Environmental Site Assessment Guidelines - Ohio Department of ...

ENVIRONMENTAL SITE ASSESSMENT GUIDANCE FOR
RAILROAD RIGHT-OF-WAY
In the past, ODOT has conducted Environmental Site Assessments (ESA) including sampling and
testing on featureless, open railroad tracks due to potential environmental concerns such as
polychlorinated biphenol (PCB) oils leaking from hydraulic systems, herbicides, and chemical spills. In
many instances, Phase II ESAs were conducted to determine the presence of common railroad track
contaminants such as creosotes, heavy metals, PCBs, and other semi-volatile organic compounds.
However, OES have compiled and evaluated analytical data from railroad ROW which indicates that
there is a very low likelihood of encountering said contaminants on featureless tracks. Based on these
findings, it has been determined that Phase II ESAs are generally not warranted on featureless, open
railroad tracks.
In most instances, railroad ROW will be investigated during the ESA Screening and/or Phase I ESA to
determine the potential of encountering hazardous substances prior to land acquisition and/or
construction involving earth disturbing activities. This is especially true when the railroad is situated in
urban or industrial areas. Where features are indicative of environmental concerns such as reported
spills or releases, USTs, spurs, sidings, loading/unloading areas, buried cars and railroad yards along
railroad right-of-way, Phase II ESA may be warranted to determine their potential impacts to the
project.
In general, it has been ODOT’s policy not to require ESAs for projects which involve upgrading or
widening of an existing perpendicular at-grade railroad crossing. However, if large amounts of
material are proposed to be excavated from the railroad bed at these locations, then limited Phase II
ESA sampling may be conducted to determine the regulatory status of the material for management or
disposal purposes. It should be noted that work at perpendicular at-grade railroad crossings is often
performed by the railroad and is not administered by ODOT.
A common use of abandoned railroads is for bikeways and hiking trails which may include acquisition
of long stretches of railroad right-of-way in both rural and urban areas. At a minimum, an ESA
Screening must be performed for these projects to identify both land uses on railroad right-of-way as
well as adjacent land uses which may pose an environmental concern. If the ESA Screening has
identified an environmental concern in terms of hazardous substances, then a Phase I ESA should be
conducted.
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