I received an interesting email from someone whom I suspect is not a long-time reader of this blog. The writer is concerned about the new pipelines being constructed to carry natural gas from the fracking fields to where it will be used and or processed in areas like Florida. The email states, in part:
“I am concerned that there doesn't seem to be a proper safety plan in place. The chance of either accident or sabotage seem high, so I am interested in your thoughts on how this issue will be managed.”
Since I address pipeline safety and security issues in this blog, responding to this email in a blog post seems like a reasonable place to address these issues.
Larger Environmental Issues
Ignoring for now the increasing concentration of CO2 in the atmosphere and the greenhouse gas issues of both methane and CO2, anyone with even a little bit of sense has got to be encouraged by the expanding use of wind and solar energy as part of the energy mix in this country. Both crude oil and natural gas are finite resources that are going to be consumed at some point and expanding alternative energy sources will put off that final consumption further into the future.
Having said that; even in the most optimistic plans for expansion of alternative energy, petroleum fuels and natural gas are going to be a large part of the energy mix in this country for a long time. This is particularly true for natural gas as it continues to displace coal as the primary source of electrical production in this country.
Bulk Liquid and Gas Transportation
There are four major types of transportation that can be used to transport bulk liquids and gasses like crude oil and natural gas; truck, barge, train and pipeline. All four of them have their place in the energy transport scheme; each with its own specific strengths and weaknesses. These strengths and weaknesses are generally related to the unit volume of material that can be transported.
Smaller unit volume generally means more flexibility in movement, higher unit cost, and increased handling. That increased handling also increases cost, but more importantly it increases the chance for accidents and equipment failure that can lead to releases of crude oil and natural gas to the environment.
Pipelines are the least flexible mode of bulk liquid and gas transportation. They have a fixed route that cannot be readily changed and they take significant time and resources to construct. They also have the lowest operating cost (per unit volume) and the least amount of handling resulting in the lowest release rate per unit volume transported.
There are a huge number [lengthy .PDF Download] of gas and hazardous liquid pipelines currently operating in the United States. For the most part, their safety is regulated by the DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) and their security is addressed by the DHS’s Transportation Safety Administration (TSA).
PHMSA’s rules regulate the physical construction, maintenance and operation of gas and hazardous liquid pipelines. Their regulations are complex and fairly comprehensive. They continue to evolve over time as new issues are identified and new technologies are developed to increase the safe and efficient transportation of gas and hazardous liquid transportation.
Of course, rules and regulations have never made anything safe and secure. It is only the full compliance with both the letter and intent of those rules and regulations by pipeline operators, along with the skill and daily attention of their employees, that truly makes pipelines the safest way to transport large volumes of gas and hazardous liquids.
Are their instances where pipeline operators or their employees take shortcuts or outright violate the pipeline safety rules established by PHMSA? Anyone with a modicum of sense will admit that this is true. This is the reason that a (too) small number of PHMSA inspectors (and some State counterparts) spend a large amount of time inspecting the operation of the regulated gas and hazardous liquid pipelines. They probably catch just a small percentage of the rule violations; fortunately, the pipeline system is robust enough that these undetected violations seldom result in significant releases to the environment.
While PHMSA heavily regulates pipeline safety, the Congress has given the TSA very little actual authority to regulate pipeline security. The security of gas and hazardous liquid pipelines in this country relies mainly on pipeline operators voluntarily using industry developed best practices. The very small number of TSA Surface Transportation Security Inspectors have little time and no authority to actually inspect pipeline security. At best they do periodic office visits to review the operator’s written security procedures. Even if they detect glaring omissions in such program documentation, they can do little more than recommend changes to be made.
We have been fortunate for a number of reasons. First, there have been relatively few attacks on pipelines in North America (see here, here and here) and they have been rather inconsequential. That does not say much for security beyond that we have been lucky and that the terrorists have been inept.
More importantly, many of the safety measures that have been put in place in response to PHMSA regulations would serve to reduce any damage from a successful pipeline attack. Things like leak detection and automated shut-off valves would help reduce the amount of gas or hazardous liquid that would be released to the environment. To be clear, this would not eliminate the dangers of an attack, just reduce the extent of the effects.
Given the problems that we have seen with large rail shipments of crude oil, it is clear that we need to move even more of the shipment of fossil fuels to pipelines. That only makes sense from both an economic and safety perspective.
That does not mean that the current regulatory environment for hazardous material pipelines cannot be improved. One area that PHMSA sorely needs to address is the cybersecurity of the electronic control systems used to monitor and control the flow of gas and hazardous liquids through the pipelines.
Normally, one would expect a DHS agency (TSA for example) to handle transportation security issues, but TSA is so under-funded and under-staffed on the surface transportation security side of the agency that, even if Congress were to provide a cybersecurity mandate for pipelines, TSA would not be able to address the issue without major funding and manpower increases. Congress is unlikely to provide a new regulatory mandate and even less likely to expand funding for TSA.
Fortunately, PHMSA could almost certainly wangle some cybersecurity requirements as safety measures to ensure adequate control and monitoring of these hazardous material pipelines. The rules would have to be fairly basic; probably including (at a minimum):
• Include cybersecurity review (including detailed control system diagram) as part of all safety reviews;
• Limit virtual and physical access to control system network and its components;
• Identify safety critical electronic control system elements and require the reporting of loss of view or loss of control incidents involving those components; and
• Require membership in an industry or control system information sharing and analysis center (ISAC).
Fossil fuel opponents are going to have to realize that for the short-term, at least, pipelines are going to be an important and inevitable part of energy policy in this country. They might be better off, rather than opposing all new pipelines, to become engaged in the pipeline safety and security discussion so that the pipelines that are going to be built and operated are the most energy efficient and environmentally sensitive pipelines possible.