WEST UNION, W.Va. – Yesterday, we reported upon the ongoing flooding in Doddridge County, W.Va. In it, we offered evidence that demonstrates that the Mountain Valley Pipeline (MVP) Right-of-Way (ROW) has multiple paths for water to flow onto a local farm, despite denials by the MVP, Doddridge County officials and West Virginia Department of Environmental Protection (DEP).

However, this is still vital information that is missing from that article. We do not know if Doddridge County emergency officials have identified the hazards from the MVP or made any plans to prepare for any emergent event that may develop as a result of its presence.

It’s not for a lack of trying though. We do not have this information because George Eidel, the Floodplain Manager and Director of the Office of Emergency Services (OES) in Doddridge County, will not answer my questions about whether the county has prepared for potential disasters that could be caused by the MVP.

Eidel has refused no less than three requests from me via email – once on Dec. 6 and twice on Dec. 7 – to tell me if those plans exist. And, I had informed him in a phone conversation in early October that I would want to discuss emergency plans, giving him plenty of lead time to anticipate any relevant questions about the county’s emergency plans. While Eidel did answer one question in those emails, he ignored two critical questions that must be answered if county residents are going to be confident that the county has prepared for any number of possible disasters related to the MVP. The two questions Eidel has not answered are:

1. In the county’s Hazard Vulnerability Analysis (HVA) is there a threat/risk assessment for the MVP?
2. In the county’s Emergency Operations Plan (EOP) are there planning, preparedness, response and recovery activities included in the event of an emergent event with the MVP?

Eidel’s failure to answer these questions calls into into question if such plans even exist. If they do not, Doddridge County OES is not adhering to best practices and is, in fact, out of compliance with federal law. The OES is a leading agency of the Local Emergency Preparedness Committee (LEPC), which is federally mandated under the Emergency Planning and Community Right-to-Know Act. Originally established to ensure first responders, hospitals and citizens had information about Hazardous Materials in their communities, the role of the LEPC has since expanded to an “All Hazards” approach after the terrorist attacks of Sept. 11, 2001 and Hurricane Katrina in 2005.

These are documents that should be readily available and shared with any citizen requesting to see them. So, even though it shouldn’t have been necessary, after Eidel didn’t answer the last time, I shared with him that I was fully competent to see and interpret those documents. I wrote, “I am well-versed in this area, having earned a post-graduate Certificate in Community Preparedness and Disaster Management from the UNC School of Public Health, and serving as a paramedic (my first shift as an EMT was at West Union in 1974) and later emergency preparedness coordinator and safety officer for two hospitals, served on numerous LEPCs and had my work on a Reverse 911 website demonstrated as a best practice for hospitals in North Carolina. I am FEMA certified in numerous areas. I have written numerous HVAs and EOPs.”

Even that information didn’t prompt Eidel to respond. So, I’ve taken it upon myself to write outlines for an HVA and EOP for the MVP (suitable for any community along its path). These are based on an upcoming booklet I am writing and publishing, “A Grassroots Guide to Community Preparedness and Disaster Management.”

The Hazard Vulnerability Analysis

The Hazard Vulnerability Analysis (HVA) is the building block of an Emergency Operations Plan. While emergency managers, response agencies and hospitals are required to have them, they can serve a vital purpose for any organization monitoring and responding to hazards, threats or disasters. It is the first step a community or organization must take to plan for disasters.

Community Participation

The organization should seek partners with similar missions and consider offering training on Community Preparedness and Disaster Management to grassroots community leaders and organizations. It should also reach out to the Authorities Having Jurisdiction (OES/911, Floodplain, Public Health, WVDEP, FERC, and especially local authorities along the route). The organization should also seek membership on county LEPCs where the MVP passes through.

So ideally, these plans would be written collaboratively. Having no input from Eidel, these documents have been developed based on my experience, not only in emergencies, but in recognizing the threats posed by the MVP based on a decade of reporting about it.

The ‘All Hazards’ Approach

An organization conducts a Hazard Vulnerability Analysis (HVA) to identify potential emergencies that could affect the organization’s ability to operate, increased demand for the organization’s services, the likelihood of these events occurring, and the consequences of those events.

The HVA is developed utilizing an “All Hazards” approach, meaning simply that the organization does not reject, out-of-hand, any potential risk. However, risks are ranked systematically, objectively and thoughtfully. This HVA, because it is relevant to a specific project – in this case, the Mountain Valley Pipeline construction and related activities – is considered an annex to the EOP to account for unique threats and required responses posed by the MVP, such as HAZMAT plans.

The HVA is based upon various sources, including: subject matter-specific historical data; current trends; community and regional historical data; collaborative discussions with internal stakeholders; collaborative discussions with external authorities and partnering agencies; lessons learned from previous emergent incidents and drills; local, state and national news and intelligence sources; population trends and shifts; mapping; natural hazards; organizational capabilities; meteorological and geological data; and observation.

I divide threats into the following four categories:

• Naturally Occurring Events
• Technological Events
• Human Related Events
• Hazardous Materials Events

Data Interpretation

To rank risks, numeric measures (I use 1-4, with 4 being the highest risk) are assigned to each potential event. Factors utilized to rank the risks are:

• Event Probability
• Severity

Event probability is simply a numeric ranking of the likelihood the event will occur. Severity is measured by comparing magnitude of the event against mitigation efforts for the event.

• Magnitude = human impact + property impact + business impact
• Mitigation = preparedness + internal response + external response

Threat Rankings

While threats posed from the MVP seem endless, my MVP HVA ranks only the top four hazards. It is notable, that while other events might occur, that the process for managing a disaster – the National Incident Management System (NIMS) – is scaleable and flexible, meaning it will help emergency managers in virtually ever disaster, regardless of the threat ranking. Here is my partial list of threats posed by the MVP, followed by the top four threats.

1. Flooding
2. Explosion or other pipeline failure
3. Water Use and Contamination
4. Air Pollution
5. Roadway Dangers
6. Public Health Issues
7. Earthquakes
8. Waste Disposal
9. Pipeline Corrosion
10. Site Development and Well Pad Activity

The top four most likely hazards to occur are:

1. Flooding (Naturally Occurring Event and Human Event)
2. Water Contamination (HAZMAT Event)
3. Explosion (Technological Event)
4. Public Health Issues (Human Related Event)

Rankings are based on the following calculations:

1. Flooding: Event probablity – 4; Severity – 4; Magnitude – 4; Mitigation – 4. So, it has the highest possible ranking at 16.
2. Water Contamination: Event probablity – 4; Severity – 4; Magnitude – 3; Mitigation – 4. So, it has the second highest possible ranking at 15.
3. Explosion: Event probablity – 3; Severity – 4; Magnitude – 4; Mitigation – 4. So, it also has the second highest possible ranking at 15.
4. Public Health Issues: Event probablity – 3; Severity – 3; Magnitude – 4; Mitigation – 4. So, it has the third highest possible ranking at 14.

While these rankings are certainly subject to varying interpretations, they serve as a starting point for discussion. If I was a member of an LEPC along the MVP, I would bring my HVA to the table to compare and contrast what others believe.

Mitigation Activities

Mitigation efforts – activities undertaken to lessen the severity and impact of a potential emergency before it occurs – are devoted primarily to those hazards which usually rank highest on the HVA. Still, some mitigation efforts – such as redundant communication systems – are developed and implemented for virtually any hazard, thus ensuring that mitigation efforts are also aligned with the all hazards philosophy.

The Emergency Operations Plan (EOP)

The Emergency Operations Plan (EOP) provides guidance based on mitigation, preparedness, response and recovery activities that have been planned based on the HVA. These plans must be drilled and exercised for them to work. It is the framework designed to allow the Incident Management Team (IMT) to coordinate emergency response activities.

My outline for an EOP for the MVP follows.

1. Establish Command & Control according to the National Incident Management System (NIMS)
2. Develop Situational Awareness
3. Summarize the Scenario
4. Crisis Communications
5. Safety & Security
6. Vulnerable Populations
7. Staff Responsibilities
8. Resources & Assets
9. Utilities
10. Volunteer Credentialing
11. Evacuation
12. Recovery

Training Exercises

Each of these areas require extensive, but concise directions. The plans must be tested. Having them collect dust is negligence. So, to assess the accuracy of the HVA and community readiness to implement the EOP, ongoing training and exercises are essential.

Training exercises include Table Top Exercises, Drills, Functional Exercises and Full Scale Exercises. Drills and Functional Exercises are often utilized to prepare for a Full Scale Exercise, or to test tasks, functions, roles, responsibilities and policies that are new or requiring improvement. These training exercises according to the definitions provided by the Homeland Security Exercise and Evaluation Program (HSEEP):

• Table Top Exercise – A Table Top exercise is a discussion among relevant personnel about an emergent scenario, often one that is to be tested in a larger exercise.
• Drill – A drill is a coordinated, supervised activity usually employed to test a single, specific operation or function within a single entity.
• Functional Exercise – A functional exercise examines and/or validates the coordination, command, and control between various multi-agency coordination centers (e.g., emergency operation center, joint field office, etc.). A functional exercise does not involve any “boots on the ground” (i.e., first responders or emergency officials responding to an incident in real time).
• Full-Scale Exercise – A full-scale exercise is a multi-agency, multi-jurisdictional, multi-discipline exercise involving functional (e.g., joint field office, emergency operations centers, etc.) and “boots on the ground” response (e.g., firefighters decontaminating mock victims).

Other activities, such as “rounding” – say in a trouble spot – should be considered.

Citizen Participation Needed on LEPCs

Both of these documents require extensive thought, input, writing, review, and assessment. Yet, they should exist. And they should be available for public review, questions and input. Evidence of exercise design, training and drills should be available, thorough and current. The best way to learn about and contribute to your county’s emergency planning is to become part of it as a member of the LEPC. The law allows for citizen participation. If you have questions, contact your local OES.

© Michael M. Barrick, 2023. Home photo is a courtesy submission of a flash flood in Doddridge County on Sept. 9, 2023, as reported in yesterday’s article. To learn more about the MVP and fracking, take a moment to learn about my book, “Fractured Sanctuary: A Chronicle of Grassroots Activists Fighting Pipelines of Destruction in Appalachia.” All revenues from book sales are used to continue this reporting.