Guide for Communicating Emergency Response Information for Natural Gas and Hazardous Liquids Pipelines (2014)

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5 C H A P T E R 2 Selected Characteristics of Pipelines Minor pipeline incidents occur frequently and are handled safely and effectively by pipeline operators and the emergency response community. However, there are also pipeline emer- gency scenarios, such as those involving transmission pipelines, which have the potential to quickly escalate into high conse- quence events. As low frequency/high consequence events, first responders and pipeline operators are sometimes not fully pre- pared or cognizant of the effort necessary or procedures needed to successfully respond to this type of incident (1). Pipeline emergencies can be inherently complex events, requiring the coordination of multiple response agencies and organizations, and having both short-term and long-term impacts that go well beyond the response phase of the incident. Analysis of past pipeline incidents indicates that commu- nication in the first critical minutes of an event—most often communication between emergency responders and pipe- line operators—is critical to determining the outcome of an incident. Incomplete, inadequate, or unclear communication can result in a delayed response, and can contribute to human casualties, excess release of hazardous substances into the envi- ronment, and excess property damage. Challenges to communications include failure to recognize the potential involvement of a pipeline in a release scenario, inability to identify the product(s) that are being released, and not knowing when or whom to notify to respond to the release. About Pipelines Pipelines are a highly efficient means for moving large quan- tities of both hazardous liquid and natural gas materials. An estimated 70 percent of petroleum products travel via pipe line (2). As such, pipelines are a crucial component of America’s energy system. Although certain parts of the country have greater concentrations of pipelines, the overall mileage of pipelines is extensive and touches every state. Table 2.1 shows data on pipeline mileage by type of pipeline. The greatest mileage is found in natural gas distribution lines, which are used to deliver natural gas directly to consumers. Oil and haz- ardous liquids pipelines account for just over 185,000 miles of the 2.6 million miles of pipeline in the United States. Types of Pipeline: Product and Function While all pipelines have many commonalities, they can be classified by either function or by the product(s) they are designed to carry. In this section, the research team provides a high-level overview that can be useful for understanding pipeline differences. Pipelines by Function Pipelines can be classified according to their function. Reg- ulatory definitions may be complex, and the reader should refer to the Code of Federal Regulations for complete defini- tions. Pipelines are classified as follows: Gathering. Gathering pipelines transport gases and liquids such as oil or natural gas from the commodity’s source—like rock formations located far below the drilling site—to a pro- cessing facility, refinery or a transmission line (49 CFR 195.2). Storage facilities exist that may receive shipments from mul- tiple gathering pipelines. The shipments are then stored in tanks. Producers of the product may own gathering pipelines. Gathering pipelines can be found transporting product from multiple production sites to regional storage facilities. Transmission. A transmission line is a pipeline used to transport natural gas from a gathering, processing, or storage facility to a processing or storage facility, large volume cus- tomer, or distribution system. A large volume customer may receive similar volumes of gas as a distribution center, and includes factories, power plants, and institutional users of gas. The term, transmission line, also refers to a pipeline used Introduction: Why Plan for Communications at Pipeline Incidents

6to transport crude oil from a gathering line to a refinery and refined products from a refinery to a distribution center. The term is often used to describe hazardous liquids pipelines. (http://primis.phmsa.dot.gov/comm/glossary/index.htm?no cache=9525#TransmissionLine see also 49 CFR 192.3). Indeed, some transmission pipelines traverse the entire continent. Transmission lines, especially those covering long distances, are often owned by specialized companies whose sole function is the operation of these specialized components of the pipeline infrastructure. Transmission pipelines are of larger diameter, and have greater flows and pressures than other types of pipelines. Because of this, they have the poten- tial for greater consequences in the event of a release. Distribution. Distribution pipelines are unique to nat- ural gas systems. Distribution pipelines are used to deliver the product to end-users or customers. Storage facilities and transmission lines feed these lines. Distribution lines have the smallest diameter. While distribution lines are more fre- quently involved with leaks, the consequences are more lim- ited, but because they tend to be in populated areas, they may be more likely to threaten structures and people. The research team distinguishes between transmission and distribution pipelines in some places of this guide. The response scenario, the differing operating environments, and the characteristics of each pipeline can have an effect on com- munication needs and the entities involved in responding to a pipeline emergency. Pipelines by Product Carried Although pipelines have many common characteristics, an important distinction is based on the products they are designed to carry. Different products require different pipe- line operating processes and characteristics. The physical characteristics of gases versus liquids will determine oper- ating pressures and flow characteristics. These differences ultimately affect pipeline design and operations. That is, a pipeline designed to carry natural gas would not typically be able to carry a liquid such as crude oil or refined products. However, the same liquid pipeline may be used for multiple liquid products. For example, a pipeline from an oil refinery to a distant storage tank distribution facility can be used to send different grades of gasoline, diesel fuel, or heating oil. Shipments through a liquid pipeline are sometimes referred to as “batch” systems because different grades or types of prod- uct may be shipped through the same pipeline at different times in so-called batches. The batch system is very common in liquid pipelines. The mixing that occurs between different grades of product is known as “transmix.” Depending on the nature of the product and its end-use, the transmix may be subject to additional treatment before being sold or used (3). Characteristics of Pipeline Systems Figures 2-1 and 2-2 provide the layout and overview of petroleum product and natural gas pipeline systems, respec- tively. Both diagrams move from production on the left to con- sumption on the right. The raw material is produced, either from wells or introduced to the system from a tanker or other external source. From there, the material is stored and may undergo some basic processing to remove contaminants. Next, the product enters the transmission line and goes either to a refinery or processing plant. The hazardous liquid or natu- ral gas is transported from the refinery or processing plant through the transmission line. The product is kept moving along the line either through pumps (liquid lines) or compres- sors (natural gas) located along the route. Large liquid volume customers may access product directly from the transmission line, but most users receive the product from a storage tank distribution facility. Natural gas customers generally receive product through the local distribution pipeline system, which is usually operated by a local utility. Odorant can be added to natural gas at the city gate as shown, but is also required in some transmission pipelines in heavily populated areas. Please refer to regulations for specific details. Pipeline Operations Pipeline operations are highly specialized and overseen by per- sonnel working throughout the system. While maintenance per- sonnel and limited operations staff work in the field, most control operations are centralized at the pipeline’s “control room.” Control rooms oversee routine and emergency operations of the pipeline. In the past, many functions relied on personnel located in the field to perform readings, monitor equipment, and open and close valves. Today, many of these functions are carried out remotely, from a centralized control room, using sophisticated monitoring and operation systems and software. Type of Pipeline Mileage Hazardous Liquid 185,425 Natural Gas (Gathering) 16,288 Natural Gas (Transmission) 302,776 Natural Gas (Distribution Mains) 1,246,248 Natural Gas (Distribution Service Lines) 891,954 Grand Total 2,642,691 Source: Pipeline and Hazardous Materials Safety Administration. (http://phmsa.dot.gov/portal/site/PHMSA/menuitem.7c371785a 639f2e55cf2031050248a0c/?vgnextoid=3b6c03347e4d8210Vgn VCM1000001ecb7898RCRD&vgnextchannel=3b6c03347e4d 8210VgnVCM1000001ecb7898RCRD&vgnextfmt=print). Table 2-1. Types of pipeline and mileage (2012).

7 Source: PHMSA “Natural Gas Pipeline Systems.” http://primis.phmsa.dot.gov/comm/NaturalGasPipelineSystems.htm?nocache=464 Figure 2-2. Natural gas pipeline systems overview. Source: PHMSA “Petroleum Pipeline Systems.” http://primis.phmsa.dot.gov/comm/PetroleumPipelineSystems.htm?nocache=6756 Figure 2-1. Petroleum pipeline systems overview.

8Supervisory Control and Data Acquisition (SCADA) sys- tems describe a distributed network of sensors and associ- ated controls. These systems monitor the status of gates and valves, flow of product, pressures, and other operating char- acteristics. These SCADA systems for pipelines are extensive, and automate many functions of pipeline operation. Computational pipeline monitoring (CPM) systems use sensors to monitor flow, mass balance, and other pipeline operating characteristics to detect leaks. These systems com- pare pipeline flows at various stages along the pipeline, and attempt to reconcile differences across these locations. Control room personnel rely on SCADA and CPM systems to monitor the status of the pipeline and detect abnormal con- ditions. The highest priority is to identify a leak or unsafe con- dition as quickly as possible. In many cases, the control room operators must interpret multiple sources of information to infer that a leak has occurred. Reports from field personnel, the public, or emergency responders can help speed this process. Even when a leak is detected, the proper valve or valves must be closed. All valves are not capable of being remotely oper- ated which may require field personnel to drive to a location and manually operate valves. The flow of residual product may continue for some time even after valves are closed. Although extensive technology is in place to monitor pipe- line operations and identify leaks along the pipeline, depend- ing on the pipeline size, location, and product involved, it may be difficult to initially detect a leak or its specific location. According to PHMSA data, public or emergency respond- ers discover a significant percentage of pipeline leaks after a report from the public (4). Please refer to Pipeline Emergencies, Second Edition, for a more complete introduction to pipelines and operational con- cerns of emergency response. This resource is available free of charge online and as a downloadable smart phone “app” via the National Association of State Fire Marshals and U.S. DOT at http://www.pipelineemergencies.com (5, 6). For additional information on pipelines go to http://www.pipeline101.com and http://pipelineemergencies.com. Review of Significant Pipeline Incidents: The Critical Role of Communication Communication at pipeline emergency incidents is com- plex, and includes communication within pipeline compa- nies, between pipeline companies and emergency responders, among emergency response organizations, and between the public and PSAP/Dispatch. This web of organizations and their communication flows illustrates the complexity of communi- cations for pipeline emergency response. Each of the parties plays an important role, and the effectiveness of communica- tion between and within the roles is crucial to the successful response to a pipeline emergency (Figure 2-3). Emergency responders must quickly identify the product involved, which is a key piece of information particularly where multiple pipelines may be in the area or within a common pipeline right of way. Knowledge of the pipelines and prod- ucts carried can greatly ease the process of determining that a call about an unknown odor, sound, or other physical mani- festation of a release is a pipeline emergency. This knowledge can shorten the time to notify the pipeline operator and to dispatch appropriate public safety and industry resources. Analysis of Major Incidents By studying past incidents, one can learn about areas for improvement for emergency response. Relying on reports from regulatory agencies and oversight bodies, such as the Figure 2-3. Roles, organizations, and communication flows.

9 NTSB, can drive improvements in safety through a mix of technological improvement, advancing industry practices, and regulatory actions. This guide relied primarily on post- incident investigative data from the PHMSA and the NTSB. The NTSB data was limited to major incidents. In addition to this data, the study involved interviews, surveys, and meet- ings with groups of professionals representing pipeline oper- ators, state and federal regulators/emergency responders, public safety communications centers, and public emergency response organizations. In examining NTSB reports for the 32 most recent major pipeline incidents (1994–2012), one can see a pattern of fail- ures that contributed to excess losses. Fifty-nine percent of major incidents had one or more deficiencies identified in the NTSB reports that contributed to those outcomes. The incidents are listed in Table 2-2. The incidents collec- tively resulted in 84 fatalities, 310 injuries, and losses in excess of $1.1 billion (2012 dollars). These incidents occurred in 25 states. The research team analyzed the critical incidents identified in the previous discussion to determine contributing factors related to this study. The team selected the following catego- ries to classify incident-related deficiencies. Multiple deficien- cies were possible for a single incident. Table 2-3 summarizes Table 2-2. Summary of losses from major pipeline incidents 1994–2012. Incident Date and Location Number of Fatalities Number of Injuries Total Cost of Damages ($M) Total Cost Current Value (2012) $M 2012 Sissonville, WV 0 0 Not available Not available 2010 Marshall, MI 0 320* >$760 $760 2010 San Bruno, CA 8 15 $44.0 $46.0 2008 Rancho Cordova, CA 1 5 $0.27 $0.29 2008 Plum Borough, PA 1 1 $1.00 $1.1 2007 Carmichael, MS 2 7 $3.38 $3.8 2005 Bergenfield, NJ 3 4 $0.86 $1.03 2004 Kingman, KS 0 0 $0.68 $0.8 2004 DuBois, PA 2 0 $0.80 $0.98 2003 Wilmington, DE 0 14 $0.30 $0.37 2003 Glenpool, OK 0 0 $2.36 $2.9 2002 Cohasset, MN 0 0 $5.60 $7.2 2000 Winchester, KY 0 0 $7.10 $9.5 2000 Greenville, TX 0 0 $18.00 $24.1 2000 Chalk Point, MD 0 0 $71.00 $95.2 2000 Carlsbad, NM 12 0 $1.00 $1.34 1999 Knoxville, TN 0 0 $7.00 $9.64 1999 Bridgeport, AL 3 6 $1.40 $1.93 1999 Bellingham, WA 3 8 $45.00 $62.0 1998 South Riding, VA 1 3 $.025 $0.35 1998 Sandy Springs, GA 0 0 $3.20 $4.48 1998 Saint Cloud, MN 4 11 $0.40 $0.56 1997 Indianapolis, IN 1 1 $2.00 $2.85 1996 Tiger Pass, LA 0 0 Not available Not available 1996 San Juan, PR 33 69 $8.50 $12.5 1996 Murfreesboro, TN 0 0 $5.70 $8.38 1996 Lively, TX 2 0 $0.22 $0.32 1996 Gramercy, LA 0 0 $7.00 $10.29 1996 Fork Shoals, SC 0 0 $20.50 $30.14 1994 Waterloo, IA 6 7 $0.25 $0.39 1994 Edison, NJ 1 93 $25.00 $38.70 1994 Allentown, PA 1 66 $5.00 $7.74 *Note: Includes people experiencing symptoms of exposure to oil.

10 the categories used and their frequency of occurrence in the 32 incidents. Nearly 60 percent of major incidents had some deficiencies in incident management. In summary, the most common problems are failure to promptly notify emergency services or the pipeline operator, followed by delayed action by a pipeline operator. The find- ings from the pipeline incident reports showed that delays in the initial notification to both emergency responders and/or pipeline operators are dominant, but that on-scene issues of coordination or proper action on the part of pipeline opera- tors or emergency services also occurred at over 20 percent of incidents. Improved communications, both during the plan- ning and response phase of incidents, would influence nearly all of the deficiencies noted. Communication Characteristics in Pipeline Emergencies There are several ways to characterize communication issues during pipeline incidents. These are summarized as follows: Timeliness. Timeliness is multi-dimensional and encom- passes many functions. It pertains to the time it takes to rec- ognize and identify a pipeline release, to determine its specific location, to isolate the product flow, and to control any release. It also refers to how quickly emergency responders are notified, arrive on the scene, and initiate response strategies and tactics to reduce the consequences and impacts of the incident. This could include isolation of the area, initiating public protective actions (evacuation or sheltering-in-place), leak and spill con- trol, vapor suppression, and fire extinguishment. Although pipeline operators maintain sophisticated systems for monitoring pipeline flows and pressures and detecting leaks, incident experience suggests that small leaks may not be initially detected through these control systems. Even in cases of significant releases, direct observation by the public, pipe- line personnel or contractors, and public emergency respond- ers accounts for well over one-half of all first reports of releases, according to a study commissioned by PHMSA (4). This means that information flow from the public and emergency respond- ers, which is typically routed through public safety communica- tions centers, often represents the initial notification. The timely ability to identify a pipeline emergency is the most important step in the incident management process. Extent of The Release and Initial On-Scene Conditions. Information on the extent of the release may not be readily apparent to emergency responders or even pipeline control room operators. On-scene emergency personnel need to be able to visually confirm that a release has occurred and pro- vide an initial estimate of the magnitude of the spill or leak. This critical information is also necessary for initiating public protective actions, including decisions to evacuate civilians and summon additional resources to the scene. For example, in the Bergenfield, New Jersey, incident, public safety units and the pipeline operator were on the scene of an outside leak from a gas distribution pipeline. However, they did not anticipate that the natural gas could migrate underground into nearby structures. No evacuation was undertaken, and as a consequence, three people were killed when an explosion resulted (7). Contacting a local one-call center by dialing 8-1-1 before engaging in any digging activities helps avoid excavation damage to pipelines. When pipeline damage does occur, the responsible party must promptly report the emergency to 9-1-1. Several major incidents were identified where delays Deficiency Percent of Incidents (Number) Delayed notification to pipeline operator 19 percent (6) Delayed notification to emergency responders 25 percent (8) On-scene coordination problem between pipeline operator and emergency services 6 percent (2) Delayed action by pipeline operator 9 percent (3) Emergency service on-scene problem 13 percent (4) Pipeline operator on-scene problem 3 percent (1) Other deficiencies not noted above 13 percent (4) Note: Percentages are greater than 100 due to multiple contributing factors for some incidents. Source: Analysis of NTSB reports. Table 2-3. Common deficiencies identified in pipeline incidents 1994–2011.

11 in notification led to increased incident damage and sever- ity. First-hand observations of contractors, who may have detailed information on the location of a leak or site hazards, were often lost as workers reported the emergency to their supervisors or third parties rather than directly alerting pub- lic safety emergency responders using 9-1-1 (8). Ideally, the public safety emergency communications cen- ter can ascertain that a pipeline is involved, begin making notifications early in the incident, and begin the coordina- tion of multiple public emergency responder agencies. In some cases, other utilities may have underground infrastruc- ture that crosses, or even shares right of way with a pipeline. Communication among different utility companies has been identified as a problem in some incidents, that is, a problem in one utility has affected the stability of an adjacent pipeline. Human Behavior and Communication Failures Behavioral factors can influence the flow of information and must be anticipated in the design and implementa- tion of communications systems, especially during the initial assessment, alerting, and notification phases. For example, in the Marshall, Michigan, incident, the NTSB identified “confirmation bias” as a factor that inhibited communications between PSAP/Dispatch operators, the public, and emergency responders (9). Confirmation bias occurs when strongly held beliefs prevent people from paying attention to subsequent communications (10). Combating confirmation bias is especially important when call takers and public safety emergency communications dis- patchers may be accustomed to receiving calls for minor natural gas leaks or odors, and unintentionally rule out the possibility of a major pipeline emergency. Other behavioral factors include what influences people to trust or defer to certain sources of information over others, as well as how people interpret high risk situations and response scenarios (11, 12). People will sometimes underestimate or deny the presence of significant hazards and extreme risks (13). People also tend to view emergencies from the perspective of their own roles. This can interfere with the likelihood that they will attend to the information needs of people in other roles who must respond to a pipeline emergency. Research about pipeline emergencies revealed that the two most likely ways in which information is not provided are (1) the infor- mation is not collected in the first place and (2) the infor- mation is sent too late. Both of these failure modes reflect preparedness problems among persons who are the sources of information. Persons who should transmit information may be unaware that someone else needs it, or they may sim- ply be so caught up in their immediate responsibilities that the information is not sent early enough in an incident. Public Safety Emergency Responders: Learning About Pipelines in Your Service Area As described in the previous section, knowing the loca- tions and products carried in pipelines in a community is the single most important step in preparing for a potential incident. Visual clues, such as markers, can also provide assis- tance in locating pipelines. However, distribution pipelines may or may not be marked, or are not marked as well as larger lines are marked. An agency should begin with the PHMSA National Pipe- line Mapping System (https://www.npms.phmsa.dot.gov/) to find out what hazardous liquid or gas transmission pipelines are running in a particular area. Representatives from public safety emergency response organizations can get an account that will permit access to the detailed maps for their respec- tive county or jurisdiction. In addition to this tool, readers can search for organizations operating pipelines by state, county, or zip code using https://www.npms.phmsa.dot.gov/ FindOperator/PublicSearch.aspx. This system allows public safety emergency responders to identify companies operating in their response area, enabling emergency response agencies to make contact with the pipeline operator and get additional information. The PHMSA mapping system does not include distribu- tion or gathering pipelines. Public safety emergency response agencies will need to contact their local gas utility for more information on these pipelines. In addition, networking with oil or gas producers should identify gathering pipelines, if such activities are ongoing in their area. Once this initial assessment is made, the pipeline operators should be contacted to verify the routing of pipelines and the products carried. Pipeline Operators: Learning About Emergency Responders in Your Service Area Pipeline systems traverse numerous political subdivisions and entities. An important, if not primary, piece of informa- tion for pipeline operators is to know how to contact the PSAP or dispatch facilities serving public emergency responders located along pipeline right of way. This requires knowing the 10-digit direct-dial number for each facility. Jurisdiction of law enforcement, emergency medical services, and fire services may not be the same, and some jurisdictions may even overlap. While the trend in many parts of the country is to consolidate emergency communications on a countywide basis, this practice is far from universal, and many variations exist. The National Emergency Number Association (NENA) offers a service to provide such contact information for pipe- line operators.

12 Another key piece of information is to know the capabili- ties of public emergency responders protecting portions of pipeline. It is critical to establish personal relationships with representatives of key public safety agencies along the pipe- line right of way. Depending on the product carried and capacity of the pipeline, specialized response equipment and resources may be necessary to respond in a safe man- ner. Resource demand for such an incident will commonly require the services of multiple agencies summoned under mutual aid agreements for all but the largest public safety agencies. The “Emergency Response Capability Database and Reporting Tool,” operated by the Pipeline Association for Public Awareness (http://www.pipelineawareness.org/ welcome-government-and-emergency-officials/response- capability-survey-reporting-tool/), is one measure that pro- vides this information on a voluntary basis. The Pipeline Regulatory Framework: How It Relates to Planning for Communications and Response Federal, State, and Local Regulatory Roles Federal, state, and tribal authorities share responsibility for pipeline safety and emergency planning oversight. Federal pipe- line safety regulations require pipeline operators to carry out specific pipeline emergency planning activities, including writ- ten emergency response plans and requirements for communi- cation of emergency plans to fire, police, and other government officials. Nearly all states and the District of Columbia have elected to adopt by reference federal pipeline safety regulations. Through agreements with the U.S. DOT and the Office of Pipeline Safety (OPS), these states have an assigned pipeline inspection and enforcement entity. More information on specific pipeline regulations is con- tained later in this guide. This guide summarized salient fed- eral and state regulation; it is necessary for users to verify state and local regulation that may exist in their communities. Several federal regulations require emergency plans and response procedures [Code of Federal Regulations (CFR) 2012, Titles 30, 40, and 49], including the following: • Notification of appropriate fire, police, and other public officials and coordinating response • Pipeline controller emergency procedures • Evacuation plans for pipeline facilities must be coordi- nated with local public safety officials • Disclosure of hazards, layout, facilities, and quantities of materials present at facilities Thirteen states have additional emergency planning or response requirements in place. These range from filing fed- eral plans with the appropriate state agency to more elaborate requirements including the following: • Notification of appropriate local emergency response agencies • Annual meetings with fire departments along the right of way • Cooperation with training local responders • Notification of schools located within 1,000 feet of a pipe- line, providing information on the location of the pipeline, products transported, designated emergency number for the pipeline operator, and information on excavation noti- fication, recognition, and procedures to follow in the event of a leak. Although some states have additional regulatory require- ments, only some of these requirements directly pertain to emergency response. For the most part, state notification requirements are not well defined, and are not standardized or specific with regard to how notifications shall occur. The PHMSA maintains links on its website to each state pipeline regulatory office. Recent Regulatory Activity and Developments Concerning Communications The PHMSA issued an Advisory Bulletin October 11, 2012 (Federal Register, Vol. 77, No. 197) directing pipeline opera- tors to make direct contact with the appropriate PSAP for any indication of a pipeline emergency (14). This advisory is designed to help the pipeline operator confirm an emergency or to provide assistance and information to public safety per- sonnel who may be responding to the event. Notification of the appropriate PSAP may be challenging due to the large number of PSAPs that may be responsible for portions of a pipeline. NTSB issued this advisory as a result of its investi- gation of the San Bruno, California, gas pipeline rupture and explosion on September 9, 2010 (15). Shortly after this advisory was issued, NENA, a trade group for the public safety 9-1-1 centers, announced a service to provide contact information for PSAPs mapped to pipeline routes (http://nenapipedb.com/). Among its many provisions, the federal law, Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, (CFR 49 Public Law 112-90 2012) requires that, within 18 months of the date of the legislation, the U.S. DOT establish time limits of 1 hour or less for telephone or electronic noti- fication of the DOT and the U.S. Coast Guard’s National Response Center (NRC) (16). This will impact owners and

13 operators of gas and hazardous liquid pipeline systems and liquefied natural gas (LNG) facilities. The legislation reflects the following: • Prompt, accurate communication about the estimated extent of damage for pipeline accidents or incidents to the National Response Center (NRC) is already required. • PHMSA’s new rule will establish specific time limits for telephone or electronic notification to the NRC about pipeline accidents or incidents. • Notification will be established as being not later than 1 hour after confirmed discovery of an accident or incident, and information communicated must include: – Name of the operator – Name of the person making the report – Telephone number of the person making the report – Location of the incident – Number of fatalities and injuries • Revision of initial telephonic or electronic notice to the NRC will still be required within 48 hours regarding the amount of product released, the number of fatalities and injuries and any other significant changes. Finally, the U.S. Government Accountability Office recently provided testimony before the Senate suggesting the develop- ment of performance criteria for pipeline operators who arrive at incidents (17). These recent developments suggest that refinements to pipeline emergency response are recognized as a concern by both the legislative and executive branches of the federal government. Additionally, both the pipeline and emer- gency response communities are working to improve pipeline emergency response.