

2 Calculations based on the Tier 2 NO

x emissions standard (0.07gNO

x /mile) for highway vehicles and assuming 12,000 vehicle miles traveled per year.days per year, mostly within a designated railyard. This newly available ‘Genset’ technology guarantees significant emission reductions. Each project proposal submitted covered a different nonattainment metropolitan statistical area cont aining at least one switchyard operation: Atlanta, Macon, and Rome. The Atlant a proposal also contained a study, which was fully funded, to characterize emission sources in and near two major railyards in Atlanta located near monitors recording some of th e worst ozone and PM2.5 levels in the city.

Table 2 provides information on the am ount of funding awarded through CMAQ per fiscal year for each of the projects (not e that FY 2009 contains the funding for the emissions study, which does not require a match and will not be awarded to a private entity):

Table 2. CMAQ Awarded Funding for Gens et Retrofits and Ambient Monitoring and Analysis in Georgia Nonattainment Areas.

Project Fiscal Year Federal Funding Minimum Match Required Total Project

2009* $200,000 $0 $200,000

2010 $12,000,000 $3,000,000 $15,000,000

2011 $12,000,000 $3,000,000 $15,000,000 EPD Railroad Project - Atlanta

2012 $12,000,000 $3,000,000 $15,000,000

2010 $1,800,000 $450,000 $2,250,000

2011 $900,000 $225,000 $1,125,000

2012 $900,000 $225,000 $1,125,000 EPD Railroad Project – Macon

2013 $900,000 $225,000 $1,125,000

EPD Railroad Project – Rome 2010 $900,000 $225,000 $1,125,000

*The 2009 project is the ambient monitoring and analysis, all others are genset retrofits.

These CMAQ funding awards will allow us to pr ovide incentive and support for railroads to purchase and use this new engine t echnology in railyards located in the GA

nonattainment areas. The railroads must also provide trainin g, updated testing and maintenance procedures, and to assume other costs and risks which are not quantified in the cost of retrofitting the switcher locomo tives. These Gensets would not be built or designated to these areas without th is significant fina ncial incentive.

After receiving internal admini strative clearance to provide f unding to private entities, the EPD plans to release a request for proposals (RFP) specifying projec t selection criteria and weighting. Any railroad operating in each nonattainment area will be eligible to participate and will be able to propose variou s retrofit options. For Atlanta, the EPD will select proposals for funding based on criter ia including, but not limited to, their total emissions reduction potentia l and its subsequent imp act on ambient pollutant concentrations, retrofit cost, available match, previous technology and conversion performance, and cooperation with data collection and emissions reporting efforts. The selected railroads will be responsible fo r conducting or subcontra cting the locomotiveretrofits. The EPD will participate in negotia tions to optimize air quality benefits with any combination of the two Class I and/or the Shortline Railroads operating in the nonattainment areas specified. .

If a voluntary program is pursued in additi on to the Genset locomotive retrofits, the Georgia EPD will advise the railroads on which potential actions would be most effective in improving air quality. There are a few pot ential emission reduction options, which are described below. The most likely for impl ementation include ensuring the use of the lower emitting locomotives in sensitive areas, accelerating the use of low-sulfur diesel fuel, and implementing anti-idli ng technologies or procedures.

Additional Emissions Reduction Options
3⁄4 Ensuring the use of the lower emitting locomotives in sensitive airsheds. A potentially effective emissions reduction strategy is ensuring the use of the lower emitting locomotives in sensitive airsheds. A program based on this principle was implemented in the South Coast Air Ba sin (SCAB) of California through a 1998 Memorandum of Understanding between CARB , the two California Class I railroads operating in the SCAB (Burlington Northern and Santa Fe Railway Company and Union Pacific Railroad Company) and the U.S. EP A. The MOU includes pr ovisions for early introduction of clean units, with requirements for a fleet average in the SCAB equivalent to U.S. EPA's Tier 2 locomotive standard by 2010.

A reduction in fleet-average locomotive emissions can be achieved by either assigning lower-emitting engines to use in and around the nonattainment counties, upgrading the

Tier-level certification dur ing re-manufacturing, a proc ess undergone approximately every 5 years of the 40+ average years of service provided by a locomotive, or purchasing as clean-running engines as possi ble when expanding the fleet or replacing

locomotives.

A promising new locomotive design has rece ntly become available which utilizes multiple (generally 2 or 3) diesel engines such as EPA Tier III off-road certified engines. This allows the locomotive, called a ‘genset’ , to run on only one e ngine when additional power is not needed, resulting in both lower emissions and lower fuel consumption. According to the EPA, much of the operating ti me of locomotives, particularly switchers, is spent in the range that woul d only require the us e of one of the engines. Additionally, ‘stop-start’ functionality is built in to reduce unnecessary idling. Comparative emission factors between traditional and genset locomotives are specified in Table 3.

Table 3. Engine Emission Factors

Gaseous and Particulate Emissions (g/bhp-hr)

Switch Line Haul

HC CO NOx PM HC CO NOx PM

Tier 0 2.1 8 14 0.72 1 5 9.5 0.6Tier 1 1.2 2.5 11 0.54 0.55 2.2 7.4 0.45

Tier 2 0.6 2.4 8.1 0.24 0.3 1.5 5.5 0.2

Genset (NREC) 0.04 1.51 3.37 0.05 0.02 0.93 2.88 0.02

National Railway Equipment Co. http:// www .northeastdiesel.org/pdf/low-emissions-switcher-012206.pdf

As can be seen, the use of a genset rather than the more common Tier 1 switcher can

result in a 70% reduction in NO

x . As an ideal example of pot ential emissions reductions from the use of these locomotives, if genset switchers replaced all yard switchers in the five heavily populated ‘urban core’ counties of Atlanta 3 (assumed to be Tier 1), NO

x would be reduced by 0.83 TPD from 2.72 TPD (b ased on 2002 EPD inventory data). A number of states, including California, Texas, and New Yo rk, have provided funding to assist Class I railroads in the purchase of switcher gensets, each of which costs approximately $1.5M. Assuming 23.54 tons NO

x /year per yard locomotive (based on EPA national average estimates for 2002), there would have been 42.2 yard locomotives operating in the urban core counties. The cost of replacing this number of yard locomotives with genset switchers is $50.6M.

As a result of the Workshop described a bove, one of Georgia’s Class 1 railroads, Norfolk-Southern, has indicated their intention to locate at least one new genset in their largest railyard in Fulton county (Inman Yard). They recently purchased other gensets,

and if we receive fundi ng assistance, we hope to negotiate the placem ent of other gensets at Inman or another rail yard(s), with the possibility of also accelerating the use of lowsulfur diesel fuel, as described below. In addition, or alternatively, funds may be used to assist a Shortline(s) with Tier level upgrades or the purchase of a genset if an improved emissions inventory combined with air quality modeling sensitivity analysis indicates that this approach would reduce peak ozone more effectively.

3⁄4 Accelerating the use of low-sulfur diesel fuel. Currently, most diesel fuel in the state of Georgia contains 15 ppm of sulfur (ppmS), while locomotives and marine engines are al lowed to use diesel with 500 and greater ppmS. The use of 15 ppmS by locomotives will be phased in between 2012 to 2014. According to a study by the Southwest Res earch Institute for the CA Air Resources Board (CARB), the use of a CARB specified fuel with 50 ppmS rather than 320 ppmS

EPA diesel fuel reduced NOx emissions fr om line-haul locomotives by approximately

3.5%.

Using the results of this study, a conservative estimate 4 of potential emission reductions from accelerating the use of lower sulfur fuel by railroads in the five urban core counties

3 Clayton, Cobb, DeKalb, Fulton, and Gwinnett.

4 Using 330 to 50 ppmS rather than 500+ to 15 ppmS sulfur reduction and using the 2002 emissions inventory estimates of locomotive emissions in Georgia (excludes Shortline activity). Additionally, ARB staff believes that, for a number of reasons, these tests underestimate emissions benefits gained from the

use of the CARB fuel.is 0.34 TPD NO

x . The use of this fuel throughout Georgia (excluding Shortlines) would

result in a reduction of 2.57 TPD NO

x (based on 2002 emissions data).

CARB estimates that the use of CARB dies el fuel over on-highway EPA diesel fuel

would result in a net cost in crease of 3 cents per gallon. Consider ing an estimate of 123,026,000 gallons of diesel fuel used by the ra ilroad industry in Georgia in 2005 (by the Dept. of Energy 5 ), the increased cost for the amount of diesel fuel used in Georgia in 2005 would have been $3.7M, or approximately $487k for only in the urban core

counties.

3⁄4 Reducing engine idling time. The use of idle-reduction technology (eg. Automatic Engine Stop-Start (AESS), Auxiliary Power Units (APUs.) with contro ls, etc.) is becoming increasingly common due to its significant reduction in fuel require ments. Switchers are estimated to idle 60% of the time, and line-haul locomotives 40% of the time 6 . Accounting for general levels of emissions under idling conditions, NO

x is estimated to be reducible by 3-5% for linehauls, and 16-20% for switchers 7 . This would result in a 0.49 TPD reduction in NO

x from switchers in the urban core, and a 0.28 TPD reduction from line- haul locomotives in the urban core (assuming average idle time even when operating in the urban core and in and around rail yards).

The EPD will assist railroad in identifying wh ere idle-reduction technology could be best implemented, and possibly assisting in its purch ase and installation (whi ch is estimated to cost approximately $30-35k per engine.) An a lternative approach to reducing idle-related emissions is to encourage more stringent s hutdown procedures. Technology selection or operation guidelines would be established in c ooperation with the participating railroad to ensure optimal emissions control and compa tibility with equipment and general operating

needs.

Other potential projects/activities include:

1. Performing a comprehensive analysis of railroad-related emissions at yards, such as from loading/unloading equipm ent, testing/maintenance, and truck patterns at Intermodal facilities to identify possible measures to reduce

emissions.

2. Encouraging/accelerating the use in Georgia of techniques and equipment under testing and development by the ra ilroads, such as LEADER (use of “Golden Run” guidance) and the opti mization of wheel-rail interfaces.

5 http://tonto.eia.doe.gov/dnav/pet/pet_cons_821dst_dcu_nus_a.htm

6 Locomotive Emission Standards, Regulatory Support Document. United States Environmental Protection Agency, Office of Mobile Sources, April 1998.

7 Locomotive Idling Reduction, Presented to National Idling Reduction Planning Conference, Albany, NY, May 17-19, 2004by D. E. Brann, Emissions Compliance, Electro-Motive Division, General Motors Corporation. http:// www 1.eere.energy.gov/vehiclesandfuels/pdfs/idling_2004/brann.pdf3. Exploring options for expanding the use of railroads for moving freight, which would reduce the per ton emissions compared with the use of trucks.

4. Exploring options for moving some railroad operations outside of highly populated areas that are out of attainment with the NAAQS.

This wide range of emission reduction optio ns for locomotives, the high levels of railroad-related emissions, and the currently cooperative stance of the Georgia Railroads offers a unique opportunity to produce signifi cant emission reductions and subsequent air quality benefits in the nonatta inment counties of Atlanta. An additional initiative in the GA EPD rail program is a eastern US (or possi bly nationwide) collaboration to increase our understanding of rail-related emissions.

Improved Understanding of Railroad-Related Emissions

The GA EPD is co-leading the Eastern Regional Technical Advisory Committee (ERTAC) Rail Subcommittee, which is made up of representatives from state and regional air quality protection agencies that convened to improve our understanding and estimates of railroad-related atmospheric emi ssions. A regional or national approach to building a railroad emissions inventory, rather than a state-by-state approach, will benefit both the railroad community and the respective air agencies by requiring less effort and resources than if acting independently. In addition, a collaborati on between the air and railroad organizations is being pursued because cooperation will produce much more meaningful results due to an understanding of th e uses of the emissions inventories by the agencies and of operations and data availa bility from the railroads. The ERTAC Rail Subcommittee, the Association of American Ra ilroads, and representatives from all eight Class I railroads that operate in the US have begun communicating about the approaches and data needs to support this effort. Th e following information was provided to the railroad community as an overview of the Subcommittee and its objectives before our first web-based meeting:

The Eastern Regional Technica l Advisory Committee (ERTAC) State air pollution control agencies must es timate emissions from sources to develop a state-wide air pollutant emissi ons inventory that is used for planning purposes. ERTAC was convened by a group of state agencies to identify and address signi ficant gaps in our representation of air pollutant emissions. We believe that collaboration will greatly improve our chances of addressing what we c onsider to be critical requirements for effective air quality planning. You can learn more about ERTAC at www .ertac.us

.

The ERTAC Rail Subcommittee

Railroad-related sources were identified as a very high-priority early in ERTAC’s planning activities due to th e extent and level of emissi ons throughout the US, the high level of uncertainty associated with their re presentation in current emission inventories, and their rapid projected growth due to in creased shipping demand, better fuel-efficiency, and generally lower emissions compared with alternative modes of transporting freight.

The ERTAC Rail Subcommittee was formed to improve emissions estimates from thissector. The subcommittee is comprised of active representatives from air quality protection agencies in 13 different stat es, as well as three regional air quality management groups representing additional states as shown in Table 1.

The Importance of Rail Emissions Railroad activity releases a variety of emi ssions and occurs throughout the United States, often concentrated in densely populated, pollute d urban areas. In particular, emissions of

NO

x and primary PM 2.5 from diesel combustion contribut e to ambient concentrations of

ozone and PM 2.5 , pollutants for which many states have counties out of attainment of the National Ambient Air Quality Standards. Ozone and some components of PM 2.5 are ‘secondary’ pollutants, meaning they are formed in the atmosphere rather than directly emitted, making them difficult to manage. Some control strategies can be inefficient or even counter productive if pursued in ar eas with a poorly characterized chemical composition (i.e. a poor understanding the mix of compounds in the ambient air). Maps

of the ozone and PM 2.5 nonattainment areas in the United States are attached (Figure 1) and clearly illustrate why these pollutants ar e of interest to air quality management agencies.

Current Status of Rail-related Emissions Inventories Historically, each state has ei ther requested voluntary data submissions individually or has estimated emissions using surrogates fo r the calculation of em issions from railroad

activities. When additional effort is undertaken, these es timates are often found to be inaccurate. For example, a recent study of lo comotive activity in the state of New York found, for the year 2002, NO

x emissions to be underestimated from Class I line-haul locomotives by 70%, by 11522% from Class II and III locomotives, and by 4671% from line-haul commuter rail. Yard locomotive (switcher) NO

x emissions were overestimated by 97%. This study estimated a total of 25,000 tons/year of NO

x to be emitted by these railroad sources in New York State, a signifi cant contribution to the airshed. This level of error can impact the effec tiveness of controls applied by other sources in the airshed, the efficiency of selected control strategi es, and can obscure valuable opportunities for reducing emissions.

Previous efforts by individual states to im prove their characterization of railroad emissions have often proven to be costly a nd ineffective. There are no consolidated, reliable sources of information regarding the location and activity of these sources. We hope that by unifying our efforts we can both build a more accurate, comprehensive inventory while reducing the burden on railroad s of responding to individual state data requests, which often are developed with di ffering approaches and formats (see Appendix A for example questionnaires).

Objectives and Approach Our primary goal is to build a link-level, c onsolidated emissions inventory of railroad related sources for the year 2008, focusing on Class I, II, and III line-haul emissions, railyard locomotive and possibly other unc haracterized yard source emissions, and commuter and passenger locomotive emissions. We plan to spatially and temporally allocate these emissions as accurately as possi ble. Our current efforts are largely aimedat evaluating potential calcul ation methodologies based on the best available data we can obtain for the 2008 inventory; however, we al so hope to develop a future methodology in cooperation with the railroad comm unity so that future invent ories will require less effort

and will be more accurate. We intend to inform stakeholders of our ac tivities at all stages of development, clearly record our efforts a nd techniques, and to invite collaboration so that we prepare an efficient mode of data collection that will not compromise confidentiality requirements or impose signifi cant administrative burdens. We feel that this activity is critical to our respective agencies’ res ponsibility of protecting and improving air quality and hope that you w ill support us in these efforts.

The following sections of the report descri bed our current understanding/plans for emissions inventory calculati ons and potential sources of data related to the Class I railroad community.