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.
Pipeline Safety
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.
Pipeline Security
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.
Moving Forward
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.