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Spill response planning required for high hazard flammable trains
At a glance
On February 14, 2019 the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule that requires railroads to develop and submit Comprehensive Oil Spill Response Plans (COSRP) for route segments traveled by High Hazard Flammable Trains (HHFTs).
The final rule requires that COSRPs must be consistent with the core principles of the National Incident Management System (NIMS) including the utilization of the Incident Command System in alignment with National and Area Contingency Plans.
The final rule also adds additional requirements for notification and information sharing, and classification testing requirements for light hydrocarbons in stabilized crude oils
On February 14, 2019 the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule that requires railroads to develop and submit Comprehensive Oil Spill Response Plans (COSRP) for route segments traveled by High Hazard Flammable Trains (HHFTs).
What is an HHFT?
High-hazard flammable train (HHFT) means a single train transporting 20 or more loaded tank cars of class 3 flammable liquid in a continuous block or a single train carrying 35 or more loaded tank cars of a Class 3 flammable liquid throughout the train consist.
Tank cars carrying residue or diluted mixtures (less than 10% oil by volume) are exempt from the HHFT determination.
When must COSRPs be implemented?
Voluntary compliance in implementing COSRPs for HHFTs is encouraged as of February 14, 2019. Compliance will be mandatory six months following publication of the Final Rule in the Federal Registry. (Estimated mandatory compliance date September 2019).
What is required in a COSRP?
COSRPs must contain:
- A description of the type(s) of oil expected to be carried
- Determination of the routes to be covered by the COSRP and worst case discharge volume
- Determination of response zones across a railroad’s network
The following information is required for each response zone:
- Description including state, county, route section, environmentally sensitive areas
- Identification of Qualified Individuals (QI)
- Equipment and personnel staged for response within 12 hours
- Notification procedures and contacts
- Description of response and mitigating activities including:
- Initial discharge detection
- Initial actions to be taken before the arrival of the QI
- Responder roles and responsibilities
- Response procedures
- Documentation of employee training and certification
- Documentation of equipment certification and testing
- Description of exercise regime to meet the United States Coast Guard’s Preparedness Response for Response Exercise Program (PREP)
How can GHD help?
GHD’s strong technical team is familiar with the final rule, NIMS, National, Area, and Regional Contingency Plans, associated guidelines, and industry best practices. We can assist with all, or aspects of, the Comprehensive Oil Spill Response Plan (COSRP) implementation including:
- Identification of response zones
- Identification of environmentally sensitive areas and receptors at risk
- High-consequence area assessment and worst-case discharge location identification
- Geographic response planning
- Oil Spill Removal Organization (OSRO) identification and drive time analysis
- Response contractor assessment
- Equipment testing and certification programs
- Plan testing and exercising following the PREP guidelines
- Geographic information system (GIS) support services
- Plan organization and storage including
- Functional PDFs
- SharePoint portals
- GIS web application
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