Emergency Response Planning – A Proposal

Last week, in a blog about the emergency response plans for the San Bruno pipeline, I made a statement that was just a bit over the top in the hyperbole department and I was called on it this week end. In regards to the adequacy of the response plans I made the comment that “there are no standards to which such plans can be measured against”. A friend in the emergency response community challenged that statement telling me that she was sure that there were standards for such plans.

Less than Helpful Standards

Going back to the regulations I found (as I expected) that technically she was correct; 49 CFR 192.615 specifically details the requirements for pipeline security plans. These regulations tell pipeline companies what type incidents must be covered, and outlines what types of operator response must be addressed in the plan. So yes there are standards. They don’t mean much, but they do exist.

For example §192.615(a)(6) states that the plan must address: “Emergency shutdown and pressure reduction in any section of the operator's pipeline system necessary to minimize hazards to life or property.” One of the complaints about the San Bruno incident concerned the time that it took to turn off the gas supply and stop the huge torch from burning. Did the PG&E actions ‘minimize hazards to life or property’?

Well the explosion caused the most severe portion of the damage and it could be argued that the subsequent fire at the pipeline rupture did comparatively little additional damage. Most of that damage was done before it could have been reasonably expected for PG&E to shut down the gas flow. So it could be argued that the ‘minimize hazards’ standard had been met. Besides, there is no time limit for how fast the pipeline must be closed in an incident.

Besides, in a catastrophic incident of the sort seen in San Bruno, there isn’t much in the way of response needed from the operator besides turning off the gas. The bulk of the response falls on local fire, police and emergency medical teams. The only place this is addressed in this regulation is in §192.615(c)(4) where the operator is required to establish a liaison with local emergency response personnel to: “Plan how the operator and officials can engage in mutual assistance to minimize hazards to life or property.”

While the article addressed in the earlier blog notes that there was no sharing of plans between PG&E and local responders, it is not entirely clear who is at fault. If PG&E had appointed a liaison who had made practically any contact with local emergency response agencies, it would appear that the letter of the regulation had been met.

Military Response Planning

Now let me make perfectly clear, I have not been trained in emergency response planning and I have never worked with pipeline companies. So, I am hardly an expert in writing pipeline emergency response plans. I do, however, have extensive experience in the process of writing, coordinating, and practicing plans for combat operations. This was all done in a peacetime setting, so it was a form of contingency planning very closely aligned with the types of operations considered in emergency response plans.

The military has extensive experience in the area of contingency planning. It serves a two fold function. First, and most obviously, it provides units with an extensive file of plans for the various actions that the unit might need to accomplish. When an incident arises plans exist for a variety of units to respond in a coordinated manner. Second, it provides training and practice in the process of developing these plans; a process that would be the heart of any potential combat operations.

Now the military has a clear advantage in the planning process. First off there is a unified structure through which all affected agencies are trained. Everyone in the military uses the same planning format for example. This makes the planning process easier for everyone involved. Additionally, there is a clear chain of command, a chain of authority. There is always at least one commander who has clear legal responsibility for all of the organizations involved in responding to an incident.

Neither of these applies to the planning process for emergency response to a pipeline incident (or most other incidents of interest to the chemical security community). FEMA has established an incident management process, but I don’t think that there is significant legal authority to require all personnel involved in an emergency response incident to follow this process. Even if there were such authority the process seems to apply more to actual response operations than for emergency planning operations. Though similar, these are two different things with significantly different requirements.

Emergency Planning Process

So the first thing that needs to be done is for Congress to establish the legal authority mandating an emergency response planning process. This federal process would not apply to distinctly local government response to distinctly local incidents. Where federally regulated industries (like pipeline operators or high-risk chemical facilities, etc.) or Federal facilities need to be involved in the emergency planning process the Federal process would apply. Where interstate planning was required, the Federal standards would apply. State and local governments would be encouraged (with Federal training resources and grants) to apply the same processes to emergency planning requirements under their unique control.

FEMA should establish a responsible person at each county, State and regional level who would be held responsible for the coordination of emergency response planning at that level. This would be a Federal employee with authority to review and approve plan submissions from federally regulated private entities and Federal facilities within that jurisdiction. FEMA would provide the appropriate information from that plan to local agencies and require those agencies to provide a response plan for the covered incidents. Once those plans were received and evaluated FEMA would request additional response plans from other Federal agencies necessary to compliment or supplement local response.

Notification Process

To allow this coordinated emergency response plan to be promptly executed there needs to be a centralized emergency notification system. Both 911 services and pipeline control rooms (for example) would be able to identify from their consoles a situation that would require implementation of a previously established pipeline emergency response plan. The system would allow the identifying agency to select the particular plan appropriate to the incident and fill in the appropriate information for that incident.

This system would immediately send notifications to the designated local response agencies as well as notify State and Federal agencies of the incident. An automated system like this would alleviate concerns about all appropriate agencies receiving the prompt notification of a covered emergency. All subsequent communications would be directed through the incident command system.

Where emergency responders were at an incident that turned out to be pipeline related, their response back to dispatch would be used to trigger the pipeline incident notification system. To ensure that the appropriate pipeline response was triggered for the event, the 911’s geographical interface system (GIS) would have to be programmed with the location of all covered pipelines within its response area. This information should be available through the PHMSA pipeline mapping system.

Having this information programmed into the 911 GIS would provide first responders with and their planning agencies with the necessary information for emergency response without potentially compromising the security of these pipelines. First responders have the ultimate need-to-know when responding to incidents that do or could involve these facilities.

With the notional planning and notification system established, I’ll look at the planning process in more detail in future blogs.