Emergency Response Planning – Communications

Earlier this week I proposed a new structure for Federally mandated emergency response planning for regulated industries like natural gas and hazardous material pipelines. I suggested that FEMA should be the agency that would be responsible for the coordination of emergency response planning between the regulated private entity and the potentially responding Federal, State and local response agencies. FEMA would have offices at county, State and regional levels to effect this coordination. I would like to take a look at how that might work, starting today with communications requirements.

Current Pipeline ERP Requirements

Currently 49 CFR 192.615 establishes the requirements for emergency response planning for natural gas and other hazardous material (except oil and fuel) pipeline operators. It specifically lists {§192.615(a)(3)} four types of incidents that must be addressed in the ERP:

• Gas detected inside or near a building.
• Fire located near or directly involving a pipeline facility.
• Explosion occurring near or directly involving a pipeline facility.
• Natural disaster.

Interestingly there is no requirement for pipeline operators to address a loss of pipeline pressure in their plan. This is the one indication that the operator would have in their system that there was a potentially dangerous leak. Nor is there a requirement to address an overpressure situation. Three of the remaining incidents listed would require that an outside agency contact the pipeline operator to initiate their response.

The ERP required in this regulation outlines what the operator would do in the event of one of these incidents occurring. With the exception of the first and last incident, the only real response required from the pipeline operator is to shut down the flow through the pipeline. In the two remaining incidents leak detection and pipeline repair are the types of actions that most people would expect pipeline operators to include in their emergency response plan.

The problem is that things like emergency evacuations, fire fighting, emergency medical care and police services are not in the purview of the pipeline operator, but would form the largest part of any emergency response plan. The current regulation only requires the pipeline operator to provide a liaison to the agencies that would conduct that emergency response planning. There are no requirements for communications in the current emergency planning regulations.

Routine Communication Requirements

Under the proposed ERP program each pipeline operator would be required to provide details about the location of transmission pipelines, large volume distribution pipelines and above ground pipeline facilities to each affected 911 operation. The information would be provided in a format compatible with the geospatial information system (GIS) used in the 911 operation.

Pipeline operators would be required to provide all 911 facilities supporting areas that any of their pipeline traverses with a 24-hour emergency contact number. Pipeline operators with distribution pipelines would be required to provide each customer with the same 24-hour emergency contact number. For high-risk or high-consequence pipelines there would be a requirement for a dedicated line between the operator’s control room and each affected 911 facility.

Pipeline operators with transmission (as opposed to distribution) pipelines in populated areas would be required to notify all property owners within a reasonable distance of the pipeline of the location of that pipeline and the 24-hour emergency contact number for that operator’s control room. Notification would be by mail and would include a brochure that would describe emergency actions people should take in the event of a distribution pipeline leak, fire near the pipeline, or regionally likely natural catastrophe (earthquake, hurricane, tornado, etc).

The notification would include provisions for the property owner to register as an ‘at risk’ facility (hospital, nursing home, school, daycare, or person with restricted mobility) that might need special assistance in the event of a pipeline incident. The notification would also provide for registration of property owners in an emergency notification program that would allow for the operator to contact affected property owners by phone, email or text message in the event of an emergency.

Pipeline operators would be required to provide 24 hour emergency contact information to the County, State and any regional FEMA Emergency Response Coordinator (ERC) that could be affected by an incident associated with one of their pipelines. They would also be responsible for identifying an emergency response liaison officer that would be responsible for working with the affected FEMA ERCs. The operators would be required to provide the appropriate FEMA ERC with all of the information provided to local 911 facilities as well as a list of all self-identified at risk facilities in the area covered by that FEMA ERC.

Emergency Communication Requirements

In the event of any of the emergency situations listed in §192.615(a)(3) (and we would add loss of pipeline pressure and pipeline over-pressure incidents to the list), which ever party (pipeline operator or 911 service) received notification of the incident would immediately notify the other. The 911 service would be responsible for notifying the FEMA ERC. The emergency communications protocols established in the appropriate emergency response plan would be established.

Pipeline personnel designated as emergency response personnel would be required to communicate with the 911 dispatch by radio when they were activated as part of an ERP. Pipeline service personnel supporting emergency response personnel would be required to maintain communications with the pipeline control room (or designated pipeline emergency response center) and the supervisor of the pipeline emergency response personnel.

Once an incident command post was established, the pipeline operator would be required to provide a communications team to the command post that would allow for communications with all pipeline personnel working in the area and maintaining direct communications between the command post and the operator’s control room. The operator’s liaison and the county FEMA ERC would be expected to be at the command post to provide assistance and information to the incident commander. The FEMA ERC would establish communications with State, regional and national response facilities.

Communications Exercises

To ensure that the communications protocols established in this requirement actually work, there would be a requirement for routine communications exercises. Facilities with a required dedicated line to 911 services would be required to do (and document) a daily check of that line with a separate daily check initiated by the 911 service. All of the remaining pipeline control rooms would be required to document a weekly contact check with each of their supported 911 services.

Every vehicle owned by a pipeline operator that could be required to maintain communications with 911 dispatches in the event of a pipeline incident would be required to conduct a weekly communications check with each 911 dispatch to which it might be required to communicate. Whenever possible, that check should be made from within the covered area of the 911 service.

On a monthly basis the pipeline operator would verify communications with those people registered as wanting to be notified in the event of an emergency. The communication will be clearly identified as a test and would request an acknowledgement of receipt of the test message.

On an annual basis each covered pipeline operator would be required to report the communications exercises to the appropriate county FEMA ERC. In the event of any failure in communications with an 911 service or 911 dispatch, the report would include a description of the corrective action taken and the amount of time that the communication channel was known to be non-functional.

Other Regulated Industries

Many of the requirements for pipeline emergency response communications will be unique to that industry due to the nature of their distribution system and the continuous flow of hazardous materials through their lines. Other regulated industries would have similar requirements tailored to the nature and distribution of the risk associated with that facility.

Railroads for instance would be required to notify each FEMA ERC that had routes used to transport ‘rail security sensitive materials’ of the type hazardous materials included in that designation that were shipped on line as a designated route “posing the least overall safety and security risk” under the PHMSA rail routing rule. They would also be required to establish similar communications protocols with 911 services along those routes.

High-risk chemical facilities and RMP-covered facilities would be required to notify the affected FEMA ERCs and establish liaisons with the affected county FEMA ERC. Facilities would be required to provide mail notification to all property owners within the affected area described in the appropriate regulations. All covered facilities would be required to maintain communications with the local 911 service with Tier 1 and 2 CFATS facilities being required to maintain dedicated lines.

Detailed communications standards similar to those described above for the pipeline operations could be developed for any facility that the Federal government decided merited requiring the maintenance of an emergency response plan. The guiding principal would be that the private entity posing the risk would be required to notify the local FEMA ERC of the risk and establish an ERP liaison with the FEMA ERC. Provisions for emergency communications, and testing of those communications protocols, between the private entity and the local 911 service would be a necessary part of any ERP.