S 2276 Passes in Senate

At the close of yesterday’s session the Senate considered and passed S 2276, the Securing America’s Future Energy: Protecting our Infrastructure of Pipelines and Enhancing Safety (SAFE PIPES) Act after adopting substitute language to the language reported out of the Senate Commerce, Science and Transportation Committee. There was no debate on the bill and it was adopted by unanimous consent (which means no vote was taken).

Revisions to the Original Bill

The Committee removed one section from the original bill that would have established the Great Lakes as an ecological resource under 49 CFR 195.6(b). It also added a number of new sections:

Sec. 4. Hazardous materials identification numbers.

Sec. 10. Pipeline odorization study.

Sec. 17. Joint inspection and oversight.

Sec. 21. Small scale liquefied natural gas facilities.

Sec. 22. Report on natural gas leak reporting.

Sec. 23. Comptroller General review of State policies relating to natural gas leaks.

Sec. 24. Provision of response plans to appropriate committees of Congress.

Sec. 25. Consultation with FERC as part of pre-filing procedures and permitting process for new natural gas pipeline infrastructure.

The substitute language adopted by the Senate yesterday included two additional new sections:

Sec. 26. Maintenance of effort.

Sec. 27. Aliso Canyon natural gas leak task force.

Moving Forward

The House has just started work on their version of the pipeline safety reauthorization bill. The House is unlikely to take up S 2276 until it has considered their homegrown version of the bill. There are many areas of general agreement between the current draft bill being considered in the House Transportation and Infrastructure Committee, but there are certainly differences that will have to be worked out.

Commentary

The study on odorization of ‘all combustible gas in transportation’ should provide an interesting look at the problem with a current, very basic safety rule. In general flammable gasses used for fuel (propane, natural gas, etc) are odorized by the addition of an odiferous contaminant. This is done because the chemical mixtures in their produced state are not detectable by the human senses of sight or smell. Without the addition of these stinky chemical additives leaks of these materials in transportation could be very dangerous. With the addition of very small amounts of these organic contaminants people at the scene of a transportation accident can readily tell when there is a leak and take appropriate precautions.

All very good until you realize that not all of these flammable gasses are used as fuels. They are frequently used as feedstocks for a variety of other chemical manufacturing processes. Because these odorants are not found in the pure chemical they frequently cause problems in the chemical reactions that are used to make other chemical products and they are difficult (read expensive) to remove. So when these flammable chemicals are shipped as chemical feed stocks rather than fuel, they are typically shipped without the addition of the odorants.

I currently live in a refinery town and frequently see tank trucks transporting propane on our local streets that are marked with the phrase “No Odorants Added”. This is done to notify first responders that they cannot rely on the ‘typical’ smell of the odorized product to warn them of a leak in the event of an accident. They would then take additional precautions when coming upon an accident scene of one of these marked trucks such as making precautionary evacuations and employing a variety of gas detectors as they approach the accident.

There are however times where these non-modified flammable gasses are transported in pipelines. In those situations, when a pipeline leak occurs that is not physically obvious, there is nothing to warn people in the immediate area of the potential danger of fire and explosions. Even if there were very effective leak detection equipment on the pipeline there would be a substantial time delay between when the pipeline control center is notified of the leak and when that notification can be relayed to the immediate area of the leak. In that time delay, serious problems can occur.

As a chemist I fully understand that these odorants can be a problem for chemical manufacturing processes. At the very least the odorant would make it through the manufacturing process unchanged and provide an unpleasant odor to the finished product that could make it unusable. In the worst case you could have side reactions take place between the odorant chemical and other necessary chemicals in the process that would make the final product unusable. And, of course, in some cases there would be no noticeable changes because of the very low concentrations of these odorants in the flammable gas.

There are a variety of mitigation measures that could be put into place where it is necessary to transport un-odorized flammable gasses by pipeline. One way would be to reduce the potential for leaks by establishing that the entire route of such a pipeline would be considered to be a high consequence area (HCA) requiring the additional safety management controls currently used when pipelines transit residential areas. Another measure could be to put local alarms in place that would be activated by advanced leak detection equipment. Another could be to require the employment of gas detectors with local alarms as leak detection equipment where ever these types of pipelines transited current HCAs.

The one short coming of the odorization study provisions of §10 in this bill is that it does not require PHMSA to do a comprehensive review of current and potential mitigation measures that could be employed. The closest it comes is a requirement to do a cost-benefit comparison of odorizing all flammable gases and “using other methods to mitigate pipeline leaks” {§10(3)}.