What is a Transloading Containment Plan?

Understanding Railcar Transloading Requirements for Spill Containment

If your facility performs railcar transloading, it’s likely required by law to have a Spill Prevention, Control and Countermeasure plan in place. The SPCC regulation requires facilities prepare a plan to prevent accidental oil discharge from entering navigable waters. While one hopes spills never happen, if they do, this rule ensures the environment will be harmed as little as possible. 

What is transloading spill containment?

Transloading is the process of transferring liquids from railcars to trucks and vice versa. The federal government requires spill prevention containers to catch incidental spills that may occur during railroad transfer operations. Facilities can also install high-strength, corrosion-resistant transloading spill containers between train tracks to function as storage units.

Who needs a transloading plan?

Most transloading facilities need a transloading spill containment plan to meet federal safety guidelines. Facilities accomplish transloading through a variety of methods. For example, trucks can transfer material to another truck or train; cranes, loaders or conveyors can transfer liquid into railcars; and ships are utilized to transfer large shipments great distances.

Your facility is required to have a transloading plan if:

• There is a likelihood of oil discharge into local navigable waterways
• The facility handles petroleum and/or non-petroleum oils
• The facility is non-transportation related
• The facility has an aggregate above-ground storage capacity >1,320 gallons or composite underground storage of >42,000 gallons

If your facility meets these criteria, the EPA requires you to implement a transloading spill containment plan. The plan will require you to find a way to hold at least the capacity of any compartment that might be loaded or unloaded at your facility.

What does a transloading containment plan have?

Effective transloading spill containment plans address ways to control scenarios from slow drips to catastrophic spills at industrial railyards, maintenance facilities and other locations.

Transloading plans should consider elements, such as:

• Facility information, including location, rundown of operations, contact information and proximity to waterways
• Emergency information, such as phone numbers, hospital locations and descriptions of how to react to a spill
  Documented oil and petroleum locations
• Current spill prevention information, including training materials, site security information and existing spill equipment
• Equipment details for monthly inspections

What spill containment system should I use?

Transloading containment plans should document immediate actions and required materials in the event of a spill. The Star Track railcar spill containment system relies on a center containment pan between train tracks and two outside pans. Star Track offers safe, effective protection and quick installation. Complete your SPCC plan with the Star Track spill containment system from Polystar to ensure your facility is EPA compliant.

For more information about Star Track or other Polystar secondary containment systems, contact us.