AN ENHANCED HAZARDOUS COMMUNICATION PROGRAM TO AID COMMUNITIES AFFECTED BY OIL AND GAS INDUSTRY PIPELINES

Transcription

1 AN ENHANCED HAZARDOUS COMMUNICATION PROGRAM TO AID COMMUNITIES AFFECTED BY OIL AND GAS INDUSTRY PIPELINES Mohammad A. Malik Problem Report Submitted to the College of Engineering & Mineral Resources At West Virginia University In Partial Fulfillment of the Requirements for The Degree of Master of Science in Industrial and Management Systems Engineering Kevin A. Rider, Ph.D., Chair Khashayar Aminian, Ph.D. Steve E. Guffey, Ph.D. Department of Industrial & Management Systems Engineering Morgantown, WV 2009

2 ABSTRACT AN ENHANCED HAZARDOUS COMMUNICATION PROGRAM TO AID COMMUNITIES AFFECTED BY OIL AND GAS INDUSTRY PIPELINES Mohammad A. Malik A main objective of this work is to propose an enhanced hazard communication program for the oil and gas industry that can be enforced by law in the communities that are affected by pipelines. There are insufficient rules and regulations that meet the ideal standards of accidental control from potential hazards of pipeline leaks that can be caused in general public or nearby communities. In order to enhance the current standards of the hazard communication program, all rules and regulations must be re-assessed and reanalyzed. Some of the problems that exist in current rules and regulations on hazard communication protocols include dependency on volunteer fire fighters who are insufficiently funded and trained, lack of coordination among first responders, lack of enforcement from current protocol, poor on-time response of first responders during the incident, inconsistent protocol for emergency response, lack of public awareness protocol, and poor preparedness of oil and gas company s personnel for leak incidents. The proposed solutions and recommendations that were developed by evaluating current problems include the following: performing a 911 notification protocol for initial responders, establishing an incident command team (ICT) and ICT commander, involving the oil and gas company personnel as a first responder with ICT, co-coordinating all first responders with time parameter requirements, providing a quick reference guide for first responders, enhancing a hazard communication protocol for the emergency response, identifying specific hazard communication protocol for initial responders and general public awareness, developing better equipment and training for the oil and gas company personnel in deal with emergency response for leaks, partnering up with local county commission and Dot-PHMSA (OPS) for inspection and enforcement, and establishing an accountability at all hierarchy and appropriate consequences for failure. Any emergency plan is only as strong as its weakest link. Plans also can become so complex that accountability is lost. By considering accountability and instituting appropriate consequences, effective hazard communication can be achieved for the oil and gas pipeline industry.

3 ACKNOWLEDGEMENT I would like to give special thanks to my advisor Dr. Kevin A. Rider for his continuous support, guidance, and advice towards completion of this research. I would also like to thank to Dr. Khashayar Aminian, and Dr. Steve E Guffey my committee members for their valuable suggestions and advice. Above all, I wish to thank my God for his mercy and blessing. I would like to express gratitude to my wife and children who encouraged and morally supported me in pursuing this education. I also would like thank to David Fetty (Chief Morgantown Fire Dept.), Dr. Gary Winn, Dr. Daniell E. Della-Guistina, Dr. Robert C. Creese for providing their useful suggestions and support. Finally, I am thankful to Dr. Iskander (Dept. Chair), and my friends at West Virginia University for their support. iii

4 Table of Contents ABSTRACT... ii ACKNOWLEDGEMENT... iii INTRODUCTION... 1 Purpose... 4 Present System to Handle Oil and Gas Leak Accidents... 4 Entities Who Get Involved and Their Responsibilities (i.e. first responders)... 5 Current Problems... 7 Proposed Solutions BACKGROUND Hazard Communication Issues of Pipeline Safety U.S. Oil and Gas Pipeline Statistics Government Agencies OSHA Role EPA Role DOT - PHMSA Role Local Government Departments Office of Emergency Management (OEM) Fire Department iv

5 Operators of Oil & Gas Pipelines METHODOLOGY Analysis Assessment of Compliance with EPA Hazard Communication Requirements PHMSA Public Awareness Requirements Hazard Communication Protocol for the Office of Emergency Management (Monongalia County) Hazard Communication Protocol for the Local Fire Department (Morgantown) Oil and Gas Pipeline Operator Hazard Communication Failure Modes and Effects Analysis (FMEA) of Current HCS Program Proposed Protocol Elements of Proposed Hazard Communication Protocol Summary of Recommendations Evaluation of Current Hazard Communication VS Proposed Hazard Communication Program 48 SUMMARY AND CONCLUSIONS Findings Recommendations Works Cited APPENDIX A APPENDIX B APPENDIX C v

6 APPENDIX D APPENDIX E APPENDIX F vi

7 List of Figures Figure 1- National Oil and Gas Transmission Pipelines (Courtesy from PHMSA) Figure 2- Growth of Population along Transmission Pipeline in Washington State (Courtesy from PHMSA).. 14 Figure 3- Oil and Gas Pipeline Significant Incidents from (Courtesy from PHMSA) 15 Figure 4 - Pipeline Markers (Courtesy of Buckeye Partners, L.P.).17 Figure 5- FMEA Analysis for Proposed HCS Program...34 Figure 6 - Quick Reference Guide Model for First Responders..39 Figure 7 - Proposed Hierarchy of Control Chart 45 Figure 8 Current Program Evaluation Gantt chart...49 Figure 9 - NFPA Hazardous Material Label Figure 10 Hazardous Material label vii

8 List of Flowcharts Flowchart 1 - EPA Hazard Communication Model (Moyer, 1992) Flowchart 2 PHMSA Public Awareness Model (Office of Pipeline Safety Communications, 2009) Flowchart 3 Local The Office of Emergency Management (OEM) Hazard Communication Model Flowchart 4 Local Career Fire Department Hazard Communication Model Flowchart 5 The Local Operator ( Mountaineer Gas Company) Hazard Communication Model (Emergency Response Preparedness Report, West Virginia, 2008) Flowchart 6 - Proposed Enhanced Hazard Communication Model viii

9 List of Tables Table 1 - Leak Rate in U.S. tons/hr for pipeline by pipe s size in inches (HSE, 2009)... 2 Table 2 Typical First Responders Roles (CFD, 2009) (OEM, 2009) (Emergency Response Preparedness Report, West Virginia, 2008)... 5 Table 3 - Oil and Gas Pipeline Statistics from s (Inslee, 2007) Table 4- Specific Hazard Communication for all Stakeholder Table 5 Current Program Evaluation Time in Minute Table Table 6 Proposed Program Evaluation Time in Minute Table ix

10 INTRODUCTION According to Inslee (2007), there were 201 deaths that resulted from oil and gas pipeline leaks between 1990 and 1999 in the US. Inslee also determined that there were 2,829 injuries caused by oil and gas pipeline leaks, and estimated a cost of $780 million in property damages during the same period of time. On average, there are four major oil and gas pipeline accidents every week involving death, injury, or property damage greater than $50,000. The most significant differences between pipeline leaks and other forms of hazardous leaks or spills are the scale of the release of chemicals, the resulting potential for injuries, fatalities, and property damage, and the possibility of producing disastrous consequences that could endanger the general public and the environment. In general, a hazardous materials spill from a truck is limited to the size of that truck or vessel. However, in the case of pipelines, the leak will continue until someone stops the supply line flow or someone shuts off the supply by closing the appropriate valve of the pipeline. Therefore, it is very important to have an effective hazard communication program that will minimize the response time, and can be enforced by law to protect the communities affected by oil and gas pipelines. In order to accomplish this, one first should look at the scope of the oil and gas leak problem. The general characteristic of a pipeline leak rate depends upon the pressure in the pipeline and the size of the hole. The following is the table of leak rate in tons per hour, given with reference to the water leak rate (HSE, 2009): 1

11 Table 1 - Leak Rate in U.S. tons/hr for pipeline by pipe s size in inches (HSE, 2009) Name of Element Water Gas Oil Pressure (PSI) Hole Size (inches) 1/ The size of small crude oil pipeline is between two and six inches, whereas larger pipes run up to eight inches in diameter and still larger trunk lines can reach up to 47 inches in diameter. These pipelines run from oil wells to the main facility, then to local refineries, and between refineries all over the country (CEPA, 2007). For example, if there is a three-inch hole in an oil pipeline, the leak could be up to 120,500 gallons of oil per hour. In a full pipeline rupture in 1994 in Usinsk, Russia sent in excess of 25 million gallons into the Basin of the Pechora River (Patin, 2009). The pipeline was constructed in 1975 with a diameter of inches (Krupenio, 1995). Extrapolating from Table-1, it would have required approximately two and a half hours before the supply was shut off in order for that amount to be leaked. Such lengthy delays should not happen. Another example is Exxon s Valdez oil spill in Prince William Sound, Alaska, in In what is considered to be the worst environmental disaster ever caused by humans at sea, where more than 10 million gallons of oil spilled into the ocean (Hogue, 2001). In this incident, Exxon was required to pay billions of dollars by way of clean-up and lawsuit settlements, and their spill caused extensive damage to the marine life. If an oil pipeline leak happened on an on-shore site in a populated area, the damage would endanger countless human lives. If companies are not able to shut off the oil pipeline supply soon after a leak happens, the magnitude of the disaster could be great. 2

12 Petroleum pipeline accidents could result in a large loss of petroleum, have a substantial impact on the environment, and create potential hazards to communities living by the pipeline. According to the EPA petroleum pipeline leak detection study, Even small losses from a pipeline system cannot be tolerated, and it is the responsibility of government and operating companies to protect the community from possible damages resulting from a leak (Mastandrea, 1983). 3

13 Purpose This research is intended to provide the bases to answer the following questions when an oil or gas pipeline leak occurs: Will the current system provide an adequate response? What are the responsibilities of the entities involved? (i.e. first responders) What are present pipeline rules, regulations, and safety programs? What are some of the problems with current practices? What are possible solutions to these problems? Present System to Handle Oil and Gas Leak Accidents First responders are those, who immediately respond to the incident or who get involved as soon as an incident of oil and gas spill/leak happens. This is the first phase of handling oil and gas leak incidents. This first phase of incident response is crucial, because delays in this phase can significantly increase the probabilities of fatalities, injuries, and property damage. In the present system, when an oil or gas pipeline leak occurs, people typically call 911 operators, who then call the fire department. Fire fighters are then expected to respond to the scene within four minutes of the dispatch center receiving the call from 911 (NFPA, 2009). This standard applies to both career fire department (CFD) and volunteer fire department (VFD). However, the biggest concerns for oil & gas pipelines are VFD and also when we don t have CFD in those areas. The fire chief or reporting official establishes the incidence command post (ICP) within eight minutes from when the 911 call is received by the fire station. Fire fighters assess the hazard and the scope of the situation, then contact the oil and gas company (CFD, 2009). The oil and gas company often take up to two hours to arrive at the incident site (OEM, 2009) and (CFD, 2009). It is not uncommon for the gas company to fix the problem without reporting to the ICP an example of poor communication (CFD, 2009). 4

14 Entities Who Get Involved and Their Responsibilities (i.e. first responders) Table 2 Typical First Responders Roles (CFD, 2009) (OEM, 2009) (Emergency Response Preparedness Report, West Virginia, 2008) First Responders Responsibilities 911 Communications Personnel Fire Department Office of Emergency Management Oil and Gas Operators Law Enforcement Personnel (Police Officers) Emergency Medical Service (EMS) Notify the fire department to respond to the oil & gas leak incident. Respond to oil & gas incident: Assess the hazard, rescue /evacuate the people, control the fire. Serve as a coordination point between fire fighter, local, state and federal agencies in case of oil and gas pipeline leak s disastrous and catastrophic situation. Respond to the oil and gas pipelines leak. Control traffic and maintain law and order during the emergency situation of an oil and gas pipeline leak incidence Provide first aid and transport injured people to the nearby hospital. Table 2 explains typical roles of first responder during an oil and gas pipeline s leak incidence. The following list describes just a few of those first responders: 911 Communication Personnel & Fire Department According to the Pipeline Inspection, Protection, Enforcement and Safety (PIPES) Act 0f 2006, it is required that excavators call 911 in case of a pipeline leak or spill emergency. The U.S. Department of Transportation (DOT) / Pipeline and Hazardous Material Safety Administration (PHMSA) enforce this law. 911 is a public safety answering point works nationally under the umbrella of Homeland Security Department, locally county commission office and in some states township offices. The 911 communications personnel are responsible for notifying the fire, police, and emergency medical services (PSC, 1999). They are trained telephone operators who are responsible for dispatching these emergency responders. 911 personnel training consist of 200 hours of on-job training with a communication training officer. They are specifically trained in Public Safety Telecommunication Course, Advance 5

15 Emergency Medical Dispatcher, Automated Police Network, and National Incident Management System (MECCA 9-1-1:Telecommunicator Training, 2009). Specifically, the fire department is crucial in this situation. Most states in the country have adopted NFPA 1710 requirements for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments (NFPA, 2009). According to NFPA 1710, the local fire department is the first responder, and they are responsible for establishing the incidence command post (ICP), and they should arrive at the incident within four minutes. This is a standard response time, which every fire department should achieve during an emergency response. Office of Emergency Management After the ICP setup, the Office of Emergency Management (OEM) serves as the coordination point between the fire fighters, local oil and gas pipeline companies, the Department of Environmental Protection, and the State Office of Emergency Management. This all depends on the level of public concern, and if the OEM believes the situation is disastrous and catastrophic enough, it can go as far up as the Department of Homeland Security for assistance. However, there are about 22 agencies that fall under the Department of Homeland Security (OEM, 2009). Oil & Gas Operators Every county in the U.S has assigned local operators for oil and gas pipelines (NPMS, 2007). They have their own protocol to deal with emergency oil and gas leaks/spills, which is called Pipeline Emergency Response Planning, in accordance with EPA s Title III requirements. The oil and gas industry has long used pipelines to transporting oil and gas, starting in the late 1800s (Shell Oil Company, 2007). Since then, there has been a continual increase in demand and, leading to development of today s massive transportation system. Many government agencies and oil and gas companies have developed 6

16 safety rules, regulations, and procedures to protect the environment and the people that may be affected by a pipeline or an oil and gas transportation system. The federal agencies that have responsibility for federal and state regulations concerning the oil and gas pipeline include the Department of Labor s (DOL) Occupational Safety and Health Agency (OSHA), the Environmental Protection Agency (EPA), and the Department of Transportation s (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), which enforces its rules and regulations through the Office of Pipeline Safety (OPS). The state agencies in West Virginia that deal with oil and gas pipeline operations are the Public Service Commission, State Fire Marshall s Office, and the State and County Emergency Management Agency. The federal agency that investigates significant pipeline accidents is the National Transport Safety Board (NSTB), and at state level, the agencies that investigate pipeline-related accidents are the State Fire Marshall s Office, the state EPA, and the DOL. Some industry and trade associations that establish pipeline standards are the American Petroleum Institute (API) and the National Fire Protection Association (NFPA) (NASFM, 2009). The federal agencies play a major role when there are no domestic/state laws in place. There are only a few states that have their own rules and regulations, which are in addition to federal regulations. Most of the major oil and gas companies develop their own rules and then create procedures that comply with federal and/or state laws and regulations. Current Problems The studies collected from multiple literatures, federal and local government rules and regulations, and other programs, there are some the following programs developed to control the current oil and gas pipeline incidental system: Reliance on volunteer fire fighter organizations, lack of coordination between first responders, lack of enforcement of current protocol, poor on-time response 7

17 of first responders, inconsistent protocol for emergency response, lack of public awareness protocol, and poor preparedness for leak incidents of oil and gas company personnel. Reliance on Volunteer Fire Fighter Organizations Benjamin Franklin is credited as the person who started the first volunteer fire brigade in Philadelphia in 1736 (Jack W. Snook, 2006). Volunteer fire fighting is a tribute to the spirit of public service in our society, but there are some inherent problems associated with this service. Some of the main issues with utilizing volunteers include the following (Jack W. Snook, 2006): High turnover rate Inadequately training of volunteers Inadequately performance of the volunteers jobs Poor communication between career and volunteer fire fighters Numerous and sometimes conflicting government regulations Of the fire fighters in the US, approximately 75% are volunteers (Karter M. J., Jr., 2008). Therefore, the performance of volunteer fire fighter is extremely important. The high turnover rate and the economic issues make it difficult to develop and maintain a high level of professionals. Hence, in oil and gas pipeline leak s emergencies, it is not prudent to leave everything to the volunteer fire department (VFD). Instead, the gas company s emergency response group should be part of the first responder team. It as was recommended on the accident report of a gas line leak and explosion in Bergenfield, New Jersey on December 13, 2005, that the responding fire department needs training to deal specifically with oil and gas pipeline leak incidents (NTSB, 2005). Lack of Coordination between First Responders In review of interviews with the local fire department s chief, and the Office of Emergency Management s (OEM) director, as well as National Transport Safety Board (NTSB) pipeline leak accident 8

18 reports, it is apparent that there is a significant lack of coordination between first responders. Even though the incidence command post (ICP) is designed for this purpose, the procedures are not followed out in a team manner. Oil companies are not called at the same time to respond to the incident, and this problem stems from deficiencies of our current system of 911 notifications to first responders. Lack of Enforcement of Present Protocol There are rules and regulations in place; however, if no one follows them, currently there are no consequences. For example, in the EPA s regulation Title III, which enforces emergency planning and Right-to-Know Act, the oil and gas companies follow the laws by making an emergency response plan and distributing it to local emergency planning committees and fire departments. By this practice they are satisfying the law, but the problem arises when an actual emergency occurs. If the operators do not follow the emergency protocol properly, there is no penalty to them for failing to doing so. Poor On-Time Response of First Responders A review of NTSB Oil & Gas pipeline accident reports shows that the fire department responded to the gas pipeline leak s incident on time (NTSB, 2005) ; however, they then had to wait for the gas company s technician to shut off the flow control valve. There are no regulations that stipulate the required response time for the company s technician, which was as long as two hours based on these reports. Inconsistent Protocol during the Emergency Response The protocol during an emergency response of first responders should be simple and straightforward. The fire department does not need big books of Emergency Response Planning from the companies during their first phase of an oil and gas leak incidence response. Instead, they need to have a quick reference guide to meet emergency requirements as quickly and effectively as possible (CFD, 2009). 9

19 Lack of Public Awareness Protocol The Pipeline Safety act of 2002 has stipulated regulations of Public Awareness 49 CFR and 49 CFR (a) which requires each pipeline operator to follow the guidelines of the American Petroleum Institute (API) recommended practice (RP) 1162 (Office of Pipeline Safety Communications, 2009). In order to meet this standard from the API RP 1162 documents, the operators have created a pamphlet type of paper which is being distributed to the four stakeholders. The problem with this pamphlet is that the messages are too lengthy and have multiple products to address the four stakeholders which tend to confuse the original message (API, 2008) Poor Preparedness for Leak Incidents of Oil And Gas Company Personnel It also was learned from NTSB s accident report of the 2005 Bergenfield, New Jersey, gas leak incident that when the gas pipeline exploded, both the fire fighters and the gas company s technician were present at the scene. This showed the deficiency of the fire brigade training and the lack of preparedness of the gas company s personnel to deal with this type of incident. It is also important to note that in this accident report that it took many hours for the gas company s technician to shut off the supply of gas, as he was unable to close the control valve (NTSB, 2005). The local fire chief also indicated that usually the oil and gas company s personnel does not come with the right equipment for the emergency in their first response to oil or gas pipeline incidents (CFD, 2009). Proposed Solutions All of the aforementioned current problems will be evaluated along with the present system and current pipeline rules and regulation to assess deficiencies in those multiple systems, and rules and regulations. some of those proposed solutions are: performing a 911 notification protocol for initial responders, establishing an incident command team (ICT) and ICT commander, involving the oil and gas company personnel as a first responder with ICT, co-coordinating all first responders with time parameter requirements, providing a quick reference guide for first responders, enhancing a hazard 10

20 communication protocol for the emergency response, identifying specific hazard communication protocol for initial responders and general public awareness, developing better equipment and training for the oil and gas company personnel in deal with emergency response for leaks, partnering up with local county commission and Dot-PHMSA (OPS) for inspection and enforcement, and establishing an accountability at all hierarchy and appropriate consequences for failure. 11

21 BACKGROUND The purpose of the following information is to discuss known issues of oil and gas pipeline safety and related concerns, requirements of chemical hazard communication for government agencies and how they relate to oil and gas pipelines, and the existing protocols for fire departments, first responders, and local operators in cases of oil and gas pipeline leak incidents. Before discussing the issues of pipeline safety further, it is essential to more clearly define hazard communication. Hazard Communication To be clear, a hazard is anything which has potential of doing damage to humans, property, or the environment. Risk related to the combined severity and probability of an incident occurring. Risk can be mitigated through controls of hazards and exposures. A Successful hazard communication alerts the user to the presence of a hazard and the need to minimize exposures and the resulting risks (UNECE, 2009). Hazard communications are the channels of communication through which employers inform their employees about hazards in the workplace. The philosophy behind the OSHA hazard communication standards is to provide employees with accurate information about the hazards of materials being used so they can take the essential safety precautions (Lowry, 1985). Hazard communication also has a vital role in oil and gas pipeline safety, which will be discussed throughout the literature review. Issues of Pipeline Safety According to the U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA), there are more than 2.3 million miles of oil and gas pipeline in the U.S. every year. PHMSA also states that pipelines are our primary means of transporting 100% of natural gas and 12

22 67% of oil, since oil and gas pipeline supply meets 75% of U.S. energy needs. Transmission pipelines are everywhere across the country, including rural and urban areas, as depicted in Figure 1. Figure 1- National Oil and Gas Transmission Pipelines (Courtesy from PHMSA) Initially, transmission lines were meant to be built away from the urban population. The risk of communities being affected by pipelines increases as population grows along the pipelines. Figure 2 reveals the difference between this 1990 site of transmission lines and the same site twelve years later. 13

23 Figure 2- Growth of Population along Transmission Pipeline in Washington State (Courtesy from PHMSA) U.S. Oil and Gas Pipeline Statistics Oil and gas pipeline incident summary statistics from 1990 to 1999 are given in Table 2. The following figure represents 10 years average ( ) of significant pipeline incidents that include public and industry fatalities, injuries, and property damages. Table 3 - Oil and Gas Pipeline Statistics from s (Inslee, 2007) Gallons Lost Number of Incidence Fatalities Injuries Property Damages 62, 00,000 3, ,829 $780,000,000 Figure 3 depicts the trend of significant incidents over the last twenty years, where it appears consistent. Therefore, it seems evident that the current government rules and regulations and the practices of oil and gas operators are not having a significant effect on the number of significant incidents of oil and gas spill/leaks. The data for the graph illustrated in figure 4, is listed in Appendix A. 14

24 Figure 3- Oil and Gas Pipeline Significant Incidents from (Courtesy from PHMSA) Government Agencies Three government agencies mandate requirements for hazard communication standards (HCS) for companies involved in pipeline operations: the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), and the Department of Transportation (DOT). All of these federal agencies chemical hazard communication rules and regulations apply to the oil and gas pipeline industry since petroleum products also fall under the list of hazardous materials. In hazard communication, OSHA requires oil and gas pipeline operators to make sure that labeling, warnings, placarding, and material safety data sheets (MSDS) are available for their employees. Similarly, EPA mandates oil and gas pipeline operators through Title III to make available the list of chemical inventory and MSDS to the fire department under OSHA. CFR 49 Part 191requires oil and gas pipeline operators incident reporting by following the spill reporting standard in SARA Title III Section 304 (PHMSA Stakeholder Communications: Safety Standards:, 2009) (Moyer, 1992). The most important thing for hazard communication is that the requirements of these regulations are interrelated with each other. Hence, it is vital to have an integrated approach for compliance with OSHA s hazard communication, EPA s SARA Title III responsibilities, and DOT restrictions on transportation of hazardous materials to establish an enhanced hazard communication 15

25 program. The role of government agencies that are necessary to meet these requirements of HCS for the oil and gas pipeline industry is given below. OSHA Role Hazard communication is an OSHA standard intended to stipulate that employers are responsible for informing employees of the hazards and the identities of workplace chemicals to which they are exposed (OSHA 3084, 1998). The hazard communication objectives are achieved through a written comprehensive communication program. The program elements would include labels and warnings, material safety data sheets (MSDS), training employees, and a written implementation plan. The Hazard Communication Standard 29 CFR is divided into six subparts (Grant, 2006). See Appendix B for details. OSHA has a significant role in oil and gas pipeline safety, enforcing safety and health rules for employees. However, its HCS standards, such as MSDS documents, are widely used as a source of safety information by the first responders. Two examples of oil and gas companies MSDS are provided in Appendices C and D. EPA Role The Environmental Protection Agency was chartered to protect the environment. The EPA deals with the aftermath of pipeline failures, but the agency does not provide effective hazard communication plans for communities and energy workers. The Superfund Amendments and Re-Authorization Act (SARA)was passed on October 17, 1986 primarily to control the cleanup of toxic chemicals. One part of this law is Title III, the Emergency Planning and Community Right-To- Know Act of 1986 and is widely used by oil and gas pipeline operators to meet hazard communication requirements. SARA Title III also requires local and state governments to make this information readily available to the public, and is divided into four subparts: Section (Emergency planning for accidents), Section 304 (Notification of spills), Section (Annual reporting of chemical 16

26 inventories), and Section 313 (Annual reporting of routine and accidental toxic chemical discharges into the environment) (Francis, 1992). See Appendix E for additional details. DOT - PHMSA Role The Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency within the U.S. Department of Transportation (DOT), is responsible for keeping the public safe and the environment protected when hazardous materials are moved throughout the country by land, sea, or air. PHMSA, through the Office of Pipeline Safety (OPS), develops and enforces regulations for the 2.3 million-mile pipeline transportation system, which is intended to eliminate incidents, injuries, deaths, and environmental and property damage when hazardous materials are shipped. PHMSA works to reduce the harmful consequences to people, the environment, and the economy after a hazmat (hazardous material) or pipeline failure occurs. The U.S. Department of Transportation (DOT) requires the use of pipeline markers to show that the pipeline is there (Figure 4). Markers point out the general location of pipelines, but they do not represent their precise location. Markers of this kind are located at road, railroad, and navigable waterway crossings. Markers are also placed along the pipeline right-of-way (Emergency Response Preparedness Report, West Virginia, 2008). Figure 4 - Pipeline Markers (Courtesy of Buckeye Partners, L.P.) 17

27 Pipeline markers display: The material transported The name of the pipeline operator The operator s emergency contact Additional rules governing pipeline safety are included in Title 49 of the Code of Federal Regulations (CFR), Parts Most relevant to the research topic are: 49 CFR 194, Response Plans for On- Shore Oil Pipelines, and 49 CFR and 49 CFR , Public Awareness Regulations. Individual states may have additional or more stringent pipeline safety regulations. See Appendix F for details. Inspections and Enforcement PHMSA partners with state governments for inspections and enforcement of pipeline safety program. Funding and certifications are provided to carry out the regulatory responsibilities for oil and gas pipelines. For additional details, the current list of state partners can be found on the PHMSA website (PHMSA, 2007). PHMSA Public Awareness Regulations Federal pipeline safety regulations obligate pipeline operators to conduct continuing public awareness programs to provide pipeline safety information to four stakeholder audiences (Office of Pipeline Safety Communications, 2009): Affected Public Emergency Officials Local Public Officials Excavators Existing regulations (49 CFR and 49 CFR ) require pipeline operators to develop and implement public awareness programs that are consistent with the requirements of the Pipeline 18

28 Safety Improvement Act (PSIA) of 2002 and the guidance provided by the American Petroleum Institute (API) Recommended Practice (RP) 1162, "Public Awareness Programs for Pipeline Operators". Likewise, PHMSA s 2005 rule requires that all pipeline operators must develop a written public awareness program and carry out the program on a continuing basis. The program should be for occupants near the pipeline, and must include information about safety and environmental risks, information on identifying and responding to pipeline emergencies, and it must be included for emergency responders (Gas Operators and Public Awareness, 2008). PHMSA's final rule exempts operators of master meters and petroleum gas systems from the requirement to develop and implement a written continuing public education program. In its place the operator must develop and implement a "written procedure" to provide customers with public awareness messages two times in a year. The message must include a description of the purpose and reliability of the pipeline, an overview of the hazards of the pipeline and prevention measures used, information about damage prevention, how to recognize and respond to a leak, and how to get additional information (Gas Operators and Public Awareness, 2008). The Public Awareness Regulation s final rule was published in May 2005, which required American Petroleum Institute s RP 1162 public awareness programs to be implemented by June 20, According to PHMSA, the first evaluation of effectiveness of the Public Awareness program is due on June, Local Government Departments The local government Office of Emergency Management / 911, and the Career Fire Department are being studied for hazard communication protocol. For example, Monongalia County in West Virginia has been chosen for the purpose. However, this research is still credible because most of the rules and regulations are similar across the U.S. The background information of hazard communication of this kind is based on convenience for adaptability anywhere in United States. 19

29 Office of Emergency Management (OEM) The Office of Emergency management (OEM) works in connection with the local government, emergency response organizations, state agencies, volunteer organizations, and federal agencies such as the Federal Emergency Management Agency (FEMA). The Office of Emergency Management fulfills its objective by coordinating the county s mitigation efforts for emergency preparedness, response, and recovery (Ronald A. Kyle, Shaunda Y. Rauch, 2008). The local office of emergency management in this area is the Monongalia County Office of Emergency Management. The Monongalia County Commission started the Monongalia County Office of Emergency Management in compliance with West Virginia Code Chapter 15, Article 5 in July of The objective of the State Emergency Response Commission (SERC) and Local Emergency Planning Committees (LEPCs) is to implement the Emergency Planning and Community Right to Know Act (EPCRA) and to reduce the effects of a release or spill of natural or man-made hazardous materials. On October 17, 1986, in response to concerns for safety around chemical facilities, Congress passed the Emergency Planning and Community Right to Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act (SARA) (West Virginia Tier 2 Sections Summary, 2008). The OEM and 911 adhere to the following protocol in the case of an oil or gas pipeline leakage incident (OEM, 2009): Call 911 for any oil and gas pipeline leakage Notify local fire department for spill or leakage of oil or gas pipeline The fire department confirms that there is a small or large spill or leakage of oil or gas Once the fire department reaches the scene and provides their assessment, they then inform the oil and gas pipeline company If it is a public concern, then OEM calls state emergency management and Department of Environmental Protection (DEP) 20

30 OEM becomes the coordination point by following instructions from the fire department s Incidence Command Post (ICP) OEM provides on-going support to the ICP & DEP or State Emergency Management If there is a public concern, then they serve as communicator to inform the public through phone, text messages, and local media 911 Emergency Response Including PHMSA, almost all companies, organizations, and government departments and agencies ask civilians to call 911 for a pipeline leak, so this makes 911 the first line of response. The simple rules to recognize and respond to a pipeline leak are (Explorer Pipeline Company, 2008): look for dead vegetation liquid on the ground near the pipeline fire or a dense white cloud or fog a hissing sound a strong petroleum smell Call 911 Evacuate everybody from the area immediately and warn others to stay away Accordingly, a person should be aware of the following things: Do not light a match, start an engine, use a telephone or a cell phone, or turn on/off any electronics. Do not drive into an area where you suspect a leak Do not touch or operate pipeline valves Fire Department Of the total number of fire fighters in US, around 75 % are volunteers (Karter M. J., Jr., 2008). According to NFPA 1001 Standards, the job performance requirements for the career and volunteer 21

31 firefighter are the same (NFPA, 2008). The local CFD fire department provides both proactive nonemergency and reactive emergency response services to the community. including a generic protocol for spill and leak of oil and gas pipeline (VFD, 2009): Call 911 for any oil and gas pipeline leakage Receive notification from 911 for a spill or leakage of an oil or gas pipeline Respond to the scene within four minutes Identity the hazard Evaluate the scope, whether it is a small spill/leakage or a big one Evacuate and secure the area properly Contact the appropriate people for a more in depth-response. Call the local operators of the oil and gas company. Since they know the system, they should handle that system. Operators of Oil & Gas Pipelines Since, every county in the U.S has assigned local operators for oil and gas pipelines (NPMS, 2007). For example, one of the local key operators for natural gas in Monongalia County, WV is the Mountaineer Gas Company; the state s largest natural gas distributor providing natural gas service to over 220,000 customers. Mountaineer Gas service territory extends over 48 of the 55 West Virginia counties including Monongalia County. The operation and maintenance of this company covers over 5,000 miles of gathering, transmission, and distribution lines (Emergency Response Preparedness Report, West Virginia, 2008). The Mountaineer Gas Company maintains a good record of safety and reliability. However, in case of natural gas pipeline emergencies or failure, the following protocol is applied for emergency response (Emergency Response Preparedness Report, West Virginia, 2008): Upon finding the first indication that gas may be involved, notify the Gas Company immediately. Give the location and details, whether leakage is inside or outside a building 22

32 Your name and emergency organization Gas company personnel are instructed to report to the incidence command post (ICP) when they arrived on the scene If several gas company personnel are involved at the scene, the gas company will assign a coordinator to work with the ICP s commander. 23

33 METHODOLOGY The methodology section consists of two parts: evaluation of existing hazard communication protocol, and proposed hazard communication protocol. Analysis This system of hazard communication analysis for current rules and regulations was conducted using a systems engineering approach of process modeling. Process modeling is the activity of representing the process of an enterprise. In this scenario, the flow of hazard communication along the various entities and the efficacy of achieving its ultimate objective will be shown. Assessment of Compliance with EPA Hazard Communication Requirements Flowchart 1 describes the requirements of Title III which started with oil & gas pipeline operators and ends with the first responders, local and state commission office, local department of environment (DEP) which comes under EPA. The first task, section for Emergency planning for accidents, which requires operators must report an emergency response plan to the local emergency committee, state commission, and fire department The second task, characterized in section 304 for Notification of spills, mandates that each operator that has production, usage, or storage of any hazardous chemical, which is defined under OSHA s Hazard Communication Standard, must notify the state emergency response commission, and the local emergency planning committee of any kind of spills that could cause exposure outside of the facility. In turn, local emergency planning committee which works under Office of Emergency Management will inform the local fire departments. The third task, corresponding to section for Annual reporting of chemical inventories stipulates that each operator must prepare or maintain material safety data sheets (MSDS) to comply 24

34 with OSHA s Hazard Communication Standard. Moreover, the operator must submit annual chemical inventory forms stating the average daily quantities available at the facility, the maximum quantity available on any given day of the year, and also provide the locations of these chemicals to the local fire departments. The fourth task, indicated in section 313 for Annual reporting of routine and accidental toxic chemical discharges into the environment. However, operators of oil and gas uses toxic chemical in production (hydraulic fracturing), but does not using any toxic chemical in the transmission of oil and gas. If operator processes, or uses any toxic chemical in amount greater than the threshold limit must submit annual reports on the discharge quantity of the chemical during the year into the environment to the EPA and to the designated state official. According to studies by Office of Pipeline Safety, there are numerous weaknesses in the facility response plans that are likely to reduce response effectiveness in actual incidental events (OPS, 1999). The current operators emergency planning is not meeting the requirements that are needed to deal with potential hazards of the pipeline leak / spill, or any accident, which can impact nearby communities or general public. First operators emergency planning should be enhanced in order to meet the challenge of potential danger of a pipeline that they are imposing on general public. Secondly, MSDS is good source of safety information about oil and gas and should be carried by 1 st responder, but in an emergency situation or in the first phase of response, it can become confusing methodology because of the extensive information. Instead, the first responders should also have some kind of quick reference document to promptly handle the situation of an oil or gas pipeline leak incident. Overall, the deficiencies in hazard communication will lead to an increase in risks and significant losses. 25

35 Toxic Chemical Release Form (313) Operators Emergency Planning ( ) 2 3 Emergency Inventory (312) Emergency Notification (304) MSDS or List (311) Designated State Official EPA State Commission Emergency Response Plan Local Committee Fire Department Flowchart 1 - EPA Hazard Communication Model (Moyer, 1992) PHMSA Public Awareness Requirements Flowchart 2 represents the PHMSA public awareness model, where all four stakeholders should receive the general information from the pipeline operators. Flow Chart 2 shows that operator creates a public awareness pamphlet from API (RP) This pamphlet consist of the following: Purpose and reliability of pipeline, hazards of pipeline, damage prevention, recognize and respond to a leak, and how to get addition information. This information are than communicated to all four stakeholders. However, the problem persists for effectively delivering extensive messages to four stakeholders with distinctly different needs. When operators create a brief pamphlet to meet the requirements of the API RP 1162 for public awareness, it becomes less informative. Conversely, too much information tends to overload the message to the stakeholders. For first responders and the general public, the hazard communication protocol should be very specific and intended to warn about the immediate hazards that are associated with the oil or gas leak and how to recognize and respond to a pipeline s leak. 26

36 Because of the lengthy messages currently used, the document could tend to confuse the first responders and all others stakeholders, decreasing the effectiveness of the response that is needed in the first phase of an oil or gas pipeline leak incident for public awareness. Start Pipeline Operators Creates Pamphlet from API RP 1162 Purpose and Reliability of Pipeline Hazards of Pipeline Damage Prevention Recognize and Respond to a Leak How to get Additional Information Four Stakeholders (Affected Public, Emergency Officials, Local Public Officials, Excavators) End Flowchart 2 PHMSA Public Awareness Model (Office of Pipeline Safety Communications, 2009) Hazard Communication Protocol for the Office of Emergency Management (Monongalia County) As shown in the Flowchart 3, the Office of Emergency Management (Monongalia County) follows general hazard communication protocols for oil and gas pipeline leaks. While this process meets the Title III requirements, the content is too broad and does not address the specific need of handling oil and gas pipeline leak / spill challenges. The deficiencies with the present protocol include 911 personnel having limited knowledge for dealing with oil and gas pipeline incidents, their notification protocol do 27

37 not enhance the teamwork environment, and 911 personnel are not able to convey the information necessary for first responders to effectively resolve such emergencies. Start Call 911 for Oil &Gas Pipeline Leakage 911 Notify Local Fire Department Fire Department Respond to Scene (Establish Incidence Command Post) Confirm Leakage No End Yes Call Local Oil & Gas Company If Public Concern Yes No End OEM Becomes Coordination Point Between ICP and Other Agencies Call State Emergency Department & (DEP) Flowchart 3 The Office of Emergency Management (Monongalia County) Hazard Communication Model 28

38 Hazard Communication Protocol for the Local Fire Department (Morgantown) As shown in Flowchart 4, the local fire department follows general hazard communication protocol for an oil and gas pipeline leak. Firefighters have a long list of varied responsibilities, which do not regularly include performing hazard assessment, especially for oil and gas pipeline leaks. The responsibility for these tasks should fall on the oil and gas operators, who have the best understanding about these matters, their companies pipelines, and other associated systems. The high number of firefighters who are volunteers raises additional risks and concerns regarding the insufficiency of training a workforce with typically high turnover. Dependence on the firefighters should be limited and the assessment of the hazards of oil and gas pipeline leak must be assessed with more qualified personnel. Therefore operators should also be 1 st responders with responsibilities to coordinate with the fire department to quickly resolve oil and gas pipeline leaks. 29

39 Start Receive Notification from 911 for Spill/ Leakage of Oil/ Gas Pipelines Respond to the Scene in 4 Minutes Identify the Hazard Evacuate and Secure the Area Big Is it a Small/Big Spill/Leak Small Isolate the Area Call local Oil/Gas Pipeline Comapany Establish Incidence Command Post (ICP) Flowchart 4 Fire Department (Morgantown) Hazard Communication Model 30

40 Oil and Gas Pipeline Operator Hazard Communication The Flowchart 5 shows the hazard communication protocol for a local operator (Monongalia County), since each operator has to engage with the emergency plan for oil and gas pipeline leaks. In compliance with the Title III hazard communication requirements, operators also are responsible for providing their emergency plan to the local fire department and local emergency planning committee. Making an emergency plan is an important step; however there is limited accountability or consequences if companies do not follow those plans properly. This vast deficit in hazard communication can lead to ineffective emergency planning and delayed response times. Incorporating accountability at all levels and consequences for failure will encourage all entities to better respond to these emergencies. 31

41 Start Notify the Gas Company Immediately (upon finding the first indication that gas may be involved) Give the Location and Details (whether leakage is inside or outside of a building) Your Name and Emergency Organization (Identify yourself and your organization) Gas Company Employees to Report ICP (when they arrived on scene) Control the Leakage or Spill Assign a Coordinator to Work with ICP s Commander (when several gas company personnel are involved) End Flowchart 5 The Local Operator ( Mountaineer Gas Company in Monongalia County) Hazard Communication Model (Emergency Response Preparedness Report, West Virginia, 2008) 32

42 Figure 5 the following critical components of current hazard communiction were chosen for FMEA from 911, fire fighters, general public, local operators, and management. The FMEA shows that 911 need training for the oil and gas pipeline leak, general public need more awareness, fire fighters should also have a printout for the notification, local operator need more training, and eduaction including drill. There is no doubt about that management is responsible for any system failure. 33

43 Failure Modes and Effects Analysis (FMEA) of Current HCS Program Item /Functional Failure Mode Failure Cause Failure Effect Risk Assessment Action Required Identification 911 Miscommunication Lack of knowledge Severity Probability Risk Code Delay the Process Medium 10-2 Low- Medium / Remarks Need Training, Management Control General Public Call Local Operator Lack of Awareness Not Cooperating for Evacuation Lack of Awareness Fire Fighters Misread the Address Pager was Full of Messages Local Operator Unable to Contact ICT, Commander Not Follow the Protocol Management Management s Fault Not taking the Measurement Delay the Process Medium 10-1 Medium- High Delay the Process Medium 10-1 Medium- High Operator Should Call 911 / Need More Awareness Operator Should Call 911 / Need More Awareness Delay the Process Medium 10-5 Low Delete the Messages/Should Also Have Printout Delay the Process Medium 10-1 Medium - High Training, Warning, and Citation Increase Losses Medium 10-3 Medium Follow Hierarchy of Control Figure 5- FMEA Analysis for Proposed HCS Program 34

44 Proposed Protocol The proposed protocol is the result of identifying the deficiencies in the current policies, the consequences of these deficiencies, and strategies for improving the overall hazard communication. Consistent with the discussed deficiencies in the effectiveness of the current hazard communication system, the proposed solution addresses the cause of these deficiencies and provides a method by which 1 st responders will be able to resolve oil and gas pipeline leaks more quickly and accurately. This proposed methodology should be broadly applicable across the United States Elements of Proposed Hazard Communication Protocol The elements of proposed hazard communication protocol are: performing a 911 notification protocol for initial responders, involving the oil and gas company personnel as a first responder with ICT, establishing an incident command team (ICT) and ICT commander, co-coordinating all first responders with time parameter requirements, providing a quick reference guide for first responders, enhancing a hazard communication protocol for the emergency response, identifying specific hazard communication protocol for initial responders and general public awareness, developing better equipment and training for the oil and gas company personnel in deal with emergency response for leaks, partnering up with local county commission and Dot-PHMSA (OPS) for inspection and enforcement, and establishing an accountability at all hierarchy and appropriate consequences for failure. The list of those proposed solutions is: Performing a 911 Notification Protocol for Initial Responders The 911 notification protocol for initial responders should include full response information: o o o Name ( caller) Address (caller) Phone number (caller) 35

45 o o Place of incidence(ask from the caller) Name of oil and gas pipeline company (Emergency Response Preparedness Report, West Virginia, 2008) o o Location of pipeline leak (from the map) A communication medium, by which, OEM and all 1 st responders should be get connected with each other to form an ICT and ICT commander at the time of the incident Initial responders call the fire department and oil and gas pipeline company s personnel to respond to the scene immediately. The 911 center also send an alert about the leak incident to EMS and the police department so as they can be in contact with the ICT commander. As per situation, the ICT commander may ask police or EMS personnel to respond to the incidence scene The local Office of Emergency Management (OEM) should make sure that every local 911 center is aware of the pipeline map system and has secured access for their respective county. The OEM also must also be assured that 911 knows all resources and makes use of them. The local county pipeline map can be acquired from PHMSA s National Pipeline Mapping System, and their website address follows: The local oil and gas pipeline operators can also provide a county map to their respective 911 communication centers. In case of oil and gas pipeline incidents, 911 should be prepared to provide all response information to the first responders. Involving the Oil and Gas Company Personnel as a First Responder with ICT, Oil or gas pipeline leakage has the potential to create a disastrous situation. It is essential that pre-disaster planning prepare oil and gas companies to respond like first responders. Recall that fire brigades have many responsibilities and that there are around 75% of the fire fighters in our country are volunteers. Due to problems associated with volunteer fire fighters such as inadequate training and high 36

46 turnover rate, we cannot solely depend on these firefighters to do the job. Oil and gas pipeline companies know their pipeline system better than anybody else. So, they should respond on time, and if needed, they should shutdown their supply line by closing the control value of that particular pipeline. Establishing an Incident Command Team (ICT) and ICT Commander We are already familiar with the concept of an incidence command post (ICP), which is intended to be the on-site command center, situated nearby the incident site. The ICP is meant to deal with the emergency situation under one commander and in a teamwork environment. However the problem with the current protocol for a response to an oil or gas pipeline leak is that the fire fighters respond first, then the oil company personnel, then the police, emergency medical service (EMS), and other government departments and support groups. The necessary hazard communication is not effectively carried out, and unnecessary delays occur. In order to establish an incidence command team (ICT), it is necessary to convey the message in such manner that promotes a teamwork environment. The hazard communication protocol should be addressed as follows: 911 should notify the fire department and oil or gas company s personnel to respond immediately to the incident scene. Alert messages sent to police and EMS so they can be in contact with the ICT s command post. ICT also establishes a hazard communication link with the local Office of Emergency Management (OEM) for any additional help, if needed, to cope with the incidence of oil and gas pipeline spill/leak. Coordinating all First Responders with Time Parameter Requirements As we have learned, oil and gas leaks/spills have potential for large scale releases. So, the oil or gas will continue to leak/spill unless someone stops the flow by closing the control value. It is very 37

47 important that all first responders should have some kind of time parameter to respond. The fire departments are ahead of the game for their response to such emergencies. Oil and gas pipeline operators should strategically assign their manpower so their response time for leak/spill incidents can be better. One to two hours of response time is unacceptable from pipeline operators. Fifteen minutes to a half hour is recommended for them to be there on the scene. Even during this time, the oil and gas pipeline company s personnel should be in contact with the commander of the incidence command team (ICT). The communication during this time can further help the firefighters to assess and control the situation better. Similarly, other responders such as the police, EMS, and OEM also should be in contact with the commander of ICT. If the situation demanded, then their response should also be time bound. Providing a Quick Reference Guide for First Responders Figure 6 shows a quick references guide that can be used as a pocket guide in case of oil and gas pipeline leak emergencies. The idea is that two first responders are mitigating the risk by doing their part of duty. Since risk is a combination of the exposure duration and the type of hazard, we can reduce the risk either by reducing the exposure (evacuating the people from the leak area) or controlling the hazard (by shutting down the supply of oil or gas). This quick reference guide will assist first responders in their course of action to handle the oil and gas pipeline leak incident successfully. 38

48 For Fire Fighters (receive call from 911) 911 provide all response information For Local Operators (receive call from 911) Is There Oil or Gas Leak Is There Oil or Gas Leak Yes Yes Obtain Proper PPE Avoid Ignitable Source Establish ICT & lines of Communication 1 st MAIN OBJECTIVE: Reduce Human Exposure Small Leak / Spill Isolate the people 330 ft in all directions Large Leak / Spill Evacuate the people half mile all directions 2 nd MAIN OBJECTIVE: Save the Property Control or Restrict the Fire Obtain Proper PPE Avoid Ignitable Source Keep in Contact with ICT Commander MAIN OBJECTIVE: Mitigate the Hazard Small Leak / Spill Conduct repair Large Leak / Spill Shut Down the Supply by Closing Control Valve Figure 6 - Quick Reference Guide Model for First Responders Enhancing a Hazard Communication Protocol for the Emergency Response Flowchart 6 shows a model for a proposed hazard communication protocol during an emergency response for an oil and gas pipeline leak/spill which should be made available to all first responders. In an enhanced hazard communication protocol, all entities involved in the first phase of operation are considered first responders. If one conducts a time motion study for first response of an oil or gas pipeline leak incident, then he should also consider 911 as first responders, because, we cannot improve our response to oil and gas leak incidents without considering the responsibilities of all parties. 39

49 There are three steps to execute the enhanced hazard communication protocol during an emergency response to an oil or gas pipeline leak. The guidelines for this protocol begin with the 911 call, which prompts the notification to all first responders. As soon as the first responders receive the call and get the alert from 911, they should connect with each other through radio/video communication channels and work as a team to respond to the incident. The ICT commander should be determined ahead of time (usually the local fire chief) to reduce confusion of the chain of command. If it is a public concern, then the ICT s command may ask the office of emergency management (OEM) for further assistance. 40

50 Start Receive Call for Oil & Gas Leakage (Caller name, phone, location of leakage) Notify OEM Director/ Deputy Director Notification process (Forward to Ist Responder through automatic System) Call Alert EMS (provide medical aid) Oil / Gas Company (shutoff oil & gas supply, control the leakage problem) Local Fire Department (evacuate, rescue, and control fire) Police Department (restore the law & Order) Pre-planned Task 3 Establish a Incidence Command Team & a ICT Commander Coordination with OEM 4. Initiate the Incidence Control Operation END Flowchart 6 - Proposed Enhanced Hazard Communication Model Identifying Specific Hazard Communication Protocol for Initial Responders and General Public Awareness Table 3 shows the specific hazard communication for all stakeholders. In the case of oil and gas pipelines leak, the routine labeling and material safety data sheets (MSDS) should not be appropriate for first responders and other stakeholders. Obviously, markers are the best option for indicating the 41

51 whereabouts of oil and gas pipelines. However, markers do not show the exact location of the pipeline, instead they dictate the nearby presence of a pipeline in the area. A material safety data sheet (MSDS) is also a vital document for the oil and gas pipelines, and according to Title III hazard communication, it should be with the fire department. But in the first phase of response, it can prove to be lengthy and confusing for the first responders and the other stakeholders. Therefore, Table3 shows that specific hazard communication protocol content should be more of use for all stakeholders in their initial course of action, including markings and other warnings that meet requirements of OSHA hazard communication and EPA s Title III standards. Specific hazard communication could also be used in place of API 1162 public awareness protocol because of its simplicity. Digging is one of the leading causes of pipeline leak problems (Pipeline101, 2007)(ref?). There should be an enhanced communication protocol between the local operator and the excavators, state authority, local municipality, designer, locator, and other stakeholders in pursuant of Public Law Dec. 29,

52 Table 4- Specific Hazard Communication for all Stakeholder WARNING Petroleum Pipelines in Your Neighborhood Oil and gas are highly flammable, explosive, and have oxygen depleting capabilities May cause Physical or Health harm Oil and gas pipeline leaks have potential for Fire, Explosion, Contamination, Pollution hazards Caution: For Crude Oil flammable limits in Air, % by Volume: Lower: 1% Upper: 15% For Natural Gas flammable limits in Air: 5% (lower)15% (upper) Wear proper personal protection equipment (PPE) in the leak area (Source: MSDS) Recognize a Pipeline Leak: Respond to a Pipeline Leak: Local Operator Name and Contact: Smell for: a strong petroleum scent or a strong odor of gas Look for: fire or a dense white cloud or fog or a liquid on the ground near the pipeline Listen for: a hissing sound (Explorer Pipeline Company, 2008). Call: 911 Isolate: for small leak 330ft in all direction Evacuate: for large leak 1/2 mile in all direction (PHMSA, 2008). Warn: others to stay away Don t: drive into a leak area Don t: touch pipeline valves Don t: Light a match, start an engine, use a telephone or a cell phone, or turn on/off any electronics Courtesy from: Buckeye Partners, L.P. 43

53 Developing Better Equipment and Training for the Oil and Gas Company Personnel in Deal with Emergency Response for Leaks As part of emergency preparedness, the oil and gas pipeline company s personnel should be well-equipped to respond to the incident scene. They should have regular training and exercises to deal with oil and gas leak/spill emergencies. There should be annual or bi-annual drill among the firefighters and oil and gas pipeline company s personnel. They can also improve their emergency response planning program by conducting a critique after their drills. Partnering up With Local County Commission and Dot-PHMSA (OPS) for Inspection and Enforcement Figure 10 is the proposed hierarchy of control chart. Since, there are limited numbers of inspectors with PHMSA U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration, PHMSA (OPS) has already partnered with state government for inspection and enforcement. Generally states partners are the offices of the Public Service Commission. However, the local County Commission Office also comes under the State Public Service Commission. The local Office of Emergency Management works under local County Commission Office in order to comply with Title III regulation requirements. The point is that County Commission Offices and the State Public Service Commission can also partner with PHMSA s Office of Pipeline Safety (OPS) to facilitate law enforcement of an oil and gas pipeline safety program. They can inspect and enforce pipeline safety laws and they can also conduct briefing of the oil and gas pipeline leak s incident. If they find that any of the first responders do not meet the enhanced or extended hazard communication protocol, then they can issue a citation to the responsible party. 44

54 PHMSA (OPS) Inspection and Enforcement PHMSA Office of Pipeline Safety (OPS) State Partners (Office of Public Service Commission) Local County Partners County Commission Office Office of Emergency Management 911 Local Office of Emergency Planning 1st Responders & Local Oil and Gas Pipeline Operators Figure 7 - Proposed Hierarchy of Control Chart Establishing an Accountability at all Hierarchy and Appropriate Consequences for Failure All the elements of a proposed hazard communication protocol should be enforced by law and local ordinance, as appropriate. Each and every entity involved in the Figure 7 hierarchy of control should be made accountable for successfully executing the initial response in case of oil or gas pipeline leak and understand the consequences for failure. The accountability part can be incorporated both externally and internally. Externally, if the local county commission make periodic inspection and then they can issue citation for non-compliance with the program. They can also conduct briefing after an incidence and impose fine on the entity that is responsible for its failure. Internally, if the management uses chain of command control to implement the program, then manager, supervisor, employees are responsible for their part of duty and liable to report their respective bosses. The management can also conduct audits to gauge the training and 45

55 knowledge of their personnel for the enhance hazard communication protocol. The management should punish employees for their lack of performances. The last element is added to make the other elements work. For example, in Figure 6, the hierarchy of control model, each department should be controlled by the next department for the implementation of an enhanced hazard communication protocol, and each department is held accountable for their part of the responsibilities (function) in this protocol. If a department does not perform its duty well, then ones can go to next department to complain against them. The other two important things with respect to an emergency plan failure are the knowledge or training of the employees and the consequence if they do not follow the protocol properly. For example, suppose we ask a 911 operator how to find the location of a pipeline through a map, and he replied that he doesn t know. This shows us that even if we have the best plan in place; it will fail when a member of the team has no knowledge or skill for its execution. What you do with him? Warn him, punish him, or terminate him? And what you do when one of players in this emergency plan do not follow one of the protocols of an emergency plan properly. Should he face the consequences for its failure? Can you issue a citation? If not, then we cannot guarantee the success of this emergency plan. 46

56 Summary of Recommendations It should be possible to significantly increase the hazard communication system efficiency by: As shown in Figure 8 & 9 - by changing a process of a series of procedures to parallel procedures Developed new techniques to increase collaboration Development of infrastructure with independent responsibilities Accountabilities to all levels and consequences for failure Infrastructure that facilitates justice system for government law enforcement Faulty processes elimination Barrier to success as shown in FMEA of current Figure 5: Training of first responders including 911 Public awareness Management s fault For the successful execution of the plan as shown in Figure 9: Use Hierarchy of control for inspection and enforcement 47

57 Evaluation of Current Hazard Communication VS Proposed Hazard Communication Program Table 5 signifies current hazard communication protocol for the first responders. It shows that emergency response time for first responder is 205 minutes. Figure 8 Gantt chart denote a series processing protocol of the current system. Table 6 implies that in the proposed protocol, first responders emergency response time decrease to 60 minutes. Figure 9 Gantt chart indicate a parallel processing of proposed hazard communication protocol. Table 5 Current Program Evaluation Time in Minute Table ID Task Name Start Time Duration End Time Receive Call for Leak / Spill Notifies Local Fire Department Fire Depart Responds to Scene Establish Incidence Command Post (ICP) Identify the Hazard Call OEM Call Local Oil/Gas Pipeline Company Evacuate/Isolate the Area Oil & Gas Company Dispatch Personnel to the Incident 11 Company Personnel Controls the Leak Fire Depart Controls Fire Total Time

58 Figure 8 Current Program Evaluation Gantt chart 49

59 Table 6 Proposed Program Evaluation Time in Minute Table ID Task Name Start time Duration End Time Receive Call for Oil and Gas Leakage notification process st responders report to ICT's Commander Initiate the Incidence Control Operation by The first responders: Fire Department Police Department EMS Oil / Gas Company's Personnel Total Time 60 50

60 Figure 9 Proposed Program Evaluation Gantt Chart 51

61 SUMMARY AND CONCLUSIONS The main purpose of this study was to determine that if an oil or gas pipeline leak occurs, then: What kind of system is currently in place? What do the entities (first responders) who are involved do? What are present pipeline rules, regulations, and safety programs? What are some of the problems with current practices? What are possible solutions to these problems? In regards to the current system, the government and the operators were considered to be responsible for any oil or gas pipeline leak. The involvement of these and other regulatory entities were evaluated, in part through oil and gas pipeline statistics from s identified as fatalities, injuries, and property damages. The oil and gas pipeline industry recorded a significant number of incidents between 1988 and 2008, and the causes of these incidents were shown to still be relevant today, despite operational and government mitigation efforts. The present pipeline rules, regulations, and operators safety programs were evaluated and they were used to identify problems with current practices, from which a solution is proposed to directly meet these observed challenges. Findings The findings of the study were made as follow: In section for Emergency planning for accidents, it is required that the emergency planning program information should be shared with supervisor in charge of that department However, first operators emergency planning should be enhanced in order to meet the challenge of potential danger of a pipeline that they are imposing on community living by oil and gas pipeline. In section that stipulate that each operator must prepare or maintain material safety data sheets (MSDS). MSDS is good source of safety information about oil and gas and should be carried 52

62 by 1 st responder. However, in an emergency or in the first phase of response, MSDS can become confusing document because of its length and amount of contents it has. Instead, the first responders should also have some kind of quick reference or markers and warnings document to on time handling of the situation of incident of an oil or gas pipeline leak. Making an emergency plan is important, because by this way operators can meet one of the requirements of Title III law. However, there is no accountability and no consequences if no one follows those plans properly. API RP 1162, it appears that it is a good, 70-page, technical document. It also has wellestablished guidelines for all four stakeholders: the affected public, emergency officials, local public officials, and excavators good, general training material for these stakeholders. Because of its lengthy message, this document could tend to confuse the first responders and all others stakeholders, decreasing the effectiveness of the response that is needed in the first phase of an oil or gas pipeline leak incident. 911 personnel have very limited knowledge for dealing with the emergency of oil and gas pipeline incidents. Their notification protocol does not enhance the teamwork environment. Approximately 72 to 75% of firefighters are volunteers in our country. There is also the issue of training with volunteer firefighters. Execution of present series process practices by the 1 st responders in response to oil or gas pipeline leak incidence is proved to be more time consuming and could not institute teamwork environments A strong inspection and enforcement mechanism is needed to mitigate the losses from pipeline leak incidence. Hierarchy of control can provide such a platform for successful execution of the emergency plan 53

63 Recommendations Recommendation for Management Use management tools such chain of command control, audit, and reward and punishment performance for the successful execution of proposed enhanced hazard communication program. Recommendations for Local Operators 1. Train your emergency personnel in proposed enhanced hazard communication protocol 2. Incorporate a bi-annual drill with the fire department and other responders for a successful execution of emergency plan in case of real life emergencies 3. Respond as one of the first responders for the sake of public safety and to reduce your own losses Recommendations for DOT-PHMSA s Office of Pipeline Safety 1. Mandate proposed enhanced hazard communication program to mitigate significant losses 2. Incorporate hierarchy of control to strengthen the inspection and enforcement process 54

64 Works Cited Alabama Gas Pipeline Safety Seminar: U.S. DOT/PHMSA Southern Region. (2007, December 11). Retrieved October 7, 2009, from DOT - PHMSA: API. (2008, July 28). API: Pipeline Standards Committees. Retrieved July 20, 2009, from American Petroleum Institute: Emergency Response Preparedness Report, West Virginia. (2008). Pipeline Emergency Response Planning Information. Wichita, KS: Paradigm Liaison Services, LLC. Explorer Pipeline Company. (2008). Recognizing & Responding to a Pipeline Leak. Retrieved June 11, 2009, from Explorer Pipeline: CFD, Local (2009, May 22). Morgantown Fire Department. (M. Malik, Interviewer) (1992). Explanation of the Hazard Communication Standard. In C. A. Francis, HAZARD COMMUNICAIOTN HANDBOOK - A Right- to- Know Compliance Guide (pp. 1-3, 2-1). DEERFIELD IL. NEW YORK NY. ROCHESTER NY: CLARK BOARDMAN CALLAGHAN. Gas Operators and Public Awareness. (2008, January 22). Retrieved June 20, 2009, from Enviro.BLR.com: Grant, D. C. (2006, October 17). Hazard Communication (HazCom). Retrieved June 3, 2009, from Safety in the Chemistry Laboratory: HSE. (2009, July 3). OTH Pipeline leak detection study. Retrieved July 20, 2009, from Health and Safety Executive: Inc., 2. L. (2009, June). Hazardous Chemical Label. Retrieved June 3, 2009, from Industrial & Safety Supplies: 55

65 Inslee, J. (2007, October 2). Issues - Statistics on Pipelines. Retrieved July 8, 2009, from Jay Inslee: Jack, W. Snook, J. D. (2006). History and Background, Problems Utilizing Volunteers. In J. D. Snook, Recruiting, Training, And Maintaining Volunteer Fire Fighters (pp. 1, 5-12). Sudbury, MA: Jones and Bartlett Publishers. Johnson, B. B. (1987). Accounding for the Social Context of Risk Communication. Science & Technology Studies, Vol. 5 No. 3/4, Karter, M. J. Jr. (2008, November). U.S. Fire Department Profile Through Retrieved July 20, 2009, from NFPA: Krupenio, N. N. (1995). Mapping of segments polluted by petroleum products in the usinsk region of the Komi republic from remote-measurement data. Power Technology and Engineering (formerly Hydrotechnical Construction), 648. Lowry, G. G. (1985). Handbook of Hazard Communication and OSHA Requirements. Michigan: Lewis Publishers Inc. Magnussen, N. (1997, August 2). Introduction - Hazardous Materials Transportation Act. Retrieved June 18, 2009, from College of Science, Texas A&M University: MECCA 9-1-1:Telecommunicator Training. (2009, November 19). Retrieved December 6, 2009, from MECCA 9-1-1: Monongalia Emergency Centralized Communications Agency. (2008). Retrieved June 15, 2009, from MECCA 911: Moyer, A., Francis. Hazard Communication Handbook: a right to compliance guide. Deerfield: Clark Boardman Callaghan,

66 NFPA. (2008). NFPA 1001: Standard for Fire Fighter Professional Qualifications. Retrieved October 9, 2009, from NFPA: NFPA. (2009). NFPA 704. Retrieved June 3, 2009, from National Fire Protection Association: NPMS. (2007). Retrieved December 5, 2009, from PHMSA: National Pipeline Mapping System: NTSB. (2005). Pipeline Accident Brief: Natural Gas Service Line Break and Subsequent Explosion and Fire. Bergenfield: NTSB. Office of Pipeline Safety Communications. (2009, May 4). PHMSA Stakeholder Communication: Public Awareness Programs. Retrieved June 20, 2009, from PHMSA Pipeline Safety Program: OPS, Analysis of Facility Respnse Plan Review Finding: Final Report. (1999, April 30). Retrieved June 11, 2009, from PHMSA: CFR RESPONSE PLANS FOR ONSHORE OIL PIPELINES:. (2009, July 7). Retrieved July 7, 2009, from SETON: Patin, S. t. (2009, July). Oil and gas accidents during the offshore exploration and production. Retrieved July 30, 2009, from Offshore-enviroment.com: PHMSA. (2007, August 14). PHMSA - Federal and State Partners. Retrieved September 23, 2009, from PHMSA Web site: PHMSA. (2008, August 14). ERG PHMSA. Retrieved October 7, 2009, from PHMSA - US DOT: PHMSA Stakeholder Communications: Safety Standards:. (2009, May 4). Retrieved July 07, 2009, from PHMSA Pipeline Safety Program: 57

67 Pipeline101. (2007, November 12). Preventing Pipelines Emergencies. Retrieved December 9, 2009, from Pipeline101: PSC. (1999, September 15). Retrieved December 6, 2009, from Public Service Commission: Ronald A. Kyle, Shaunda Y. Rauch. (2008, 09 1). Monongalia County OEM [PowerPoint]. Retrieved June 15, 2009, from Monongalia County Office of Emergency Management: OEM, Local (2009, May 28). Protocol of Monongalia County's Office of Emergency Management. (M. Malik, Interviewer) Shell Oil Company. (2007, 3 1). From Source to The Pump. Weekly Reader Corporation Custom Publishing, pp United Nations Economic Commission for Europe. (2009, August). UNECE. Retrieved August 5, 2009, from United Nations Economic Commission for Europe web site: U.S. Department of Labor Occupational Safety and Health Administration. (1995). Employee Information and Training. In O. 3111, Hazard Communication Guidelines for Compliance (pp ). Washington, DC: U.S. Government Printing Office. United States Department of Labor - Occupational Safety and Health Administration. (n.d.). Regulations (Standards - 29 CFR): Hazard Communication Retrieved March 28, 2009, from OSHA: 58

68 West Virginia Tier 2 Sections Summary. (2008, April 10). Retrieved June 15, 2009, from West Virgina Division of Homeland Security and Emergency Management: Zechauser, E. K. (1996). Hazard Communication: Warnings and Risk. Annals of the American Academy of Political and Social Science, Vol. 545, Challenges in Risk Assessment and Risk Management,

69 APPENDIX A National All Pipeline Systems: Significant Incidents Summary Statistics: Year Number Fatalities Injuries Property Damage (A)(B) Gross Barrels Lost Net Barrels Lost (C) $81,290, , , $53,649, , , $46,900, ,827 54, $76,660, ,210 55, $92,248, ,769 68, $84,669, ,132 57, (D) 120 $204,554, , , $64,943, ,931 52, $139,924, , , $94,744, , , $149,827, ,348 60, $153,020, , , $221,214, ,614 56, $67,951,894 98,046 77, $113,731,682 95,663 77, $135,834,910 80,041 50, $274,554,732 88,145 68, (E) $1,093,807, ,052 45, $132,348, ,500 53, $133,902,406 89,894 68, $410,298, ,932 95,442 Totals 6, ,805 $3,826,079,185 2,882,333 1,603,368 5 Year Average ( ) 10 Year Average ( ) 20 Year Average ( ) $354,089, ,327 57, $247,619, ,039 66, $170,789, ,820 75,396 (Source: PHMSA significant incidents files April 15, 2009) 60

70 APPENDIX B The Hazard Communication Standard 29 CFR is divided into six subparts (Grant, 2006) which are as follow: 29 CFR (f) Chemical Labeling - this standard requires that all kind of chemicals in the workplace must be labeled. This information should include the name of the chemical and warnings about any hazards that material may possess. The OSHA Hazard Communication Standard (HCS) mandates labeling of all chemicals in the workplace so as to warn of any hazards these chemical possess. However, there is no specific guide of labeling presented in the HCS. This requirement may be implemented in many ways. There are two systems, the NFPA Hazard Identification System and the Hazardous Materials Identification Guide, which are most commonly used. NFPA 704 Hazard Identification System NFPA 704 standard provides a quickly recognized and easily understood system for identifying hazards and their severity by using visual, spatial, and numerical methods (NFPA, 2009). The system is represented by the "diamond shape that is color-coded as: Blue for health, red for flammability, and yellow for instability. This diamond identifies the hazards of a material and the degree of hazard severity for health, flammability, and instability. Hazard severity can be shown by a numerical rating thatranges from zero (0) value which is a minimal hazard, to four (4), severe hazard. The hazards are also arranged spatially in the diamond shape which issued to Figure 5 - NFPA Hazardous Material Label 61

71 distinguish the hazards as follows: Health at nine o'clock position Flammability at twelve o'clock position Instability at three o'clock position The six o'clock position on the symbol represents special hazards and has a white background. The special hazards in use are W, which shows reactivity with water and is a caution about the use of water in either fire fighting or spill control response, and OX, is for oxidizer materials. The only authorized symbols are the W and OX symbols mentioned above. The NFPA wanted to keep the number of symbols low for the purpose of emergency visibility and simplicity. Other symbols are taken care of under health, flammability. It is important to note that the NFPA 704 rating system is only applicable to industrial, commercial, and institutional facilities that manufacture, process, use, or store hazardous materials. It is important to note that the NFPA 704 standard is not applicable to transportation or for use by the general public. The NFPA 704 system is often confused with the placarding required by the Department of Transportation for hazardous materials. The NFPA 704 standard is also not applicable to non-emergency occupational or to chronic exposures. Hazardous Materials Identification Guide The Hazardous Material Identification Guide (HMIG) is a labeling system developed and sold by Lab Safety Supply Inc. This system uses four color-coded bars and a space on the top of the label. The blue represents a health hazard, red color for flammability, and reactivity hazard is associated with yellow color. These color-coded bars use a numbering scale from 0-4. A zero value signifies no Figure 6 Hazardous Material label 62

72 hazard, whereas a rating of 4 represents an extreme hazard (Inc., Lab Safety Supply2009).The white portion marked with Personal Protection and a check list to show what kind of personal protective equipment (PPE) should be used to handle the material safely. 29 CFR (g) Material Safety Data Sheets (MSDS) - A MSDS is a document that provides detailed information about a material and any associated hazard with it. A MSDS must be readily available to employees at workplaces where hazardous materials are used. The HCS specifies three responsibilities with the MSDS: The manufacturer is responsible for determining the hazard associated with the material and to prepare and provide MSDS for the material to any recipient. The employer is responsible for providing MSDS and training to the employee. MSDS for hazardous materials must be readily available at the workplace. The employee is responsible for reading and understanding MSDS for any kind of chemical used on the job site. OSHA stipulates that the MSDS must be in English and consist of at least the following information (Francis, 1992): Section I Manufacturer s name and address with its telephone number for emergency contact and information and the date of preparation Section II Hazardous ingredients including component applicable exposure limit and or threshold levels Section III Physical and chemical hazards Section IV Fire and explosion hazard data Section V Reactivity data Section VI Health hazard data Section VII Precautions for safe handling and use Section VIII Control measures. 63

73 29 CFR (d) Hazard Determination The employer must identify and maintain a list of all hazardous chemicals used in their workplace. 29 CFR (e) Written Implementation Program - Requires that the employer must develop a written plan, a Hazard Communication Program, which shows how the requirements of the HCS are being implemented by the employer. 29 CFR (h) Employee Training - Requires that the employer provide to the employees training covering handling of hazardous materials, use and interpretation of both MSDSs and haz-com labels, and information about the HCS. In order to meet the requirements of employee training, the following things need to be taken into account (U.S. Department of Labor Occupational Safety and Health Administration, 1995): Designation of person who is responsible for administrating training Designing the set-up of the training program to be used Training program s elements should be in compliance with paragraph (h) of the HCS Procedure to train new hires before assigning them to work with hazardous chemical and training of employees when a new hazard is brought in the workplace 29 CFR (i) Trade Secrets Dictates the conditions under which a manufacturer may withhold information about a material and the conditions under which such information must be disclosed to health care providers. 64

74 APPENDIX C 65

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