Tuesday, March 28, 2017

Reader Question: Wither safety and security for new energy pipelines?

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.

1 comment:

terrefirma said...

Having made original post, I followed up a few days later with a comment that wasn't published which is understandable. I assume that this blog is intended to be one more cog that promotes and supports pipelines and won't speculate on motive. But certain comments are disingenuous- in particular those that insist that gas and oil are 'here to stay' being an inevitable part of the energy policy, so opponents would do BETTER to become engaged in safety and security discussions, rather than oppose ALL new pipelines. Excuse me? First of all, what discussion? About safety, to start. We certainly are not privy to widespread information regarding safety, or even news about failures. Seeing pipelines blow sky high isn't good press. Even those policies in place such as the 'Call Before You Dig" state ones get little press. Some states like Texas, do make attempts to educate first responders, holding events where they can even see (paid) demonstrations of just what it looks like, sounds like and feels like to witness a backhoe scrape a pipe that is already deteriorating and blows, igniting the safer compressed air. But other states, including my own of Florida not only ignore the possibility until it happens, but when an incident does occur we hear conflicting stories of who, what, and how it happened, until the pipe is covered back up. When word does get out about what caused the Interstate 75 shutdown there are so many rumors floating that no one worries about the true story. Yet Emergency Management systems, while having a coordinated plan in theory, are reactive at best, Triage at worst. Yet we live surrounded by jet fuel pipelines, natural gas transport and even more volatile, vulnerable gases simply stored in highly visible structures near the port . And if there was a coordinated, simultaneous event that involved multiple areas, emergency response agencies and both rural and urban municipalities would be severely impacted. Here in Tampa we are prepared for the Superbowl, the RNC and March Madness. We even had an orderly evacuation- once I think. But drive on one of our roads at rush hour, or Orlando or Miami, then picture panicked exodus, coupled with knowing we are trapped on this peninsula. Clearly terrorists are patient planners, so why give them wide open miles of targets? Not only the event itself but the shutdown of the grid which would occur is mind numbing in its short sightedness. I feel troubled even writing this as though I might give someone an idea, but we all know that it isn't necessary to trigger one. They are out there, planning at their computers with intel and maps provided freely by government and private industry. And those same organizations are complicit in keeping the public ignorant, and dependent preventing us from having systems of alternative energy that could provide the most basic of human needs or even collaborating in small microgrids to keep basic systems of water and sanitation moving in event of an emergency.

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