Carbon Dioxide (CO2)

Emergency Response
Tactical Guidance Document
Best Practice Guidelines for Preparedness
and Initial Response to a Pipeline Release
of Carbon Dioxide (CO2)

AUGUST 2023
(UPDATED NOVEMBER 2023)

This guide was developed by the American Petroleum Institute and the Liquid Energy
Pipeline Association with input from the National Association of State Fire Marshals.
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Introduction
This field operations guide is not an educational or decision-making tool. This guide contains a set of
operational tools and references to assist in the response to a pipeline release of carbon dioxide (CO2).

The priorities for CO2 response are:

People: safety of response personnel and the public;

Environment: prevention of environmental, human health, and welfare effects;

Assets: minimizing damage to structures and equipment; and

Relations: keep customers, community, and federal, state, and local government agencies informed.

Responder safety and health should never be compromised for tactical considerations. Likewise, CO2
release response should be conducted to maximize safety around health impacts to responders, the public,
and the surrounding areas of a release. For the purpose of this report, we are limiting the response effort
to supercritical transmission pipelines.

Intended Audience
This guide is intended for pipeline operators and response operations personnel having basic knowledge
in emergency response.

Current Applicable Federal Regulations

40 CFR 195, Transportation of Hazardous Liquids by Pipeline

Additional Resources

— API Recommended Practice 1162, Public Awareness Programs for Pipeline Operators

— API Recommended Practice 1174, Recommended Practice for Onshore Hazardous Liquid Pipeline
Emergency Preparedness and Response

— DOT/PHMSA Emergency Response Guidebook (ERG)

— CDC/NIOSH Pocket Guide to Chemicals

NOTE Additional state or local regulations may apply.

iii
Acronyms and Abbreviations

ACGIH American Conference of Governmental Industrial Hygienists

AEGL Acute Exposure Guideline Level
CASRN CAS Registry Number
CCS carbon, capture, and storage
CFD computational fluid dynamics
CFR Code of Federal Regulations
CO2 carbon dioxide
CPM computational pipeline monitoring
EOR enhanced oil recovery
ERPG emergency response planning guidelines
HAZCOM hazardous communication
HAZWOPER OSHA’s Hazardous Waste Operations and Emergency Response Standard
HCA high consequence areas
HSE health, safety, and environment
HVL highly volatile liquid
ICS Incident Command System
IDLH immediately dangerous to life or health
LEPC local emergency planning committee
NCEI National Centers for Environmental Information
NIMS National Incident Management System
NIOSH National Institute for Occupational Safety and Health
NOAA National Oceanic and Atmospheric Administration
NRC National Response Center
O2 oxygen
OSHA Occupational Safety and Health Administration
OSRO oil spill removal organization
PAC protective action criteria per SCAPA (see below)
PEL permissible exposure limit
PHMSA United States Pipeline and Hazardous Materials Safety Administration
PPE personal protective equipment
PPM part per million
PREP Preparedness for Response Exercise Program
PSI per square inch
REL recommended exposure limits
ROW right of way
SAR supplied air respirator
SCADA Supervisory Control and Data Acquisition
SCAPA U.S. Department of Energy’s Subcommittee on Consequence Assessment and
Protective Actions
SCBA self-contained breathing apparatus
STEL short-term exposure limit
TEEL temporary emergency exposure limit
TLV threshold limit values per ACGIH (see above)
TWA time-weighted average

iv
Contents
Page
Introduction ................................................................................................................................................ iii
Intended Audience ..................................................................................................................................... iii
Current Applicable Federal Regulations ................................................................................................. iii
Additional Resources ................................................................................................................................ iii
Acronyms and Abbreviations ................................................................................................................... iv
1 Transportation of Carbon Dioxide (CO2) in Pipelines ...................................................................... 1
2 Characteristics of CO2 ......................................................................................................................... 2
2.1 Physical Hazards ............................................................................................................................. 2
2.2 Oxygen Displacement ..................................................................................................................... 4
2.3 Exposure Limits ............................................................................................................................... 4
3 Emergency Preparedness and Planning ........................................................................................... 6
3.1 Community/Stakeholder Outreach and Liaison ........................................................................... 6
3.2 Response Drills and Exercises ...................................................................................................... 7
3.3 Training ............................................................................................................................................. 7
4 Dispersion Modeling Best Practices................................................................................................ 10
5 CO2 Pipeline Leak Detection & Identification .................................................................................. 12
5.1 Physical Identification ................................................................................................................... 12
5.2 Remote Identification .................................................................................................................... 13
5.3 Supplemental Identification Methods .......................................................................................... 13
6 Internal Notification Protocols ......................................................................................................... 14
7 Reportable Release Thresholds ....................................................................................................... 14
8 Public Safety Answering Point Notification of CO2 Pipeline Release .......................................... 16
8.1 Information to Provide to First Responders During Agency Notifications ............................. 16
9 Third-party Notification of a CO2 Pipeline Release ......................................................................... 17
10 CO2 Pipeline Release Response Actions......................................................................................... 17
10.1 Emergency Responder Safety ...................................................................................................... 18
10.2 Isolation Strategies........................................................................................................................ 19
10.3 Real-time Plume Predictions and Surveillance .......................................................................... 22
10.4 Air Monitoring Strategies .............................................................................................................. 22
10.5 Incident Management .................................................................................................................... 24

Figures
1 Examples of Uses of CO2…………………………………………………………………………………….1
2 Phase Diagram of Carbon Dioxide ..................................................................................................... 2
3 Day Dispersion during Blowdown Operations ................................................................................. 3
4 Night Dispersion during Blowdown Operations ............................................................................... 3
5 Transport and Dispersion of Released Carbon Dioxide on Flat Land ......................................... 11
6 Transport and Dispersion of Released Carbon Dioxide with Topographical Features…………12
7 Incident Reporting Criteria ............................................................................................................... 15
8 Icing of Flanges During a Release ................................................................................................... 18
9 Controlled Venting Operations......................................................................................................... 21
10 Forced Air Displacement Using a Trailer-mounted Fan ................................................................ 22
11 Planning P .......................................................................................................................................... 24
 Best Practice Guidelines for Preparedness and Initial Response
to a Pipeline Release of Carbon Dioxide (CO2)

1 Transportation of Carbon Dioxide (CO2) in Pipelines

CO2 transportation pipelines have been operating safely in the United States for decades. CO2 is typically
transported in the dense phase as a supercritical fluid, typically at pressures higher than 1,000 psi. It may
also be transported in the gaseous phase in a pipeline. There are thousands of miles of CO2 pipelines,
ranging from 8 in. to 36 in. in diameter. This CO2 is used for enhanced oil recovery (EOR); carbon capture,
and storage (CCS); and other commercial and industrial purposes.

Various Uses of CO2

Dry ice Used as a refrigerant during shipping of perishable products such as meats or ice cream
Fire extinguisher Used to displace oxygen to extinguish a fire
An inflatable life jacket contains a small cylinder of compressed CO2 used for rapid
Life jackets
inflation
Carbonated Used in soda products as a protective measure that keeps the soft drink fresh and
beverages prevents the growth of bacteria in the liquid while stored
Enhanced oil The injection of CO2 into existing oil fields increases the overall pressure of the oil
recovery reservoir, forcing the oil toward production wells
Carbon capture and CO2 emissions are captured from industrial processes, then transported to and stored in
storage deep, underground geological formations

Figure 1—Examples of Uses of CO2

2 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

2 Characteristics of CO2

In its purest form, CO2 is a nonflammable, colorless, and odorless gas. Depending on temperature and
pressure conditions, CO2 can exist in a gas, liquid, or solid state. When pressures and temperature exceed
the critical point, such as in supercritical pipelines, the gas phase and liquid phase become
indistinguishable.

Figure 2—Phase Diagram of Carbon Dioxide

Atmospheric CO2 is derived from many natural sources, including volcanoes, forest fires, respiration, and
the decomposition of organic material by bacteria. Cars, trucks, industrial equipment, and burning fuel for
power plants are some of the major man-made contributors to carbon dioxide in the air.

Airborne CO2 concentrations are easy and inexpensive to measure. Carbon dioxide is not generally found
at hazardous levels in outdoor environments, yet it is often measured when trying to determine indoor air
quality because it is a good surrogate measure of how well natural and mechanical ventilation systems are
working. If the levels of carbon dioxide are elevated, it is assumed that there may not be adequate
ventilation to that area, which in turn may allow for buildup of other environmental pollutants.

Human exposure to CO2 occurs constantly. It is a regular by-product of cellular respiration, and the CO2
content of normal fresh air varies between approximately 0.03 % (300 ppm) and 0.06 % (600 ppm).

2.1 Physical Hazards

During a release of CO2 from a pressurized pipeline to the atmosphere, the dramatic change of pressure
at the release point will cause rapid large-scale expansion of the CO2, which generates a refrigeration effect.
This can produce an opaque water vapor cloud, which may be dispersed by the wind. However, due to the
density of CO2, during cool and humid conditions with little to no wind, the CO2 could accumulate in low-
lying areas, such as valleys and ditches. This water vapor cloud can significantly reduce visibility, especially
during nighttime hours, making driving or walking through the CO2 release hazardous.
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 3

At the release point, CO2 can present a dermal hazard to those coming into contact with the extremely cold
released product or adjacent piping and equipment. After exiting the release point and warming up to
ambient temperatures, the opaque water vapor cloud will dissipate. Since CO2 is colorless, it may still be
present. In dry, arid climates, an opaque water vapor cloud may not develop at the release point due to the
lack of humidity in the atmosphere.

In general, day conditions allow for greater turbulent mixing and dispersion caused by solar intensity, winds,
and lower relative humidity. Calm night conditions lead to far less dispersion and are considered to yield
the worst-case air concentrations of CO2.

Meteorological Effects on Physical Hazards

Potential Hazards
Scenario Reduced Accumulation of
Dermal Hazards
Visibility CO2 in Low Areas
Daytime, sunny, with winds
X
greater than 10 mph
Daytime, cloudy, humid, with
X X
winds less than 3 mph
Nighttime, with winds greater
X X
than 10 mph
Nighttime, humid, with winds
X X X
less than 3 mph

Figure 3—Day Dispersion during Figure 4—Night Dispersion during

Blowdown Operations Blowdown Operations
4 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

2.2 Oxygen Displacement

When released in large quantities, such as in the case of a pipeline rupture, CO2 can physically displace
the other components of ambient air and reduce the amount of available oxygen. Normal oxygen
concentration is 20.9 % of ambient air, with the balance consisting primarily of nitrogen, water vapor, trace
gases, and other gases and particulates present due to local geography and ambient air quality. Oxygen
concentration needed for normal body function is at least 19.5 % of inhaled air. As oxygen levels fall below
19.5 %, physiological compensation results in higher breathing rates and higher cardiac output through
increased heart rate. However, as oxygen levels drop further, decreased physical coordination and impaired
mental acuity increase. At oxygen levels of 6 % to 10 %, nausea, vomiting, and lethargy increase markedly
to the point of unconsciousness. Oxygen levels of less than 6 % will result in cessation of breathing,
convulsions, cardiac arrest, and death.

Atmospheric Hazard Action Levels

Action Required by Responders if
Analyte Acceptable Levels
Outside Acceptable Levels
Evacuate to fresh air or supplied air
Oxygen (O2) 19.5 %-23.5 %
respirator (SAR) or SCBA

2.3 Exposure Limits

The American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values (TLVs) are
shown in the table below. Although the TLVs are intended for occupational daily work shift exposures over
an entire working lifetime, the current ACGIH TLV-time-weighted average (TLV-TWA) for CO2 (5,000 ppm)
is based on the lack of inhalation toxicity data in humans at this level and the ACGIH TLV-short-term
exposure limit (STEL) for CO2 is 30,000 ppm.

ACGIH TLVs
Product Name CASRN Units
TWA (8 hr)a STEL (15 min)b

Carbon dioxide 124-38-9 5,000 30,000 ppm

SAR or SCBA
Action Required for Evacuation to fresh air or
(if longer than
Responders SAR or SCBA
eight hours of exposure)

a) ACGIH TLV-TWA: Threshold limit value-time-weighted average (TLV-TWA). The TWA concentration
for a conventional eight-hour workday and a 40-hour workweek, to which it is believed that nearly all
workers may be repeatedly exposed, day after day, without adverse effect (ACGIH, 2023).

b) ACGIH TLV-STEL Threshold limit value-short-term exposure limit (TLV-STEL). A 15-minute TWA
exposure that should not be exceeded at any time during a workday, even if the eight-hour TWA is
within the TLV-TWA. The TLV-STEL is the concentration to which it is believed that workers can be
exposed continuously for a short period of time without suffering from 1) irritation, 2) chronic or
irreversible tissue damage, 3) dose-rate-dependent toxic effects, or 4) narcosis of sufficient degree to
increase the likelihood of accidental injury, impaired self-rescue, or materially reduced work efficiency.
Exposures above the TLV-TWA up to the TLV-STEL should be less than 15 minutes, should occur not
more than four times per day, and there should be at least 60 minutes between successive exposures
in this range (ACGIH, 2023).
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 5

The National Institute for Occupational Safety and Health (NIOSH) has recommended exposure limits
(RELs) for CO2 that mirror the TWA and STEL of ACGIH, although NIOSH also has a listed IDLH
(immediately dangerous to life or health) of 40,000 ppm. OSHA’s permissible exposure limit (PEL) for CO2
is 5,000 ppm.

NIOSH REL
Product Name CASRN Units
TWA (10 hr) STEL (15 min) IDLH

Carbon dioxide 124-38-9 5,000 30,000 40,000 ppm

SAR or SCBA
(if longer than Evacuation to fresh air or SAR
Action Required for Responders
10 hours of or SCBA
exposure)
6 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

3 Emergency Preparedness and Planning

3.1 Community/Stakeholder Outreach and Liaison

Operators transporting CO2 through pipelines are required to conduct outreach and awareness efforts for
specific areas along the pipeline’s route. A CO2 release and the subsequent response will present unique
circumstances that will likely differ from responses to more common products, such as natural gas, crude
oil, gasoline, etc. It is important to educate the stakeholders on these unique circumstances so that they
will be more likely to identify a release of CO2 and assist in enacting the proper response procedures.
Stakeholders may include, but are not limited to:

— affected public;

— local emergency managers;

— fire department, law enforcement, local emergency planning committees (LEPCs);

— hazardous materials response team (HAZMAT);

— excavator/contractor;

— public officials.

Operators should also become familiar with potential public gathering centers such as schools, hospitals,
etc., along their pipeline rights-of-way (ROWs) and proactively develop a plan of action for a large-scale
pipeline release with local emergency response officials. When developing a course of action with local
emergency response officials, the following should be considered:

— ability to safely evacuate people from the school, hospital, or other place of gathering;

— visibility limitations caused by the dense vapor cloud and risk of driving or walking into the vapor cloud;

— potential of vehicles stalling in the dense vapor cloud and increasing exposure to the released CO2;

— effectiveness of sheltering in place, making sure people stay off the ground or move to an upper floor
of a building and not into a basement or low area where CO2 may enter a building and collect;

— communicating with and educating emergency response personnel that may be stationed outside of
your area for public awareness but could ultimately respond to a release from your pipeline.

It is common for members of the public to be the first to discover surface releases in or around ROWs or
facilities. Federal regulation requires pipeline operators to develop and implement a written continuing
public education program 1. One of the traditional methods of achieving this is through the mailing of
flyers/postcards with educational information about the location, product, and ownership of pipelines in a
given geographic area.

Each pipeline operator is required to place and maintain line markers over each buried pipeline in a
sufficient number along the line so that its location is accurately known, and also at each public road and
railroad crossing 2. Additionally, each operator shall provide line marking at locations where the line is above
ground in areas that are accessible to the public. The marker must contain the word “Warning,” “Caution,”

1
49 CFR § 195.440
2
49 CFR § 195.410
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 7

or “Danger” followed by the words “Carbon Dioxide Pipeline,” and include the name of the operator and a
telephone number where the operator can be reached at all times.

For more information, refer to API Recommended Practice 1162, Public Awareness Programs for Pipeline
Operators.

3.2 Response Drills and Exercises

One of the means of ensuring the proper communication of emergency response procedures is to drill them
with pipeline operators and the applicable emergency responders for a given scenario, as required for high
consequence areas (HCAs) 3. Drills and exercises are great ways of ensuring pipeline operators are
prepared and rehearsing needed response actions with emergency responders that would likely be
responding to a pipeline release.

Although only applicable for oil pipelines (49 CFR 194), the National Preparedness and Response Exercise
Program (PREP) Guidelines outline a PHMSA-endorsed drill and exercise program that can prove effective
if adopted by CO2 pipeline operators, especially if it is used beyond the HCAs of the pipeline system.

The PREP Guidelines identify a format for qualified individual drills (per requirements of OPA 90 that are
not applicable to CO2 pipelines) that can be used to achieve the exercise requirements of control room
operator emergency procedures 4. Exercises can be conducted that test collaboration between pipeline and
control room operators as it relates to emergency response procedures. These exercises should be
documented per the PREP Guidelines.

Similarly, such collaboration can be exercised by the PREP Guidelines’ format for a tabletop exercise,
where designated emergency response team members should demonstrate adequate knowledge and
understanding of their response procedures and the ability to organize, communicate, coordinate, and
respond in accordance with those procedures. When coupled with applicable emergency response officials,
they facilitate the initiation and demonstration of the use of a unified command, consistent with the Incident
Command System. These exercises can help identify opportunities for improvement of the emergency
procedures, understand the response capabilities of the applicable emergency response agencies, allow
for cross-education between your organization and the applicable emergency response agencies, and allow
for proper coordination of response efforts as required for HCAs.

Type of Drill Frequency Attendees

Internal
Quarterly Controllers, emergency response team members
notifications/tests
Controllers, emergency response team members, third-party response
Tabletop exercise Annually
organizations, local, state, and federal emergency response officials*
* Full-scale exercises with federal, state, and local emergency response officials are recommended at least once every three years.

Adoption of a formal drill and exercise program can help to achieve the training requirements of 49 CFR
195.403 highlighted in the following section.

3.3 Training

Pipeline operators must have a training program that covers the roles and responsibilities outlined in the
emergency response plan designated for their pipeline operations. As per 49 CFR 195.403, each operator
shall establish and conduct an annual training program to instruct emergency response personnel to:

3
49 CFR 195.452
4
49 CFR 195.446(h)(6)
8 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

1) carry out the emergency procedures established under 195.402 that relate to their assignments;

2) know the characteristics and hazards of CO2;

3) recognize conditions that are likely to cause emergencies, predict the consequences of facility
malfunctions or failures and CO2 releases, and take appropriate corrective action;

4) take steps necessary to control any accidental release of CO2 and to minimize the potential impacts
to the public; and

5) learn the potential causes, types, sizes, and consequences of a leak, involving, where feasible, a
simulated pipeline emergency condition.

In addition to the above listed items, pipeline operators should provide training on topics that will be
leveraged during the response to a pipeline emergency. Those trainings should include, but are not limited
to the following:

Training Frequency
Hazardous waste operations and emergency response (HAZWOPER) One time, then annual refresher
technician level
Incident command system (ICS) One time, then routine refresher
Use of portable air monitoring/gas detection equipment* Annual
Proper use of personal protective equipment* Annual
Hazard communication (HAZCOM)* Annual
Respiratory protection Annual
First aid/CPR Biennial
* Can be included in or conjunction with HAZWOPER training.

Hazardous Waste Operations and Emergency Response Standard (HAZWOPER)

OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard applies to five
distinct groups of employers and their employees, one of which is emergency response operations for
releases of, or substantial threats of releases of, hazardous substances regardless of the location of the
hazard. Personnel who are engaged in emergency response to hazardous substance releases should be
trained on a pre-written emergency response plan that addresses pre-emergency planning and
coordination with outside parties, personnel roles, lines of authority, training, communication, emergency
recognition and prevention, safe distances and places of refuge, site security and control, evacuation routes
and procedures, decontamination, emergency medical treatment and first aid, emergency alerting and
response procedures, personal protective equipment (PPE), and emergency equipment along with critique
of responses and necessary follow-up should the plan be enacted 5. The HAZWOPER standard notes that
four people are required for an emergency response in an unknown or potentially IDLH atmosphere. This
regulation also calls out the use of the Incident Command System in its procedures for handling an
emergency response. Specific training requirements for personnel within an organization are also defined 6.
While HAZWOPER identifies different training levels and requirements, it is recommended that operators
expected to respond to a pipeline-related incident involving CO2 be trained to at least the Hazardous
Materials Technician level.

5
29 CFR 1910.120(q)
6
29 CFR 1910.120(q)(6)(I)
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 9

The table below describes the best means to achieve HAZWOPER Hazardous Materials Technician
training in preparation for a CO2 pipeline release.

HAZWOPER Applicable Training

Best Ways to Achieve or Verify
Training Level Requirements
Training and review of applicable
response plans or procedures with
Know how to implement employer's
all response personnel through
emergency response plan.
classroom training and/or drill
participation.
Know the classification,
Detailed overview of CO2 hazards;
identification, and verification of CO2
review of past incidents, discuss
by using gas detection equipment;
identifiers of a CO2 release, and the
understand basic chemical and
fate of released products in the
toxicological terminology and
atmosphere; training on the use of
behavior of CO2; understand hazard
air monitoring equipment.
and risk assessment techniques.

Hazardous Incident command system training

Materials for all response and management
Technician personnel that could respond to a
Be able to function within an pipeline-related incident; ICS-100
assigned role in the Incident (Introduction to the Incident
Command System. Command System); ICS-200 (Basic
ICS for Initial Response); and ICS-
300 (Intermediate ICS for
Expanding Incidents).
Training on applicable response
Be able to perform advanced
procedures associated with
control, containment, and/or
isolation; simulated drills involving
confinement operations within the
testing response times and
capabilities of the available
techniques for isolation; respiratory
resources and personal protective
protection training and the testing of
equipment.
equipment.

Incident Command System (ICS) Training

The Incident Command System (ICS) is used by public agencies to manage emergencies per the
requirements of the National Incident Management System (NIMS). ICS can be used by private-sector
businesses to work together with public agencies during emergencies such as CO2 pipeline releases. As a
result, operators and their personnel should be familiar with the fundamental concepts of the Incident
Command System to help coordinate planning and incident management with public emergency services
and agencies.

The ICS structure is meant to expand and contract as the scope of an incident requires. For small-scale
incidents, only the incident commander may be assigned. Per ICS, the first on-scene representative of the
responsible party would be considered the incident commander and would coordinate with the jurisdictional
local, state, or federal emergency response agencies within Unified Command. Command of an incident
would likely transfer to the senior on-scene officer of the responding public agency when emergency
services arrive on the scene, which may also happen for the responsible party incident commander. This
is done by performing a proper Transfer of Command.

It is important to train responding personnel in the implementation and use of the Incident Command
System, including relevant terminology, forms, and position roles and responsibilities. It is recommended
to train personnel expected to respond to and manage a CO2 pipeline-related incident to the ICS-200 level
at a minimum.
10 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

4 Dispersion Modeling Best Practices

The potential for CO2 pipeline systems to affect high consequence areas (HCAs) must be evaluated 7.
Modeling is conducted to estimate the potential worst-case consequences in the event of pipeline rupture
in or near an HCA. The consequence analysis calculations should be performed for full bore pipeline rupture
under worst-case operating and atmospheric conditions to obtain the worst potential dispersion distances
or the impact area buffer.

Listed below are key inputs to most of the models and can impact the calculated potential impact area:

— pipeline parameters: name, length, internal diameter, operating pressure, fluid composition, product
temperature and flow rate;

— meteorological conditions: data for wind speed, wind direction, air temperature, relative humidity and
Pasquill-Gifford atmospheric stability class rating;

— isolation valves and isolation time;

— CO2 concentrations of interest.

Similarly, due to the unique characteristics of CO2 and the influence of the surrounding topography,
conducting an atmospheric dispersion analysis could be challenging in terrain with significant topographic
relief. Similar to wind, it is particularly problematic when the direction of the terrain relief is in the direction
of a populated area or HCA. The use of atmospheric dispersion modeling, coupled with overland spread
analysis using computational fluid dynamics (CFD) modeling, may be necessary in these areas where
topography and elevation changes may cause the dispersion plume to travel further than what could be
determined using only the traditional atmospheric dispersion analysis. In these areas, to truly understand
whether a nearby HCA could be affected by a CO2 release, CFD modeling can be added in order to
determine the additional dispersion distance and ultimately determine whether the dispersion plume might
impact a nearby HCA at any given point on the pipeline system.

An atmospheric dispersion analysis includes modeling pipeline releases utilizing software that uses a
Gaussian plume model to evaluate the dispersion of the released CO2 under site-specific seasonal weather
conditions, to determine worst-case buffer distances for non-topographically impacted transport. Although
oxygen displacement is the main safety concern for any CO2 pipeline release, it is recommended that
30,000 PPM or 40,000 PPM of CO2 be selected as the concentration endpoint for the exposure analysis,
based on potential human health risks at that concentration.

7
49 CFR 195.450 (Definitions) and 195.452
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 11

Figure 5—Transport and Dispersion of Released Carbon Dioxide on Flat Land

When the pipeline is in proximity to a nearby HCA, the effect of topography impacting transport must be
considered. An overland spread analysis should be performed to determine whether the impact of
topography and the dense vapor cloud could affect the nearby HCA. The overland spread analysis should
consider worst-case operating conditions, ambient conditions, elevation changes, and topographic
features, which would favor the channeling of CO2 from a release location in the direction of the specific
HCA. The Overland Spread Analysis uses site-specific, topographically based CFD modeling to further
evaluate the potential hazard distances in these areas.

Simply stated, the atmospheric dispersion plume model will help predict the radius of impact following a
pipeline rupture, while the CFD will evaluate the influence of the topographic features to provide the worst-
case distance of impact caused by a release. Because CFD modeling requires high levels of computational
power, modeling large distances of pipeline is, in most cases, not practical. A recommendation to achieve
the highest level of effectiveness is to use the atmospheric dispersion model for the entire pipeline system
and use CFD modeling in areas that exhibit significant elevation changes and significant channeling in the
direction of an HCA that is within several miles of the pipeline system.
12 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

Figure 6—Transport and Dispersion of Released Carbon Dioxide with Topographical Features

In addition to the impact of topography, examples of meteorological data that can affect the transport of
CO2 during a pipeline release include air temperature, wind speed, and relative humidity. These factors can
influence the rate of evaporation, the density, and the distance the products can travel in the air. Data for
these factors can be obtained from the National Oceanic and Atmospheric Administration (NOAA) National
Centers for Environmental Information (NCEI) Comparative Climatic Data for the United States through
2018 8. When preparing models to determine potential impacts to an HCA, it is recommended that worst-
case climate data inputs are used and compared to average most-probable climate data inputs. This will
give the pipeline operator an understanding of how far the CO2 can migrate under the worst possible
atmospheric conditions.

5 CO2 Pipeline Leak Detection and Identification

5.1 Physical Identification

When a leak occurs on a CO2 pipeline, the rapid drop in pressure causes the supercritical fluid inside the
pipeline to quickly change to a dense gaseous phase. In a smaller leak, this change will occur
instantaneously at the point of the leak. In large, complete pipeline ruptures and during the worst-case
ambient conditions, the dense gas may aggregate in low-lying topography and travel downhill before
dispersing in the atmosphere. A leak of CO2 from a pipeline may be recognized by using one or any
combination of the following:

— sight: presence of a dense while cloud, fog, or ice developing near the pipeline release point, blowing
dirt, dust, or soil in the air, or water bubbling in a puddle, pond, or creek;

8
[Link]
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 13

— sound: a hissing, blowing, or roaring sound;

— smell: CO2 is often odorless in a transmission line but may have a slightly musty odor.

5.2 Remote Identification

Like other pipeline systems, CO2 pipelines are equipped with Supervisory Control and Data Acquisition
(SCADA) systems, which transmit information and data that are critical to the operation of the pipelines
back to a remote, centralized control center. Sensors and actuators installed on the pipeline system allow
pipeline controllers to monitor the pressures and flow rates inside the pipeline from the control center and
take action to remotely open or close valves when a pressure anomaly and flow rate change is observed.

Pipeline controllers play a significant role in the early detection of a leak by closely monitoring the SCADA
systems. They are responsible for receiving initial notification of or recognition of a potential rupture of a
pipeline based on information from the SCADA system as indicated by the following:

— an unanticipated or sudden pressure reduction outside of the pipeline’s normal operating pressures, as
defined in the operator’s written procedures;

— an unanticipated or unexplained flow rate change, pressure change, equipment function, or other
pipeline instrumentation indication at the upstream or downstream station.

In addition to the above, pipeline controllers should be able to identify a rupture through remote monitoring
and fully close any remote rupture mitigation valves within 30 minutes of the initial rupture identification to
minimize the volume of CO2 released from a pipeline to mitigate the consequences of a rupture. They must
also be able to promptly respond to emergency and abnormality alarms and efficiently initiate proper
response actions required to prevent or mitigate the condition.

Line break technology can also be used to remotely detect pipeline ruptures. When the pipeline pressure
rapidly and significantly declines at a pipeline block valve (equipped with pressure telemetry and actuation),
beyond a pre-established reference value, the control logic within the actuators of the upstream and
downstream valves is designed to automatically close the valve, completely isolating and stopping flow to
the segment in which the pressure decline occurred. This technology is designed to automatically isolate a
pipeline rupture quickly and reliably, therefore reducing impacts to the areas surrounding the release.

Computational pipeline monitoring (CPM), typically used in crude oil pipeline operations, is difficult to
achieve with CO2 pipeline operations due to the compressibility of the CO2 inside the pipeline.

5.3 Supplemental Identification Methods

In addition to the physical and remote identification methods mentioned above, patrol surveys on pipeline
ROWs are performed as a way to detect a leak from the pipeline that may not be able to be detected
through pressure monitoring or to identify activity that may be harmful to the integrity of the pipeline.
Operators of regulated pipeline systems are required to develop procedures for conducting these patrol
surveys. The procedures for conducting the patrol surveys will include methods for conducting the patrols
by ground, air, or water, and provide guidance for identifying and reporting signs of:

— unusual conditions or activity;

— evidence of leaking or spilled products;

— third-party excavation or construction activity;

— logging activity;
14 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

— vandalism;

— erosion, washouts, or subsidence;

— exposed portions of the pipeline;

— excessive vegetation or tree canopy that might impede inspection or maintenance of the pipeline;

— any other factors that could affect public safety and operations.

If any of the above signs or activities are reported during a ground or aerial survey of the pipeline, the
pipeline company will investigate and take appropriate actions.

6 Internal Notification Protocols

Each operator should develop standardized reporting procedures for internally reporting pipeline-related
incidents. These internal notification procedures ensure incidents are properly reported in an efficient, timely
manner. The procedures should also be designed to enable the operator to provide the most consistent
and accurate information when initially reporting incidents externally and when updating responding
agencies. It is recommended that internal notification procedures include the following:

— a method for the pipeline controller to quickly provide information to the responding pipeline personnel,
such as dedicated conference call lines, mass communication systems initiated from the control room,
etc.;

— internal flowcharts that depict the flow of information, allow the operator to notify the appropriate level
of management, and quickly involve all departments, such as legal, HSE, land, public relations, risk
management, etc., needed to support the ramp-up of the Incident Command System and deployment
of the incident command team.

7 Reportable Release Thresholds

At the earliest practicable moment following the discovery of a release of CO2, but no later than one hour
after confirmed discovery, the operator of the system must give notice to the National Response Center
(NRC) of any failure that 9:

— caused a death or personal injury requiring hospitalization;

— resulted in a fire or explosion not intentionally set by the operator;

— caused estimated property damage, including cost of cleanup and recovery, value of lost product,
damage to the property of the operator or others, or both, exceeding $50,000;

— results in pollution of any stream, river, lake, reservoir, or other similar body of water that violated
applicable water quality standards, caused a discoloration on the surface of the water or adjoining
shoreline, or deposited a sludge or emulsion beneath the surface of the water or upon the adjoining
shorelines; or

— in the judgment of the operator was significant even though it did not meet the criteria listed above.

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49 CFR 195.52
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 15

Due to the ambiguity of the last bullet above, it is recommended that any release causing the following
should result in notification to the NRC:

— highway or road closures;

— evacuations or sheltering in place;

— any public exposure to CO2.

Any notification to the NRC or any state or local agency should occur verbally over the phone as soon as
possible and never be delayed due to the lack of information about a release. The order in which verbal
notifications occur should be prioritized with the focus on public safety.

Figure 7—Incident Reporting Criteria

In addition to the federal reporting thresholds, some states have specific reportable quantities for CO2.
Operators should develop detailed reporting procedures for reporting CO2 releases to all appropriate state
agencies in the areas in which they operate. Where published reportable quantities for CO2 do not exist, it
is recommended that the operator notify the applicable state emergency hotline or state agency responsible
for public safety for any release that results in the following:

— death or personal injury requiring hospitalization;

16 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

— road closures or evacuations; or

— any off-site or public exposure to CO2.

When federal or state reportable thresholds are exceeded, operators should also consider notifications to
owner/operator of nearby infrastructure that may be affected by the release, such as railroads, airports,
businesses, hospitals, or places of gathering.

8 Public Safety Answering Point Notification of CO2 Pipeline Release

Existing pipeline regulations also specify that operators must prepare a means for notifying the appropriate
public safety answering point (i.e., 911 emergency call center) of carbon dioxide pipeline emergencies to
coordinate and share information to determine the location of the release, including both planned responses
and actual responses during an emergency, and any additional precautions necessary for an emergency.
When a pipeline release occurs, the pipeline operator will immediately and directly notify the appropriate
public safety answering point or other coordinating agencies for the communities and jurisdiction(s) in which
the pipeline is located.

Because 911 dispatch centers are routed based on the area in which the call is originated, those outside
of the geographic area of a potential rupture may not be able to reach the 911 dispatch center by simply
dialing 911. As such, the pipeline operator should identify and document the “non-emergency” or “back-
door” numbers for 911 dispatch centers so that, during an emergency, the appropriate 911 dispatch center
can be reached, regardless of the caller’s origin location. These should be included within the applicable
emergency response plans. It is recommended that the 911 dispatch center should be the first external
notification made by the operator in the event of a pipeline rupture which has impacted, or has the potential
to impact, the public.

In order to notify the affected public of a pipeline release, many local (county/parish) emergency services
maintain reverse 911 services that allow for immediate notification to the affected public where a targeted
alert can be broadcast to warn of potential danger, the need for evacuation or sheltering in place, or the
like. Use your public awareness materials to make the public aware of such services.

8.1 Information to Provide to First Responders During Agency Notifications

Based on the identified hazards associated with a CO2 pipeline-related incident, it is imperative to
communicate accurate information in a timely manner to local first responders. All factual information known
at the time of reporting should be conveyed, with the priority of protecting public health. Items that should
be communicated include, but are not limited to:

— origin of release;

— nearest intersection/landmark;

— dispersion characteristics of vapor cloud (laying low to ground, overland travel, dispersion into
atmosphere, etc.);

— suspected path and direction of travel;

— volume released (pre-calculating volumes between valve sets is recommended for this purpose);

— potential outcomes such as limited visibility due to the vapor cloud and potential oxygen displacement;

— Actions being taken by the pipeline operator;

 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 17

— initial evacuation distances; and

— options to shelter in place.

If provided as soon as possible, the above information will enable local emergency managers and first
responders to make critical decisions that will help ensure the safety of the public that is impacted, or has
the potential to be impacted, by the release.

9 Third-party Notification of a CO2 Pipeline Release

Existing pipeline regulations assist in ensuring the public is able to contact the appropriate operator
following the discovery of a release. Each operator is required to maintain a process for receiving calls from
the public and disseminating the information provided by the public to the appropriate internal responders.
The process should include procedures for receiving calls from the public at the control center and gathering
pertinent information regarding the report from the public. This information should include, but is not limited
to:

— address of suspected release (including city/town and state);

— observations that have been made by the caller (vapor cloud, sounds, etc.);

— suspected path of travel of the vapor cloud (if observed);

— any roads, homes, schools, or other entities that are being impacted by the suspected release;

— injuries or fatalities caused by the suspected release;

— callback phone number for any follow-up questions.

The pipeline controller receiving the call must also help ensure the safety of the caller and instruct them on
what personal protective measures to take, such as sheltering in place or evacuation upwind.

10 CO2 Pipeline Release Response Actions

Each pipeline system is required 10 to have a manual of written procedures to cover not only conducting
normal operations and maintenance activities, but also the handling of abnormal operations and
emergencies, including the ability to respond to events and coordinate local, state, and federal response
agencies to effectively minimize public exposure. The procedures (commonly compiled into an emergency
response plan), should be written to allow the pipeline operator to achieve multiple objectives
simultaneously in a timely manner. Since CO2 is not likely to cause any short-term or long-term
environmental impacts requiring extensive cleanup activities like an oil spill would, the objectives following
a rupture should be focused on the following:

— protection of public;

— safety of the first responders and personnel;

— stabilizing the incident;

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40 CFR 195.402
18 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

In the event of a CO2 pipeline-related incident, ensuring the safety of the public and emergency responders
and isolating the upstream and downstream control valves will be the most important objectives to mitigate
the threats, including asphyxiation.

10.1 Emergency Responder Safety

The safety of emergency responders is a high priority. In addition to facilitating drills with local emergency
responders, meetings should be routinely conducted with local emergency planning committee directors,
fire chiefs, and law enforcement that are within the response radius of pipeline ROWs. During these
meetings, the pipeline operator should ensure that local emergency responders understand the hazards
associated with CO2 and how they should protect themselves. In addition, the following should be discussed
with local emergency responders:

— dermal hazards (frostbite to hands) and the use of leather or insulated rubber gloves while working in
close proximity to a CO2 release or while working at any of the facilities that were near the release point
immediately after the release has been stopped;

— the risk of debris (soil, vegetation, rocks) being thrown from a buried pipeline release;

— exposure to excessively high noise caused by the CO2 escaping the pipeline release or a controlled
blowdown;

— respiratory protection capabilities and types of respirators (supplied air respirators or SCBA) that should
be used when entering an area with elevated levels of CO2.

Figure 8—Icing of Flanges During a Release

 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 19

Local emergency responders, especially in remote areas, may not have adequate equipment that would
allow them to detect the concentrations of CO2 or O2 in the atmosphere. It is important for them to
understand those limitations and not expose their responders to an atmosphere with elevated CO2
concentrations or cause oxygen deprivation. If emergency responders have gas detectors, but they are not
capable of reading CO2, they should be educated to closely monitor O2 levels when entering the hot zone.
O2 monitors will go into alarm mode at readings of 19.5%, but responders should be trained recognize
decreasing O2 levels and what actions are necessary (evacuation to fresh air or don SCBA) to protect
themselves before exceeding the alarm threshold. Only properly trained and equipped responders should
enter the hot zone.

Under certain conditions, pipeline CO2 releases may create plumes extending thousands of feet that contain
CO2 concentrations greater than the STEL. It is important for emergency responders to understand the
constraints of their respiratory protection equipment and how much time they have available to enter a hot
zone while wearing a SCBA. Responders should allow enough time to enter and exit the hot zone without
running out of supplied air.

The operator should also take steps to ensure the safety of their personnel responding to a CO2 release.
All personnel responding to a pipeline release should have the appropriate training to do so, as covered in
3.3. Operators should never allow personnel to enter an IDLH atmosphere alone. If personnel are to enter
an IDLH atmosphere, they should have an adequate amount of supplied air, use the buddy system, and
have rescue personnel on standby. All of the aforementioned safety precautions should also be taken.

The below table shows PPE that should be considered while responding to a pipeline release.

PPE When Should It Be Used

Hard hat, safety glasses, and steel
While participating in any active response operations
toe boots
Leather gloves When contacting piping or valves in close proximity to the release*
Hearing protection (earmuffs or ear
When working near the pipeline release or controlled blowdown stack
plugs)
Self-contained breathing apparatus When entering an IDLH atmosphere or an atmosphere containing
(SCBA) or SAR unknown levels of CO2 or O2
* Local emergency response officials (fire department, law enforcement, etc.) should never attempt to close a valve on a pipeline
system, valve station, or facility.

10.2 Isolation Strategies

The control and isolation of the pipeline is one of the highest priorities of any response to a pipeline failure.
The longer the CO2 is released, the more likely it is that high concentrations of CO2, inside of the dense
vapor plume, will migrate and impact the public. Dispersion modeling suggests that CO2 will spread quickly
following natural contours until it reaches an equilibrium and then will quickly disperse following the isolation
of the pipeline. To prevent impact to the public, the means to limit the volume of the release should be
established. These measures may include the following:

— installation of remote rupture mitigation valves near HCAs;

— improving response times to manually actuated isolation valves;

— providing power tools to pipeline operators that aid them to close manual valves quickly;

— installation of line break technology in areas that are more densely populated or susceptible to impact
from a pipeline rupture.
20 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

Where remote isolation valves exist, establish protocols for verifying that remote valves have closed
properly. These protocols provide field personnel with guidance on how and when to confirm closure of
valves and provide pipeline controllers with methods of confirming that flow through the valve has ceased.

Controlled Venting or Blowdown

During a leak of the pipeline, it may be necessary to vent CO2 from the pipeline in a controlled manner at a
safe location. This can help bring the pipeline pressure down quicker and reduce the amount of CO2 that
may be releasing from the leak point, which could allow responders to access the release point to close a
valve, assess damage, and/or minimize the duration of the release.

During controlled venting operations, the following procedure is recommended to safely vent the CO2 from
the pipeline system:

1) Select a location that will not impact the public (homes, roads, schools, etc.).

2) Avoid venting from locations near low areas such as creek crossings or heavily wooded areas, which
prohibit the dispersion of CO2 into the atmosphere.

3) As a courtesy, notify the local 911 dispatch center and emergency manager, and appropriate state
agencies to make them aware of the venting operation and to discuss any questions they may have
regarding the event.

4) During venting operations, minimize personnel on-site to only essential personnel.

5) Station air monitors capable of detecting oxygen and carbon dioxide levels in the atmosphere at the
venting site. If oxygen levels below 19.5 % or CO2 concentrations higher than 30,000 ppm are
detected, personnel at the venting site must evacuate to fresh air immediately and the venting must
cease.

6) When CO2 is released from the pressurized pipeline into the atmosphere, the large associated
pressure drop causes it to cool down dramatically (sub-freezing temperatures). Venting equipment
should be designed to operate in extreme cold conditions.

7) Certain meteorological conditions (cool, humid, no wind) may limit the dispersion of CO2 during
venting. Every effort should be made to avoid controlled venting operations during these periods. In
addition, understanding wind direction and how it may cause the plume to migrate is important so that
it is not blown into a public area by the wind.

Controlled venting is typically not required on a pipeline rupture; however, it may be necessary for pipeline
ruptures that have occurred on pipeline segments that have long distances between isolation valves or for
releases that may have a smaller exit point.
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 21

Figure 9—Controlled Venting Operations

Forced Air Displacement

When a pipeline release occurs, the dramatic change from pipeline pressure to atmospheric conditions will
cause a white vapor cloud, which will reduce visibility at the leak point. When entering an atmosphere that
exceeds an action level for respiratory protection, pipeline operators will have to don a SCBA; however, the
reduction of visibility may prohibit responding pipeline operators from accessing an isolation valve or valve
station. When this occurs, the use of forced air blowers, fans, etc., may be necessary to provide safe access
to the site. This action is particularly effective for smaller releases such as flange or valve packing leaks
that do not totally encompass the site with CO2. Forced air displacement is not a viable option for most
pipeline ruptures and large-scale releases of CO2, particularly during nighttime hours, when dispersion is
less likely to occur.
22 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

Figure 10—Forced Air Displacement Using a Trailer-mounted Fan

10.3 Real Time Plume Predictions and Surveillance

During a pipeline leak or rupture, the ability to predict the direction of the CO2 plume will aid emergency
responders in making key public safety decisions. Wind direction is the most common indicator of which
direction the plume will travel. When winds are light, topography may influence the plume, carrying it down
gradient or causing aggregation into low-lying channels.

During daylight hours, aerial surveys by plane or drones may also assist in predicting the travel of the CO2
plume; pilots can provide real-time feedback and drones can capture pictures or video showing where the
plume is going.

During nighttime hours, when aerial surveillance via plane or drones is not as feasible, real-time dispersion
modeling may be useful in helping predict the plume direction and the possible concentrations of CO2 inside
the plume. However, real-time dispersion modeling may not be readily available during an event or take too
long to process in order to provide emergency responders with timely data.

10.4 Air Monitoring Strategies

The operator should have and maintain contracts with third-party emergency response service providers
such as oil spill removal organizations (OSROs), toxicologists, industrial hygienists, and environmental
scientists that can provide assistance during a pipeline release. OSROs can help provide preliminary air
monitoring results using handheld air monitoring devices that could aid in establishing hot and cold zones.
They can also be used to assist in rescue efforts and provide supplied air bottles to fill the SCBAs of local
emergency responders and/or the operator.

Due to the potential impact on the public, environmental health and toxicology service providers are
extremely important in the response to the pipeline release. They can provide advanced remote air
monitoring that will give the Unified Command information that could drive further response actions both at
the incident site and in the impacted community. The third-party environmental health and toxicologist
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 23

service providers can develop an air sampling and analysis plan to monitor hazards of a CO2 pipeline
release. In most cases, CO2 and oxygen will be monitored during a pipeline release; however, some other
analytes may also be included within the air sampling and analysis plan should the pipeline contain other
potentially harmful contaminants. Monitoring will continue until results indicate that these analytes do not
pose a health concern.

The air monitoring strategy typically consists of three broadly defined monitoring plans:

— work area monitoring;

— community monitoring; and

— site assessment.

Work area monitoring generally takes place in those areas where workers are actively
performing/supporting remediation operations. The readings are to be taken at a height consistent with that
of the workers’ breathing zone and in close proximity to workers without interfering or obstructing their
remediation tasks.

Community monitoring may take place in those residential and/or commercial locations immediately
surrounding the incident site.

Unlike work area and community monitoring, site assessment does not necessarily represent ambient air
monitoring near breathing zone level. Site assessment may involve a variety of different monitoring tasks
intended to provide information that may help to delineate the nature and extent of the release (e.g., fence
line monitoring, worst case determination, ground level, etc.).

Free-roaming handheld real-time air monitoring may also be conducted in a variety of areas based on levels
of activity, proximity to the release, and site conditions. Portable fixed-location and/or handheld real-time
locations may be established in the community in order to provide concentration averages that may be
observed and analyzed over time in distinct geographic locations in the community. Portable fixed-detection
systems may be utilized to monitor the scene from a remote location, if necessary.

Air Monitoring Techniques

Procedure Description
Staff members may utilize handheld instruments (e.g., colorimetric detector tubes) to
measure airborne chemical concentrations. These handheld instruments will primarily
be used to monitor the ambient air quality at breathing zone level.
Real-time handheld
Additionally, measurements may be made at grade level, as well as in elevated
survey
workspaces, as indicated by chemical properties or site conditions.
These techniques may also be used to verify detections observed by the network of
portable fixed-detection systems.
A radio-telemetering network of fixed-detection systems may be deployed in locations
Radio-telemetering where monitoring from a remote location would be beneficial. These instruments will
network relay readings back to a centralized location that is monitored by the third-party
provider.
Multiple community locations may be identified and monitored at the same location
Fixed real-time approximately once per hour using handheld instruments.
monitoring locations This allows the use of statistical analysis more effectively than with a random
approach.

Most third-party environmental health and toxicology service providers have capabilities to collect ambient
air samples, if necessary. These sampling methodologies may be utilized if the results from real-time air
monitoring efforts indicate the potential for exposure above acceptable occupational or community
24 CO2 EMERGENCY RESPONSE TACTICAL GUIDANCE DOCUMENT

exposure levels. These samples may be helpful in substantiating the impact on personnel or the public.
After outdoor community CO2 levels are sustained and continually measured below 5,000 ppm, initial indoor
assessment real-time monitoring can be performed inside residences and other buildings potentially
impacted by an incident, at the owners’/occupants’ request. This confirmatory air monitoring allows the
Unified Command to make decisions for safe return to homes and businesses following an evacuation.

10.5 Incident Management

With pre-determined emergency response procedures, including the isolation of upstream and downstream
valves and adequate training and testing of their implementation, the public health threat of a CO2 pipeline
release will likely not exceed 24 hours. As such, the proactive incident management may not be able to be
utilized. ICS should still be utilized by the incident commander with support from emergency response
contractors and local first responders. Key components that ensure a successful response is carried out
include the ability to operate within Unified Command with local, state, and federal agencies, the
establishment of incident objectives, and the adoption of a site safety plan and incident action plan.
Responding emergency response team members should focus on successful implementation of the stem
on the Planning P (initial response), but still be prepared to progress through the entire planning process if
the event lasts longer than expected (see below).

Figure 11—Planning P

Due to the anticipated short duration of a CO2 pipeline-related incident, an off-site command post may not
be established; instead, the command post will be established adjacent to the incident scene at a safe
distance from known hazards, possibly on the tailgate of a truck or field office. Since much of the ICS
documentation focuses on expanding events taking place over multiple operational periods, it may be
beneficial to generate ICS forms that are able to be filled out quickly in the field by pipeline operators to
 BEST PRACTICE GUIDELINES FOR PREPAREDNESS AND INITIAL RESPONSE TO A PIPELINE RELEASE OF CO2 25

document the objectives of Unified Command. One such method is to combine the components of the site
safety plan and the incident briefing form (ICS 201) into a singular document that allows for the critical
components of the initial response to be identified, documented, and clearly communicated with response
agencies and response personnel.