WRITTEN STATEMENT OF KRISTA L. EDWARDS

DEPUTY ADMINISTRATOR

PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION

U.S. DEPARTMENT OF TRANSPORTATION

BEFORE THE

COMMITTEE ON ENERGY AND NATURAL RESOURCES

UNITED STATES SENATE

- - JANUARY 31, 2008 - -

Chairman Bingaman, Ranking Member Domenici, members of the Committee:
Thank you for the opportunity to discuss the safety programs
administered by the U.S. Department of Transportation's Pipeline and
Hazardous Materials Safety Administration (PHMSA) and our experience in
overseeing the commercial transportation of carbon dioxide.

As the Committee considers future requirements for carbon capture and
sequestration, I am pleased to confirm that large volumes of carbon
dioxide (CO2) are shipped safely in the U.S. today, including by
pipeline. PHMSA's existing programs and standards governing CO2
transportation provide effective protection to life and property, with
due regard for the efficiency and performance of the transportation
system.

As the DOT agency with jurisdiction over the movement of hazardous
materials by all transportation modes, PHMSA has extensive experience
managing the risks of compressed CO2, in each of its physical states:
gas, liquid, and solid (dry ice). Unlike natural gas and other gases
regulated as hazardous materials, CO2 is noncombustible and nontoxic. A
colorless, odorless by-product of human respiration, CO2 is present
naturally in the environment and, at normal atmospheric levels, is vital
to plant life and poses no immediate hazard to people or animals. In
higher concentrations, as when CO2 is contained for transport or
storage, exposure to CO2 can cause respiratory problems, including
suffocation. CO2 reaches its liquid state at combinations of high
pressure and low temperature. Both variables affect the consequence of a
release of liquefied CO2 in each case depending on the proximity of
people and the location and surrounding conditions. In a remote,
unpopulated area, even a large release of liquefied CO2 will vaporize
harmlessly into the atmosphere and is unlikely to cause serious injury.
By contrast, a large, sudden release of liquefied CO2 could have
catastrophic consequences in a populated area. Because it is heavier
than air, compressed CO2 tends to pool near the ground, displacing all
oxygen, and form a vapor cloud as it dissipates.

Because of these properties when compressed and/or in high
concentrations, CO2 has long been considered a hazardous material
subject to the Hazardous Materials Transportation Laws, 49 U.S.C. 5101
et seq., and DOT's implementing regulations, 49 C.F.R. parts 171-180,
governing transportation by air, rail, highway, and water. PHMSA's
Hazardous Materials Regulations (HMR) prescribe a comprehensive risk
management framework for CO2 transport, covering classification,
packaging, handling, and hazard communication (shipping documentation
and labeling). The packaging standards for CO2 transport vary based on
volume, pressure, and transportation mode; in each case, the HMR mandate
the use of an approved cylinder or tank, subject to specific
requirements for design, testing, certification, and filling.

The Department assumed oversight of CO2 pipelines in 1988, under
legislation directing the Secretary to develop regulations for the safe
transportation of CO2 by pipeline. Pursuant to the mandate, in 1991, the
Department extended its existing hazardous liquid pipeline rules (49
C.F.R. part 195) to these operations. CO2 pipelines became subject to
additional integrity management requirements when the liquid IM program
was adopted in 2000.

As with liquid operations generally, PHMSA shares oversight of certain
CO2 pipelines with authorized State programs. Together with these State
partners, PHMSA currently oversees close to 4,000 miles of CO2
transmission pipelines (as depicted in Figure 1) – amounting to
roughly five percent of all hazardous liquid pipeline mileage under our
jurisdiction. Of these CO2 lines, approximately 66% are interstate
(crossing State borders) pipelines with the remaining 34% classified as
intrastate (within State borders). Located primarily in the States of
Texas, New Mexico and Wyoming, these pipelines deliver CO2 for a
variety of industrial purposes, including enhanced oil recovery
activities. Within the national pipeline network as a whole, the CO2
lines are relatively new: approximately 91% were constructed after 1980.

[Image depicting: CO2 Pipelines in US as of 12/17/07]

As the Administration and Congress work to enhance our Nation's energy
security and protect the environment, we understand the need to extend
the transportation infrastructure – including the delivery of
alternative fuels and the transport of CO2 for sequestration or use in
energy production. And we understand the importance of pipeline
transportation for safe and efficient movement of large volumes of
hazardous materials. With the right risk controls in place, pipelines
can operate safely anywhere – it's not a matter of "if," but "how."

PHMSA's pipeline safety program aims to promote continuous improvement
in public safety, environmental protection, and system performance by
identifying and addressing all threats to pipeline integrity and
mitigating the consequences of pipeline failures. Our regulations cover
the design, construction, maintenance, and operation of liquefied
natural gas (LNG) facilities and hazardous liquid and natural gas
pipelines, both interstate and intrastate, including the gas
distribution systems that directly serve homes and businesses. We work
closely with national and international standards organizations and
encourage the development of consensus standards complementing our
performance-based regulations.

Our integrity management regulations, which currently apply to
transmission pipelines (liquid and gas), require operators to conduct
risk assessments of the condition of their pipelines; develop and
implement risk control measures to remedy safety problems, worst first;
and evaluate and report on program progress and effectiveness. Under
integrity management programs, operators are identifying and repairing
pipeline defects before they grow to failure, producing steady declines
in the numbers of serious incidents.

Along with risk-based standards and practices, technological advances
are driving significant improvement in the control of pipeline risks.
PHMSA administers a cooperative research program that promotes the
development of new methods, materials, and tools for improving leak
detection systems and detecting and preventing corrosion, outside force
damage, and other threats to pipeline integrity. We work closely with
informed stakeholders, including other Federal agencies, our State
partners, and industry, to target our limited R&D funding on promising
technologies to address the most urgent safety issues. Most recently, in
preparation for the growing use of alternative fuels, our R&D program is
focused extensively on technical issues associated with the movement by
pipeline of ethanol and ethanol-blended fuels.

As an agency dedicated to the safe transportation of hazardous
materials, PHMSA must be more than a regulator. Our success depends on
our ability to leverage non-regulatory solutions and to work closely
with all stakeholders who can contribute to safety outcomes, including
communities in the path of existing or new pipelines. Although PHMSA has
no authority in pipeline siting, we work closely with the Federal Energy
Regulatory Commission (FERC) in reviewing designs for proposed gas
transmission pipelines and liquefied natural gas (LNG) facilities and in
responding to local concerns about pipeline safety. We consult with
other Federal and State agencies on how our regulatory requirements
relate to their permitting decisions about pipelines. Recognizing that
public decisions affecting transportation and energy supply often must
be made at a national level, we believe a pipeline safety program can
and must involve local communities, including zoning and planning
officials and emergency responders. As part of a comprehensive approach
to pipeline safety, we believe in preparing communities to make
risk-informed land use decisions and in building local capability to
respond to pipeline incidents. PHMSA works closely with fire service
organizations on numerous safety projects, including the development of
training standards and educational materials concerning pipeline
incident response.

To carry out our oversight responsibilities, PHMSA operates five
regional pipeline safety offices and is authorized to employ 111
inspection and enforcement professionals for fiscal year 2008. In
addition to compliance monitoring and enforcement, PHMSA's regional
offices respond to and investigate pipeline incidents and participate in
the development of pipeline safety rules and technical standards. Our
regional offices also work closely with PHMSA's State program partners
which employ approximately 400 pipeline inspectors and directly oversee
the largest share of the U.S. pipeline network, including most
intrastate pipelines. Under our Congressionally-authorized Community
Assistance and Technical Services (CATS) program, PHMSA's regional
offices provide safety-focused community outreach and education. With
the current wave of pipeline expansion, and increasing commercial and
residential development around existing pipelines, the CATS program is
serving a vital role in educating the public about pipeline safety and
encouraging risk-informed land use planning and safe excavation
practices.

[Graph depicting: Serious Pipeline Incidents Involving Death or Injury
(1998-2007)]

With safety our top priority, under Secretary Peters' leadership, the
Department is targeting the prevention of all transportation-related
deaths and injuries. Although further improvement is needed, the safety
record for hazardous materials transportation is good and getting better
in all sectors, including hazardous liquid pipeline operations. Since
the introduction of IM programs in 2000, the annual number of serious
incidents involving hazardous liquid pipelines has reached historic
lows, even as the size of the pipeline network has grown. Although the
data sets are not yet large enough to make statistically significant
comparisons, the trend line over the past 20 years (as depicted in
Figure 2) is favorable.

Within these data, the safety record for CO2 pipelines is particularly
good. Of the 3,695 serious accidents reported on hazardous liquid
pipelines since 1994, only 36 involved CO2 pipelines. Among the 36
incidents, only one injury, and no fatalities, was reported. In all
other instances, the accidents were classified as serious based on the
extent of property damage (including damage to the pipeline facility) or
product loss.

With the benefit of this experience and record, PHMSA is pleased to work
with the Committee, our Federal and State partners, and industry to
prepare for the safe operation of new or extended CO2 pipelines. The
existing pipeline safety program administered by PHMSA has provided
effective oversight of CO2 pipelines since 1991 and will accommodate new
and expanded carbon dioxide pipelines, however they are configured. We
are happy to work with the Department of Energy and other Federal
partners to evaluate the feasibility of particular pipeline
configurations and/or plan for their development.

Likewise, PHMSA is committed to working with any agency or agencies
involved in siting CO2 pipelines, just as we work with FERC today in
connection with the licensing of gas transmission pipelines and LNG
facilities. We offer our agency's considerable experience and technical
expertise to the Committee as it considers and addresses the
transportation requirements associated with CO2 capture and
sequestration.

Mr. Chairman, I want to assure you and members of the Committee that the
Administration, Secretary Peters, and the dedicated men and women of
PHMSA share your strong commitment to safe, clean, and reliable pipeline
transportation. Like you, we understand the importance of PHMSA's
mission to the Nation's economic prosperity and energy security, and we
look forward to working with the Committee to address the current
challenges.

Thank you.

