Good for the Goose, Good for the Gander: Who Should Have Access to Plume Modeling for CO2 Pipeline Ruptures?

Good for the Goose, Good for the Gander: Who Should Have Access to Plume Modeling for CO2 Pipeline Ruptures?

Author: Paul Blackburn, Bold Alliance
Oct. 2, 2024

Introduction

This is the final blog in a four-part series about carbon dioxide (CO2) pipeline ruptures.  It discusses the failure of government and industry to generally require plume modeling for CO2 pipeline ruptures, as well as legislative proposals that would make any modeling that is done secret.  But, it also makes the point that if neither government nor pipeline operators provide modeling to the public, then communities can hire experts to do their own modeling.  So you know, the prior blogs in this series cover:

• 1: Chasing a Wild Goose Egg: Understanding Computer Plume Modeling for Carbon Dioxide Pipeline Ruptures (The basics of CO2 pipeline ruptures and the need to know the danger zone following a rupture – Sept. 23, 2024)
• 2: Is Your Goose Cooked? The Potential Health Impacts of CO2 Pipeline Ruptures (Sept. 25, 2024)
• 3: A Tale of Perfect Goose Eggs: CO2 Plume Computer Modeling Options (The computer models available to predict the size of danger zones for CO2 pipeline ruptures – Sept. 30, 2024)
• 4: Good for the Goose, Good for the Gander: Who Should Have Access to Plume Modeling for CO2 Pipeline Ruptures? (Public access to CO2 pipeline rupture computer modeling and industry and government efforts to keep it secret – Oct. 2, 2024) 

The goal of this series is to help current and potential future neighbors of CO2 pipelines access technology that can help them understand whether or not they are at risk.  

Will Citizens Have Access to Plume Modeling for CO2 Pipelines?

The prior blog posts described the need for and capabilities of CO2 pipeline rupture plume modeling, but the best modeling in the world is useless if it’s not used or kept secret.  As discussed, there are two basic types of computer models, called dispersion models and computational fluid dynamic (CFD) models, that can predict how far dangerous concentrations of CO2 would extend from a rupture site.  So, the technology exists to predict CO2 pipeline rupture danger zones, but if nobody uses the models or if their output is kept secret, what good are they to you?  

Unfortunately, neither PHMSA nor state and local governments expressly require plume modeling before a CO2 pipeline is routed, or make such modeling public.  Also, few if any state or local governments require that their emergency response agencies conduct plume modeling to plan for CO2 pipeline ruptures.  Federal regulations in effect require plume modeling to inform pipeline company monitoring and maintenance requirements and emergency response, but these regulations do not specify any type of computer modeling.  Worse, the CO2 pipeline industry is supporting new federal legislation that would make government and industry pipeline rupture modeling secret, based on an argument that its release would aid terrorists.  So, what can you do to ensure that you have access to plume modeling so that you can protect yourself, your family, and your animals?  

With regard to routing new pipelines, Federal law does not regulate CO2 pipeline routing.  Therefore, no federal agency will conduct plume modeling for CO2 pipeline route selection or require that a pipeline developer conduct plume modeling before a CO2 pipeline route is selected.  Instead, CO2 pipeline routing is within the jurisdiction of state and local governments.  Unfortunately, many states and local governments have chosen not to regulate pipeline routing, and in some states local regulation of pipeline routing may be prohibited by state law.  Even where state or local pipeline routing laws exist, few if any state or local governments expressly require pipeline developers to submit plume modeling as an aid to agency route selection.  While some state agencies have required disclosure of plume modeling during administrative hearings, to date all of the models disclosed have been dispersion models, not CFD models.  Moreover, some of these agencies have made the modeling confidential. 

With regard to using plume modeling in emergency response planning, it appears that few if any state or local governments currently require plume modeling during CO2 pipeline emergency planning efforts, generally because relatively few CO2 pipelines exist.  Those that do likely rely on cheap and quite possibly inaccurate dispersion modeling.  Emergency responders may also have access to pipeline company modeling, most of which would also likely be cheap and inaccurate dispersion modeling.  Emergency response agencies should be skeptical of the output of simple dispersion modeling provided by pipeline developers.  Instead, they should conduct their own CFD modeling at pipeline developer expense or at least require pipeline developers to conduct CFD modeling and disclose all of the data and assumptions used, so that response agencies may assess the quality of the modeling.    

For existing pipelines, Federal regulations require that pipeline operators identify the “high consequence areas” (HCAs), including high population areas, through which their pipeline pass that could be affected by ruptures.  Pipelines in HCA’s are subject to higher operational and maintenance safety standards.  Although federal law does not expressly require the use of plume modeling to determine whether a pipeline could affect a community, as a practical matter CO2 pipeline companies do conduct plume modeling, typically inexpensive dispersion modeling.  However, PHMSA’s finding in the Satartia Consent Agreement that Denbury’s dispersion modeling for the pipeline that ruptured near Satartia was “wrong”, and the Consent Agreement’s requirement that Denbury conduct “overland” (CFD) modeling, may result in more and more CO2 pipeline companies conducting CFD modeling to avoid possible regulatory enforcement actions, higher fines, and greater civil liability in the event of a rupture.  

The potential for CO2 pipeline mass casualty events suggests that pipeline operators might voluntarily choose to use CFD modeling, even if it is expensive, as a means of reducing their potential liability.  Along these lines, insurance companies may also require CFD modeling so that they can accurately assess the degree of financial risk they face in the event of a rupture near high population areas.  This does not mean that pipeline companies will share their computer modeling results with the people put at risk by their pipelines.  They prefer that you simply trust them to protect you, your family, and your animals.  It’s cheaper and easier for CO2 pipeline operators if nobody except first responders knows the risks created by pipeline ruptures.  But, in rural areas how long will it take for first responders to show up?  What can you do until then?  

Instead of proactively determining and publicly disclosing accurate danger zones based on CFD modeling, the CO2 pipeline industry has instead resisted accurately defining danger zones and left the decision about disclosure to individual pipeline operators who almost universally keep this information secret.  Their industry’s resistance to using CFD modeling may be due to cost, and it likely resists public disclosure of modeling results because they might show that many are or will be at risk from existing and proposed CO2 pipelines, thereby creating citizen concern and opposition.  Such a position would be short-sighted.  In the long run, keeping those at risk in the dark will only increase distrust.

Even if governments and pipeline companies keep their plume modeling secret, the good news is that private citizens can do their own CFD and/or dispersion modeling.  The software is public and all needed data is either public or can be reasonably estimated based on public information.  The Abraham Paper proves that citizen CFD modeling is possible.  The practical result of government and company secrecy is not increased public safety, it merely forces communities to pay for their own modeling.   

What’s Good for the Goose Is Good for the Gander

CO2 pipelines are just one type of dangerous pipeline.  Others include natural gas, liquid natural gas, hydrogen, petroleum, and ammonia pipelines.  Danger zones for natural gas, hydrogen, and petroleum pipelines can be readily calculated using a publicly disclosed mathematical formula that requires knowledge of the contents, diameter, and pressure of the pipeline.  These danger zones are disclosed to inform pipeline routing and the siting of public housing, as well as to determine whether a pipeline is near a high population area such that higher federal maintenance and operation safety standards apply.  

For natural gas pipelines, PHMSA regulations contain a “potential impact radius” mathematical formula. 49 C.F.R. § 192.903.  All that is needed to use this formula is to know or estimate a natural gas pipeline’s diameter and operating pressure.  The formula is:  r = 0.69* (square root of (p*d2)), where ‘r’ is the radius of a circular area in feet surrounding the point of failure, ‘p’ is the maximum allowable operating pressure (MAOP) in the pipeline segment in pounds per square inch and ‘d’ is the nominal diameter of the pipeline in inches.  While the industry claims that pressure and pipeline diameters are confidential, as a general rule, pipeline diameters are public and pressure can often be discovered, too.  Even if pressure is not publicly available, a reasonable range of operating pressures can be estimated based on public information about natural gas pipeline operations.  Bottom line, knowing just the diameter and size of a natural gas pipeline allows anyone to estimate the potential impact (blast) zone of a natural gas pipeline. 

Similarly, the Federal Department of Housing and Urban Development (HUD) establishes “acceptable separation distances,” as defined by 24 C.F.R. §§ 201 and 203, between existing gas and oil pipelines and proposed affordable housing developments.  The “acceptable separation distances” for natural gas, hydrogen, and various types of petroleum pipelines are published as Appendix A: Baseline Pipeline Impact Radius Tables for MAP 9.6.S.1., which are attached to the Multifamily Accelerated Processing (MAP) Guide used to site housing.  Similar tables do not exist for CO2 pipelines, but they should.  The purpose of determining “acceptable separation distances” is to ensure that high population public housing is not built dangerously close to explosive pipelines so as to avoid the risk of a mass casualty event.  These distances are essentially danger zone estimates.  It just makes sense that the government should avoid building public housing near potentially dangerous existing pipelines.  It makes equal sense to avoid routing new dangerous pipelines near existing high population areas.  

Similarly, thousands of industrial facilities that use and store hazardous materials are required by state building and safety codes as well as federal agencies to provide mass alerts for chemical releases and to prepare and coordinate emergency response plans with government emergency response agencies.  For example, when an oil refinery blows, typically horns blare and text alerts are sent to those who live and work nearby, so that they can either evacuate or shelter in place.  The idea here is that informed communities are safer communities.  Just as do other industrial facilities, CO2 pipeline operators should provide mass alerts to potentially impacted citizens and businesses all along their pipeline routes. What’s good for the goose is good for the gander.  

What About Terrorism?

The CO2 pipeline industry claims that plume modeling must be kept secret to prevent terrorism, even if this means that citizens are at greater risk due to not knowing about or planning for this risk.  A bill in Congress, H.R. 6494, proposes to make all plume modeling required by federal law confidential for national security reasons.  For more information, check out Bold’s information page. 

For the following reasons, the CO2 pipeline industry’s claims that disclosure of plume modeling would facilitate terrorism are not well founded.  

First, any potential advantage to terrorists must be weighed against the benefits that disclosure to Americans would provide.  Disclosure of plume modeling would help Americans prepare to respond to a rupture appropriately, either by evacuation or sheltering in place.  Disclosure of plume modeling would also allow the public to confirm that company modeling efforts are based on reasonable assumptions and data, thereby increasing public safety.  Americans do not want to be designated victims.  They want to know the risks they face and have the opportunity to protect themselves.  

Second, as discussed above, estimates of danger zones can be determined for other types of hazardous pipelines based on a simple mathematical formula.  While CO2 rupture plume modeling is more complex, all danger zone size estimates boil down to a distance figure, such that complexity alone does not make CO2 plume modeling any more confidential than other more simple methodologies.  The general point here is that it makes sense to determine danger zones for proposed hazardous pipeline facilities so that they can be sited to avoid mass casualty events.  It also makes sense for those near existing CO2 pipelines to know the danger zones they create, so that neighboring communities know how to response to a CO2 pipeline rupture.  Just as at Satartia, ignorance of pipeline risks decreases public safety.  Hiding danger zone information does not decrease the risk of terrorism; it decreases public safety and makes unwise siting more likely.  

Third, terrorists are unlikely to need high-quality plume modeling to pick targets.  They are far more likely to pick targets based on a variety of practical factors, such as proximity to high population areas, that do not require access to plume modeling.  In contrast, public disclosure of plume modeling would likely force CO2 pipeline developers to route their pipelines away from vulnerable populations, thereby reducing the potential for disastrous terrorist attacks in the first place.  

Fourth, an actual pipeline rupture may or may not create the plume predicted by a particular plume model run, because the shape and extent of the plume would depend entirely on the circumstances and weather at the time of a rupture.  Wind speed and direction can change minute to minute.  The volume of CO2 released would depend on the operating conditions at the time of a terrorist attack.  Disclosure of modeling results would not provide information about actual operating conditions or the extent of an actual plume.  It provides an estimated danger zone critical to effective responder and community emergency response planning.  

Finally, there are no documented records of terrorist attacks on CO2 pipelines in the U.S.  It is true that some protestors have turned oil pipeline valves and damaged oil pipelines during their construction, but withholding plume modeling would not prevent these types of actions.  Moreover, it would seem extremely unlikely that terrorists would target CO2 pipelines in rural areas, because CO2 is not a strategic commodity and a rupture in a rural area would likely harm relatively few people, which is not what terrorists want.  Again, the best way to increase public safety is to prevent the unwise siting of CO2 pipelines near high-population areas through disclosure of plume modeling during routing decisions.

We should not let hypothetical terrorist use of plume modeling prevent citizens from knowing the risks of proposed and existing CO2 pipelines.  Ignorance does not increase public safety.  An informed community is a safer community.  

Conclusion

Hopefully, this blog series has increased your understanding of CO2 pipeline rupture plume modeling.  If you have concerns or disagree with this post, feel free to contact me.  This is a complex topic.  Ultimately, the more we understand the risks and health impacts of CO2 pipelines, computer modeling for CO2 pipeline ruptures, and how we can push back on industry efforts to keep plume modeling secret, the safer we will all be.  

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