Oil Spill Contingency Plans for Railroads
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Antea Group Consultant Phil Gilchrist presented at the recent CLSRRA conference on oil spill contingency planning for railroads.
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Oil Spill Contingency Plans for Railroads
- 1. CSLRA July 18, 2016 Oil Spill Contingency Plans Update
- 2. Never let a bureaucrat think for themselves… Guide them down YOUR tracks.
- 3. What I am not… CSLRA • Recycling • Reducing energy • Hugging trees • Saving dolphins • Saving whales • Saving puppies confidential and proprietary 3
- 4. What I am… CSLRA • Business partner • Environmental Consultant • Interested in keeping you running your railroad confidential and proprietary 4
- 5. • In September 2015, emergency regulations governing the development of oil spill contingency plans (C-Plans) and financial responsibility became effective. Did you know… CSLRA confidential and proprietary 5
- 6. Does this even apply to my railroad? CSLRA confidential and proprietary 6 • Is your railroad… • A hauler of oil? • Within ¼ mile of a surface water of the state of California? • Able to impact that/those surface waters? • An Inland Facility?
- 7. Does this even apply to my railroad? CSLRA confidential and proprietary 7 • Exemptions • Topographic or engineering controls that will prevent spill from reaching surface water. • Other exemptions in regulations do not apply to railroads • Pipeline length and diameter
- 8. Emergency Regulation Requirements CSLRA confidential and proprietary 8 By January 1, 2016 for inland facilities • Develop C-Plan • Diagrams • Incident command system • Oil spill cleanup contractor • Qualified Individual (QI) • Spill Management Teams (SMT) • Agent for service of process • Reasonable Worst Case Spill volume (RCWS) • Risk and Hazard Analysis and Oil Spill Consequences • Response times for equipment arrival & minimum equipment • Shoreline clean-up • Announced and unannounced drills • Notification information
- 9. Emergency Regulation Requirements CSLRA confidential and proprietary 9 By January 1, 2016 for inland facilities • Develop C-Plan • Reasonable Worst Case Spill Volume (RWCS) • 20% of maximum volume of oil cargo on a single train… • 10 cars = RWCS is 2 cars • 100 cars = RWCS is 10 cars • Regulation assumes 714 bbl per car • However, OSPR is willing to accept a “typical car volume” • e.g. if max volume is 714 bbl, but cars are routinely loaded with 600 bbl
- 10. Emergency Regulation Requirements CSLRA confidential and proprietary 10 By January 1, 2016 for inland facilities • Develop C-Plan • C-Plan only required for the portions of your railroad that… 1. Are used to transport oil… 2. Are within ¼ mile of a state water
- 11. Emergency Regulation Requirements CSLRA confidential and proprietary 11 By January 1, 2016 for inland facilities • Apply for a Certificate of Financial Responsibility (COFR) • Insurance • Self-insured • Surety Bond • Letter of Credit • Guaranty • Protection and Indemnity Club (P&I Club) • Any combination of these
- 12. Emergency Regulation Requirements CSLRA confidential and proprietary 12 By January 1, 2016 for inland facilities • Apply for a Certificate of Financial Responsibility (COFR) • For inland facility railroads… COFR = RWCS X $10,000 For a 10 car oil train… RWCS = 2 cars x 714 BBL = 1,428 bbl COFR = 1,428 bbl x $10,000 = $14,280,000
- 13. Emergency Regulation Requirements CSLRA confidential and proprietary 13 By January 1, 2016 for inland facilities • Apply for a Certificate of Financial Responsibility (COFR) • For inland facility railroads… COFR Min and Max Min - $1,000,000 Max - $300,000, 000
- 14. • Even a single oil tanker spill can cost MILLIONS to clean up? Did you know… CSLRA confidential and proprietary 14
- 15. Emergency Regulation Requirements CSLRA confidential and proprietary 15 Let’s assume a single tank car is compromised… Max Volume – 714 bbl That is not THAT much oil, how bad could it possibly be? Right?
- 16. Emergency Regulation Requirements CSLRA confidential and proprietary 16 Crimson Pipeline Oil Spill, Ventura, CA – June 23, 2016 • Pipeline leak ran into Prince Barranca, a seasonal stream, dry at the time… • ~ 600 bbl of oil released before release stopped • Estimated cost of $350,000 - $400,000 per day • Estimated spend to date - $1.3MM
- 17. Never let a bureaucrat think for themselves… Guide them down YOUR tracks.
- 18. Educate Regulators CSLRA confidential and proprietary 18 In the absence of good data, when public opinion demands action, they WILL regulate in a vacuum.
- 19. Educate Regulators CSLRA confidential and proprietary 19 We need to provide data to OSPR regarding… • Oil Tanker Integrity • Ratings • Speed/Crash Tests • Clean up costs • Financial Impacts on business • Insurance Costs
- 20. Educate Regulators CSLRA confidential and proprietary 20 How do we educate? • CSLRA Lobby Day is CRITICAL – Come show your support! • Data from reliable sources • American Association of Railroads (AAR) • American Short Line Railroad Association (ASLRRA) • American Petroleum Institute (API) • Others?