Comment from David BezansonPhD
David BezansonPhDSupportIndividual
Summary: The commenter, a private individual who lived near a pipeline explosion, supports the proposed action and advocates for more stringent safety regulations. They specifically call for mandatory odorants for CO2 and hydrogen, lower fugitive emission limits, the use of dedicated pipelines for hydrogen, and required safety training and equipment for operators.
Docket No. PHMSA–2021–0046
November 2023
I lived less than a mile away from a residential methane pipeline explosion that killed many residents and destroyed many houses. Such incidents do not benefit either the general public or the utility companies that own pipelines. The utility paid many hundreds of $millions to compensate victims.
PHMSA should establish more stringent regulations to prevent harmful pipeline incidents. CO2, hydrogen, and methane are commonly transported in pipelines and share 3 characteristics a) flammability, b) invisibility, and c) GHG effects on the atmosphere. Only methane has an odorant added that facilitates leak detection. An odorant should be required for CO2 as well as hydrogen.
Set a low rate of fugitive emissions for each, e.g., 1% or less. The EPA has long reported a figure of 1.4% for methane. This is based on self-reports by operators and industry. All recent research indicates that the fugitive emissions rate is far greater with one study finding it to be ten percent. Because hydrogen molecules are tiny compared to methane,
they can readily escape from pipelines designed for methane. This is one of the many reasons why blending H2 with CH4 in existing methane pipelines is risky. Permit transport of H2 in dedicated pipelines that are designed to carry such tiny molecules.
At operator expense, require operators to have safety and emergency response tools and equipment in case of hazardous leaks. Operators must provide annual training to staff to use such and to interface with public emergency services.