Oil Spill Response Plans (OSRPs) for Crude by Rail
Antea®Group assists railroads with the development of comprehensive OSRPs, training, documentation, and record-keeping to meet the latest standards. We have extensive experience writing spill response plans for railroad yards, bulk liquid terminals, manufacturers, and many other commercial and industrial facilities nationwide. We have an expert understanding of the spill response regulations contained in 40 CFR for a variety of sites and facilities, as well as a specific understanding of the requirements for various business sectors.
Regulations for Crude Oil Transportation
To address public concerns surrounding the transportation of crude oil by rail across state boundaries, the federal Department of Transportation (DOT) Pipeline and Hazardous Materials Administration (PHMSA) is responsible for developing regulations regarding Oil Spill Response Plans (OSRPs).
PHMSA regulations (40 CFR 130.31) currently require basic OSRPs for containers carrying more than 3,500 gallons of crude oil. The new regulations (40 CFR 130.103 et seq) will require comprehensive plans for many trains where only basic plans were previously needed.
Your Partner for a Comprehensive OSRP
Our comprehensive OSRPs are written to meet the unique needs of each rail line that meets the new requirements for a comprehensive plan—this includes lines with either 20 cars carrying liquid petroleum oil (as defined by the rule and ASTM D 4359-84) in a continuous block; or with 35 cars or more throughout the train. If your railroad moves trains that meet those requirements, then in addition to the elements of the basic OSRP, under the new rule the comprehensive OSRP must also consider:
- Substantial harm criteria for the entire route and quick response to larger areas than some previous plans
- Response zones identifying the response resources capable of covering the route
- National Incident Management System and Incident Command System used
- 12-hour response timeframe (420 miles from any point along the line), which may be upgraded to 6 hours for high volume areas
- Worst-case discharge from a train: 300,000 gallons of liquid petroleum oil or 15% of the total lading of liquid petroleum within the largest train expected to transit a response zone
- Qualified Individual (QI) for each zone
- Training for each employee within 90 days of employment and every five years afterward
- Plan review every five years with changes submitted as necessary
With local staff familiar with all relevant federal and state requirements, the Antea Group is proud to be your planning partner.