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.