I have been looking at emergency response planning for gas pipelines over the last couple of weeks. This is not an effort to pick on this industry of show my expertise in this industry (practically non-existent). Gas pipeline emergency response plans (ERPs) are a convenient tool to look at emergency planning requirements for a variety of regulated industries because of the recent complaints about the apparent lack of emergency planning at the San Bruno, CA incident and because there are existing requirements for emergency planning in 49 CFR 192.615.
Establishing FEMA ERC Authority
Actually §192.615(a) provides a fairly decent description of the requirements for written procedures for an operators response to “minimize the hazard resulting from a gas pipeline emergency”. The problem is that these procedures should be designed to support an emergency response plan, but they are not an ERP in and of themselves. Part of the reason is that they only reference operator actions and an effective ERP will include a number of other agencies.
The first thing that must be established in the regulations is who is responsible for preparing, coordinating and exercising the emergency response plan. Clearly it cannot be the pipeline operator because of the lack of jurisdiction over the public emergency response agencies (police, fire, EMT, hospitals, etc) that will be required to execute the bulk of the ERP. Because gas pipelines are a Federally regulated industry, I have argued that FEMA would be the appropriate agency and a County Emergency Response Coordinator would be the appropriate official to be responsible for preparing, coordinating and exercising the ERP.
FEMA would be required to establish a list of standard ERP scenarios for potential gas pipeline incidents. In an earlier blog I proposed six potential scenarios for this industry, based on §192.615(a)(3).
Initial Information Requirements
The next thing that the regulations need to establish is the requirement for the regulated pipeline operator to provide specific information to each FEMA ERC affected by a pipeline they operate. The term ‘affected by’ would have to be specifically defined to include such things as large pipelines that are outside of a county boundary, but that could reasonably be expected to affect that county in the event of an emergency.
The information required to be provided would include the locations of all transmission pipelines and significant distribution pipelines (above a specified size), the identification of an emergency response planning official for the operator, and emergency contact information for the operator’s control rooms.
Planning Participation Requirements
The FEMA ERC would be required to conduct emergency planning coordinating meetings with the pipeline operators and local emergency response officials. Those meetings would use the standard ERP scenarios as the basis for establishing the local response plans. The pipeline operator’s ERP official would be expected to provide technical information about the pipeline and potential leak consequences to the planning officials.
The pipeline operator would be required to prepare an individual ERP to support the County ERPs for each of the applicable planning scenarios. FEMA would provide a standard format for the ERP to facilitate the preparation of the ERP. The pipeline operator would be given a deadline for submitting their supporting ERP’s to the FEMA ERC who would review/approve the submitted ERP’s. Once approved, copies of the operator’s ERP’s would be provided to the local response agencies, the FEMA State ERC, and FEMA Headquarters.
Emergency Response Exercises
The FEMA ERC would be required to coordinate, plan and execute annual table top exercises for each of the gas pipeline ERP’s. FEMA would be expected to produce standard formats and supporting information for such exercises that could be adapted by the County ERCs. Operator participation in these exercises would be required by regulation.
Counties that included a high consequence area as identified in the regulations would be required to conduct a full-scale emergency response drill for one of the gas pipeline ERC’s every two years. Again, FEMA would be responsible for establishing a standard drill design for covered planning scenario. The FEMA County ERC would use these standard drill packages to coordinate, plan and execute these drills.
After action reviews of these exercises would be required and the FEMA County ERC would be responsible for ensuring that appropriate changes were made to the County ERP and each of the supporting ERP’s (including the operators ERP). The same reviews and updates would be required anytime that one of the ERP’s was actually employed to respond to a real-life incident.
Clearly specifying who has responsibility for emergency response planning will go along way to ensuring that there are adequate emergency response plans for clearly identifiable emergency situations. Adequate ERP’s, properly reviewed, exercised, and updated, will provide the best chance to minimize potential danger to life and property to both accidents and deliberate attacks on these necessary and potentially dangerous pipelines.