Thursday, October 7, 2010

S 3856 and Emergency Response Planning

In a blog posting yesterday about gas pipeline emergency response planning (ERP) I briefly mentioned S 3856, the Pipeline Transportation Safety Improvement Act of 2010, noting that an actual copy of the bill was not available on the GPO web site. Just coincidentally, I’m sure, the bill showed up today on that site. Now that I have had a chance to review the bill, I’m afraid that I am going to have to revise my disparaging comments.

ERP Communication

Sen. Lautenberg’s (D, NJ) bill would require that the PHMSA web site would include “a comprehensive list and individual copy of each gas and hazardous liquid pipeline operator’s facility response plan, excluding any proprietary or security-sensitive information that may be contained in an operator’s plan” {60138(a)(2)}. This would certainly be a step forward as this would make the plan available for public inspection. There is, however, nothing in the proposed legislation that would require the pipeline operator to coordinate the ERP with State or local emergency planning or response agencies.

While I certainly understand the ‘security-sensitive information’ exclusion, this wording would allow pipeline operators to avoid listing actual locations of the pipelines covered under the ERP. So it could be very difficult for a local emergency planning or response organization to determine if they would be affected by the ERP, especially given the really poor search capabilities on Federal web sites.

The one good point about this requirement is that post-incident investigations by the press and public interest groups should be able to find out how well the ERP was executed. I think that is covered under the phrase ‘closing the barn door….’.

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