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

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24 C H A P T E R 4 Developing an emergency response plan, acquiring the nec- essary resources and equipment, training responders to per- form their expected tasks and skills, and conducting exercises to test the desired operational capability are the cornerstones of an effective emergency response program. Underlying all of these elements is the need for a communications system that integrates the key players who will be involved in a pipe- line emergency, including emergency responders, the pipe- line operators, and the PSAP and communications centers. Networking and relationships developed during the planning process will help develop a level of trust that will be critical during the response phase. A key player during the planning process will be the local or county emergency management agency, because its role is to facilitate the coordination of the planning and response processes, especially when the use of mutual aid resources is anticipated. The general approach to planning for pipeline emergency communications is drawn from FEMA doctrine, and supplemented with information gathering techniques developed as part of this research. Given the risks involved in a pipeline emergency and the rel- ative infrequency with which major incidents occur, a collab- orative effort is essential to integrate emergency responders, the pipeline operators, and the PSAP and communications centers. This collaborative effort will ensure the development and delivery of an effective emergency preparedness capabil- ity. A successful incident outcome will not be achieved in the absence of addressing critical information needs and commu- nications processes. The Critical Role of Public Safety Emergency Communications (PSAP/Dispatch) Centers One of the most important functions that must be per- formed in a pipeline emergency is to coordinate the flow of information at an incident. Most commonly, in the early stages of an incident, this will involve transmitting information from responders in the field to pipeline operators. In most cases, the information flow is mediated by the public safety dispatch facility. This critical linkage between pipeline operators and the emergency response community is not always recognized and acknowledged. The role of the public safety dispatcher or call taker is thus crucial to the communications process. There are a number of technologies that may be used to facilitate the exchange of information among organizations responding to a reported pipeline emergency. The following are the most common technologies: • Telephone • Radio • Computer/Electronic Data Exchange The technologies used to exchange information between emergency responders and pipeline operators should be identified in advance. In most cases, pipeline operators must rely on telephone communication to speak to first respond- ers; however, other technologies may be usable with prior training. Advances in 9-1-1 system technology, the wide- spread use of computer aided dispatch systems by public emergency responders, and greater availability of computers with wireless connectivity in the field will all offer oppor- tunities for greater connectivity in the future. Regardless of the technologies used, they should be in good working order, which is critically important for the communication func- tion. Alternative technologies and redundant modes of com- munication should be available as well in the event that the most commonly used mode is not available. Guidance Documents for Public Safety Communications Centers and Pipelines Model Protocol for 9-1-1 Centers and Pipeline Emergencies NENA publishes a model procedure known as the “Pipeline Emergency Operations Standard/Model Recommendation. Developing and Exercising the Communications Plans

25 Document 56-007” (23). This document provides a structured protocol for handling pipeline emergencies. The protocol requires that dispatch personnel be provided with informa- tion about physical signs of a pipeline release so they can recognize a potential pipeline emergency based on equivocal or incomplete information. Lay personnel may provide this information when reporting an unusual situation to PSAP. While the protocol advises PSAPs to be aware of pipeline companies and contact information in their service areas, the centers may need to rely on identifying pipeline markers or calling 8-1-1 to reach the local “one call center.” The centers may also need to identify emergency contact information for the pipeline operator(s) in question. In addition, the proce- dure includes a listing of common pipeline leak indicators as described by 9-1-1 callers. These indicators include smells, sounds, and visual indicators such as liquid pooling, dead veg- etation, and frozen ground in the summer or a melted patch of snow in the winter. Also included in the protocol is informa- tion to determine if the caller is in danger and instructions to provide guidance under common scenarios depending on the nature of the hazard, distance from the leak, and physi- cal indicators. Immediate notification of the pipeline operator is indicated and the dispatcher is directed to obtain additional informa- tion on hazards near the location of the leak or spill as well as determine the response time and any actions to be taken by the pipeline operator. Pipeline operators, the American Petroleum Institute (API), and PSAP personnel jointly designed NENA’s Document 56-007 (23). The document is available at NENA’s website, http://www.nena.org. NENA Pipeline Database In response to PHMSA Advisory Bulletin ADB 12-09, NENA established a pipeline database designed for use by pipeline operators to determine the appropriate PSAP along the route of a pipeline (24). The database provides a 10-digit direct-dial number to each of the PSAPs along a pipeline route, and can also be used for identifying the appropriate PSAP for a given location. Released in October 2012, the PHMSA Advisory Bulletin reinforces PHMSA’s intent that operators of gas, hazardous liq- uid, and liquefied natural gas pipelines should have the ability to make immediate contact with the appropriate PSAP located at any point along the pipeline route. The purpose of this com- munication is not only to advise emergency responders of a possible hazardous condition, but also to assist the pipeline operator in gathering first-hand observations made by callers to 9-1-1 centers or by on-scene emergency responders. Such information can be crucial in verifying a leak and reducing the amount of time before taking action to close valves or otherwise isolate the problem. NENA has maintained the U.S. database of all 9-1-1 centers for a long time. This database, which was initially developed for interconnection between 9-1-1 centers and cell sector call rout- ing, has been expanded to include 10-digit numbers for the call centers. These services are available on an annual license, with data updated quarterly (http://nenapipedb.com). Pipeline operators or other users provide a list of counties in which they have facilities, and the NENA database cross- references the list and creates a tabular database list of PSAPs based on locations along the pipeline route. This service is par- ticularly valuable because many counties are served by mul- tiple PSAPs, and the service area boundaries are not always apparent. The use of an authoritative service, such as that provided by NENA, can be an efficient way for pipeline operators to main- tain emergency reporting capabilities for local authorities. Planning Process Pre-incident planning for pipeline emergency communica- tions can follow the same approach used in developing emer- gency operations plans. The research team briefly describes the planning process, identifies key information sources and flows necessary to manage an incident, and suggests approaches to effectively carry out the planning process. As previously noted, the local emergency management agency can be a key player in coordinating and collaborating with multiple organizations and disciplines. Characteristics of Effective Emergency Plans The planning effort should involve all stakeholders to ensure that key players are represented. Minimum partici- pation includes the pipeline operator, public emergency responders, and public safety emergency communications agencies that serve the response agencies. A representative of each center should participate in cases where multiple com- munications centers serve the agencies that would respond. This should include (a) the agency dispatch center(s), (b) the PSAP, and (c) any communications center that receives wire- less 9-1-1 calls. This ensures all centers that may handle any portion of the critical communication are involved. A systematic process should be used to address uncertainty around potential hazards and threats. For example, FEMA already requires states and many local jurisdictions to develop a Threat and Hazard Identification and Risk Assessment (THIRA) as part of its “all hazards” planning process. In the case of pipelines, responders should consider variables such as the type and products carried by pipelines, and their pres- ence in sensitive locations. The pipeline operator’s expertise and familiarity with previous incidents can help the operator anticipate possible outcomes. Public emergency responders routinely plan and prac- tice for a number of hazards, often under their jurisdiction’s

26 Emergency Operations Plan (EOP). Planning for pipeline emergency communications should follow the same gen- eral steps, but the research team suggests some refinements in this area. The benefit of incorporating pipeline emergen- cies into the jurisdiction’s EOP is that it has the support of the entire political jurisdiction and engages other agencies beyond public emergency responders, who would play a role in responding to and mitigating a major pipeline emergency. Further, this approach is consistent with FEMA’s notion of “whole community” planning (25). The mission and supporting goals of each entity in the plan should be clearly specified. This stage of the planning process enables identification and clarification of resource constraints and roles. The planning process should have active participation of senior personnel from all participating agencies. Involvement of participants with the ability to speak for their organiza- tions, make commitments, and resolve uncertainties is criti- cal to the process. FEMA identifies three levels of planning: strategic, opera- tional, and tactical. Strategic planning sets overall policy objectives. Operational planning addresses roles, responsibil- ities, tasks, and action. The tactical level planning addresses personnel functions, equipment needs, and resource man- agement. To be effective, the planning of emergency commu- nications must reach down to the tactical level. It is important to establish specific technologies for exchange of informa- tion, means of sharing information among all parties, and contacts for key individuals and offices. An objective of this planning effort is to support the devel- opment of a “common operating picture,” whereby all enti- ties involved have a shared and consistent understanding of not only where things are, but also where they are expected to go in the near term. A common operating picture describes having a situation awareness among those agencies and orga- nizations involved in the response to a pipeline emergency. The goal of the planning effort is to be able to achieve this common operating picture or situation awareness as quickly as possible after an incident is reported to any party. To summarize, the planning for pipeline emergency com- munications should be consistent with emergency planning already practiced and embedded in the agency’s larger pro- cess of developing emergency operations plans. The planning effort is a process. It should be integrated into training exer- cises and evaluations. Once completed, revisit the process to ensure that it remains current and effective (Figure 4-1). Managing the Incident: Unified Command and the EOC Efforts to plan for communications and incorporate that information into EOPs should be consistent with federal guid- ance in the National Incident Management System (NIMS) and the National Response Framework (NRF). The use of terminology and resource descriptions should be consistent with NIMS guidance. The reader is referred to the national planning frameworks published by the U.S. Department of Homeland Security because they are critical to understand- ing the need for planning communications for pipeline emer- gency response. The national planning frameworks provide an overarching vision for the relationship between pre-event mitigation, emergency response, and recovery. The activities associated with planning for communications in pipeline emergency response would fall under the planning function of the National Mitigation Framework (26). The National Infrastructure Protection Plan (NIPP) is another resource designed to protect the nation’s critical infra- structure and key resources (CIKR). See http://www.dhs.gov/ nipp for additional information. The CIKR Support Annex and Private-Sector Coordination Support Annex provide detailed guidance regarding implementation of the NIPP, including roles and responsibilities, concept of operations, and incident-related actions. Incident and Unified Command In the incident command function, a local public emergency responder, usually the ranking officer on scene from the most relevant public safety agency will assume the role of Incident Commander. The incident command system (ICS) has the capability to integrate pipeline operator representatives as liaisons, where they can efficiently share information with the Incident Commander. This level of integration may be suf- ficient for smaller incidents of limited duration and commit- ment of resources. Figure 4-1. The preparedness cycle. Source: Federal Emergency Management Agency.

27 However, for larger or more complex incidents, the con- cept of unified command brings together all critical agencies that play a crucial role in managing the incident. Organiza- tions or agencies may be defined as candidates for partici- pation in unified command based on provision of expertise, resources, jurisdiction, or legal responsibility. Unified command, in which on-scene command is shared by multiple agencies, is a method to recognize the multi- disciplinary nature of pipeline events, and the important role played by other agencies, such as law enforcement, human ser- vices, environmental protection, hazardous materials response teams, and the specialized expertise of pipeline operator responders. Implementing a unified command structure enables development of a single integrated incident organization. In the early stages of an incident, communication between the pipeline operator and emergency responders is likely to be mediated by the public safety dispatcher, with such commu- nications typically taking place over radio. When a pipeline company representative arrives at the scene of an incident, the primary means of communication shifts so that it is direct, usu- ally face-to-face between the Incident Commander, or a mem- ber of his/her staff, and the pipeline company representative. Assuming an ongoing incident, implement a unified command at this stage. Generally speaking, distribution pipelines, such as those operated by natural gas utilities, will have pipeline represen- tatives on the scene of an incident sooner than transmission pipeline operators. This is due primarily to the more urban nature of distribution pipeline systems, and the long distances that must be covered by transmission pipeline operators. Fur- thermore, local emergency services are likely to have a closer and better established relationship with local pipeline opera- tors because of their proximity and the higher frequency of incidents occurring on local natural gas distribution systems. The Role of the Public EOC Pipeline incidents can be complex events, requiring the response of multiple agencies from different disciplines and different levels of government. Often, such incidents may affect multiple jurisdictions as well. Diverse agencies require multi- agency planning, which presents a coordination challenge. As an incident escalates in terms of its scope or duration, a decision will likely be made to activate the local EOC. The local EOC may be activated on larger or longer duration incidents to assist in coordination, resource management, and fulfillment of functions. Functions may include track- ing resources, ordering specialized resources, and providing legal and financial support, such as executing contracts, and accounting for funds. As multi-agency coordination centers, EOCs are designed to serve as a means to coordinate the flow of information between the incident scene and other agencies and support entities. EOCs bring together key decision makers to provide guidance and direction to support the on-scene incident management activities. Putting Plans into Practice: Exercises Exercises enable organizations to evaluate plans in a risk free environment. The purpose of exercises is to clarify roles and responsibilities and to identify areas where the need for improvement may exist. Exercises are designed to take place before an incident to help the participants and their organi- zations improve their capacity to respond to an actual event. Exercises are important because they help ensure that the effort and information developed in the plan will actually translate into action. The discussion of exercises is limited to planning pipeline emergency communications. In addition to FEMA, TCRP Report 86/NCHRP Report 525: Transporta- tion Security, Volume 9: Guidelines for Transportation Emer- gency Training Exercises may serve as a useful reference (27). Exercises exist in a hierarchy. They range from a simple review of key plan components with critical players, to elab- orate full-scale exercises that may involve hundreds of per- sonnel from dozens of organizations. Figure 4-2 shows the hierarchy of exercises in terms of their sophistication. The research team advocates developing communications plans at least at the operational level. Identify and test com- munication methods and links among all critical parties as identified in the plan. Any pipeline-related exercises should also include tests of communications procedures among all the primary entities previously identified. Situation Awareness Information Requirements Analysis The Situation Awareness Information Requirements Analy- sis (SAIRA) was designed to be effective in particular contexts of identifying role-based information needs based on real- world decision making. This technique, described briefly in Figure 4-2. Hierarchy of exercises. Source: Federal Emergency Management Agency IS-120a Course.

28 Chapter 5, lends itself to identifying information needs in an emergency communications context. Interoperability and Controlling Communications Traffic Communication during a pipeline emergency requires coordination with numerous government agencies and pri- vate companies. A mixture of technologies will undoubtedly be used by the various organizations that must interact to successfully resolve a pipeline emergency. Before an incident, identify contact information and methods for communicat- ing with pipeline operators in the community. Important steps to prepare for this task include the following: • Document intra-agency communication technologies and procedures. • Identify relevant organizations and agencies for notifica- tion and coordination. • Identify preferred communication technologies and pro- cedures for notification and coordination. Identify in advance pipeline operators with facilities in the response area. State or federal agencies that would respond to a significant event, along with their contact information, should also be identified in advance. Interoperability Interoperability is a concept that has received considerable attention in recent years. While interoperability can extend beyond communication, the research team uses it to refer to the ability of different organizations to communicate directly through some technology accessible to all necessary partici- pating organizations. Interoperability is defined as “the ability of emergency responders to work seamlessly with other systems or prod- ucts without any special effort. Wireless communications inter operability specifically refers to the ability of emergency response officials to share information via voice and data signals on demand, in real time, when needed, and as authorized” (28). The concept of interoperability is important to pipeline emer- gency response because the dispatch center or EOC will fulfill a critical role and facilitate communication among personnel and equipment located at the scene of the incident and special- ized resources, including state, federal, and industry assets. While interoperability is commonly thought of as involv- ing voice radio communication, the concept also applies to the ability to communicate with data across disparate agen- cies. Figure 4-3 shows the interoperability continuum. The U.S. Department of Homeland Security’s SAFECOM Office developed this figure. While the diagram is elaborate, it aids in understanding interoperability and its components given the needs of emergency communications in pipeline events. Figure 4-3. Interoperability continuum. Source: U.S. Department of Homeland Security.

29 Examine the continuum by starting at the left side, which represents the lowest level of integration and interoperabil- ity, and move progressively toward the right side of the pre- sentation where there are higher levels of integration and inter operability. Interoperability as a concept is divided into five distinct components: • Governance • Standard operating procedures • Technology • Training and Exercises • Usage The continuum is a useful guide when envisioning com- munication strategies used during a prospective pipeline emergency. The far right column is not necessary in this application, but shows useful concepts to stress the impor- tance of coordinating joint procedures and exercises to prac- tice communication. Elements of a Good Communications System FEMA defines the elements of a desirable communications system. It is important to keep these elements in mind when designing plans and exercising communications procedures for pipeline emergency communications. Communications systems need to have the following characteristics: • Interoperable—able to communicate within and across agencies and jurisdictions. • Reliable—able to function in the context of any kind of emergency. • Portable—built on standardized radio technologies, proto- cols, and frequencies. • Scalable—suitable for use on a small or large scale as the needs of the incident dictate. • Resilient—able to perform despite damaged or lost infra structure. • Redundant—able to use alternate communications meth- ods when primary systems go out (29). Again, while these requirements are designed for public safety communications systems, procedures and technol- ogy should be in place to develop some level of redundancy. Redundancy provides for an alternate means of communica- tion, between the pipeline operator and the public safety first responders. If a primary means of communication is dis- rupted in operational terms, this burden would fall primarily on the pipeline operator, because public safety communica- tions systems are designed with redundancy and resilience in mind (see Figure 4-3).