MSRC’s STARs contractor network in the interior of the United States, combined with its dedicated coastal capability, provide national OSRO/COSRP coverage to the U.S.’s largest Class I Railroads. By citing MSRC, railroad operators are able to demonstrate all of the spill response requirements under new rules issued by FRA and PHMSA for high hazard flammable trains. MSRC identifies, vets, trains and manages a multitude of local environmental services contractors in the remotest parts of the country to provide our rail and pipeline contractors with capable first-strike response that can arrive within the required timelines per PHMSA guidelines. For incidents that require response durations beyond 24 hours, MSRC cascades dedicated responders and equipment from its coastal zones as a “strike team” for the duration of the response.
MSRC trains and manages a network of contractors in spill response so that our customers do not have to. Our training curriculum covers topics specific to the likely spill scenarios of the surrounding environs, including: berms and dams, swift water response, dikes, ice response, rail car support, terrestrial response, in-situ burning, site control and staging areas, and more.
While there are specialized oil spill response techniques for rail, MSRC’s role is distinct from rail car remediation:
IN SCOPE for MSRC:
- Specialized swift water response tools
- High capacity pumps and skimmers
- Access to specialized vehicles for remote locations
- eRailSafe certified personnel
- NFO (NonFloating Oil) Classified OSRO
- Customized spill response trailers
- High Rail Vac Trucks (STARs)
- Remote Sensing
- Communications Trailers
- Heavy Equipment (STARs)
OUT OF SCOPE:
- Rail Car Remediation
- Equipment service or repairs on railcars
- Flare service
- Tank cleaning
- Transload services
OSRO/COSRP Coverage
In 2018, the FRA and PHMSA issued new rules for high hazard flammable trains (HHFTs) requiring spill response capability that would arrive at any incident site within 12 hours.
These rules apply to any train with:
- 20 continuous cars carrying Class 3 Flammable liquids, or
- 35 cars spread throughout any one train carrying Class 3 Flammable liquids.
PHMSA is the regulating authority that reviews COSRPs. Rail Operators must submit COSRPs that align with PHMSA’s pipeline Facility Response Plan Requirements, update and re-submit their COSRPs every 5 years, and share COSRPs with State and Tribal Emergency Response Authorities.
By citing MSRC in their COSRPs, rail operators needing to comply with these requirements are able to:
- Demonstrate readiness to address a WCD of 300,000+ gallons,
- Demonstrate ability to Respond in 12 hours of all areas or meet State requirements if timelines are tighter,
- Exercise and test COSRPs, documenting these activities,
- Ensure response personnel are ready to respond through training and exercises, and
- Ensure equipment is ready to respond through maintenance and testing.