On May 19, RLBA completed a federal regulatory review of Howard Energy Partners’ (HEP) G.T. Logistics (GTL) rail facility in Port Arthur, TX. HEP purchased GTL two years ago and was unfamiliar with regulations in the rail space but was familiar with federal oversight from their experience in the oil and gas industry. After visits from the Federal Railroad Administration and internal concerns regarding the loading, unloading, and handling of hazardous materials in unit tank car trains, HEP determined a full regulatory compliance review was needed. RLBA conducted an on-site review of all documentation to ensure compliance with FRA, PHMSA, TSA and OSHA regulations where applicable as well as determining if filing with the STB as a railroad would be beneficial. During the on-site review, RLBA interviewed key members of HEP and GTL’s management to gauge an understanding of the operations occurring at the facility and the team’s knowledge of rail operations. RLBA also audited for compliance with plans submitted to the FRA and advised on deficiency’s in those plans.