Appendix E

Carbon Dioxide Pipeline Risk Analysis

APPENDIX E
CARBON DIOXIDE PIPELINE
RISK ANALYSIS

HECA Project Site
Kern County, California
Prepared for
Hydrogen Energy International LLC
One World Trade Center
Suite 1600
Long Beach, CA 90831
May 19, 2009





TABLE OF CONTENTS
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1.0 Risk Evaluation............................................................................................................................ 1-1
1.1 U.S. Department of Transportation (DOT) Regulations.......................... 1-2
1.2 Regulatory Framework Governing Carbon Dioxide................................ 1-2
1.3 Industrial Evaluations for Carbon Dioxide Pipelines.............................. 1-2
1.4 Risk Definition......................................................................................... 1-3
1.5 Cause and Effect Analysis....................................................................... 1-5
2.0 Quantitative Failure Analysis ..................................................................................................... 2-1
2.1 Databases Used in the Statistical Analysis.............................................. 2-1
2.1.1 Historical Failure Rates................................................................ 2-2
2.1.2 European Gas Pipeline Incident Data Group/Oil and Gas
J ournal.......................................................................................... 2-4
2.2 Potential Adverse Consequences............................................................. 2-4
2.3 Standard Industry Practices...................................................................... 2-4
3.0 Potential Hazard Impacts and Consequence Modeling............................................................ 3-1
3.1 Carbon Dioxide Exposure Limits............................................................ 3-1
3.2 Consequence Model and Methodology................................................... 3-2
3.2.1 Carbon Dioxide Worst-Case Release Scenario............................ 3-3
3.3 Modeling Results..................................................................................... 3-4
4.0 Risk Analysis ............................................................................................................................... 4-1
4.1 Risk Probability....................................................................................... 4-1
4.2 Risk Evaluation........................................................................................ 4-2
5.0 Proposed Mitigation Measures................................................................................................... 5-1
6.0 References ................................................................................................................................... 6-1

List of Figures
Figure 1 Carbon Dioxide Pipelines in the United States
TABLE OF CONTENTS
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List of Tables
Table 1-1 Frequency Index
Table 1-2 Consequence Index
Table 1-3 Risk Index
Table 1-4 Sample Risk Matrix Combination of the Above-Mentioned Indices
Table 1-5 Pipes and Valves
Table 2-1 Existing Long-Distance Carbon Dioxide Pipelines in United States
Table 2-2 Detailed Report on Carbon Dioxide Pipeline Accidents between 1986 and 2008
Table 2-3 Failure Rates for Carbon Dioxide Pipelines
Table 3-1 Concentrations of Concern for Carbon Dioxide
Table 3-2 Potential Quantities of Carbon Dioxide Released Per Pipeline Segment After
Worst-Case Scenario Release
Table 3-3 Approximate Distances to Concentrations of Concern
Table 4-1 Failure Rates for Carbon Dioxide Pipelines
Table 4-2 Project Risk Matrix
Acronyms
ACGIH American Conference of Governmental Industrial Hygienists
ALOHA Areal Locations of Hazardous Atmospheres
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
DOT U.S. Department of Transportation
EOR Enhanced Oil Recovery
GHG Greenhouse Gases
HECA Hydrogen Energy California
HEI Hydrogen Energy International LLC
IDLH Immediately Dangerous to Life and Health
km kilometers
LORS laws, ordinances, regulations, and standards
MPa million Pascals
NIOSH National Institute for Occupational Safety and Health
NRC National Response Center
OCA Offsite Consequence Analysis
OSHA U.S. Occupational Safety & Health Administration
PEL Permissible Exposure Limit
ppm parts per million
SARA Superfund Amendment and Reauthorization Act
STEL Short Term Exposure Limit
TLV Threshold Limit Value
USEPA U.S. Environmental Protection Agency
USDOE U.S. Department of Energy

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1.0 Risk Evaluation
This appendix sets forth the Risk Evaluation conducted for an accidental worst-case release
scenario from the Projects carbon dioxide pipeline. Carbon dioxide does not manifest
hazardous properties (i.e., toxicity, reactivity, flammability, or explosivity) that would result in
regulatory classification as a hazardous material. However, as further discussed in Section 1.1
below, the current U.S. Department of Transportation (DOT) requirement for pipelines
transporting carbon dioxide (49 Code of Federal Regulations [CFR] 195) directs the operator to
perform a risk assessment. Pursuant to this DOT requirement and industry practice, the Project
conducted a risk analysis for the carbon dioxide pipeline.
Carbon dioxide captured in the gasification processes at the Project will be compressed and
transported to the custody transfer point for injection into deep underground hydrocarbon
reservoirs for CO
2
enhanced oil recovery (EOR) and sequestration (storage)
1
. A compressor will
pressurize (up to 2,800 psig) the carbon dioxide for offsite delivery. The carbon dioxide pipeline
will transfer the carbon dioxide from the Project Site southwest to the custody transfer point.
The carbon dioxidepipeline will consist of an underground pipeline buried approximately 5 feet
below grade for the majority of the route. Where crossing under the California Aqueduct and
Kern River Flood Control Channel, the carbon dioxide pipeline will be buried as deep as 100 feet
below grade. The length of the pipeline exposed above the subsurface, which connects the
compressor and underground pipeline, will be approximately 200 feet long and entirely within
the Project Site.
The carbon dioxide pipeline will be equipped with a series of emergency block valves that will
isolate various segments of the pipeline. The first block valve will be located at the end of the
200-foot aboveground pipeline segment from the compressor discharge, before the pipeline
transitions below ground. The pipeline will have block valves placed approximately 200 feet,
3,100 feet, 5,800 feet, and 21,800 feet from the point of origin. The last block valve is placed at the
custody transfer point, which is the pipeline terminus within the Elk Hills Field. The evaluation of
the potential risk associated with a worst-case release from the carbon dioxide pipeline will be
limited to pipeline segments from compressor discharge to the custody transfer point.
Transporting carbon dioxide in pipelines under high-pressure conditions is a process that is
commonly found in the petroleum and chemical industries. Within the United States alone,
approximately 3,500 miles of carbon dioxide pipelines are operating safely and securely under
standard industrial practices at pressurized conditions similar to those at the Project (see
Figure 1). To understand and manage the potential risks posed by the proposed pipeline, the
following analysis was conducted.

1
This carbon dioxide will be compressed and transported via pipeline to the custody transfer point at the adjacent
Elk Hills Field, where it will be injected. The CO
2
EOR process involves the injection and reinjection of carbon
dioxide to reduce the viscosity and enhance other properties of the trapped oil, thus allowing it to flow through
the reservoir and improve extraction. During the process, the injected carbon dioxide becomes sequestered in a
secure geologic formation. This process is referred to herein as CO
2
EOR and Sequestration.
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1.1 U.S. DEPARTMENT OF TRANSPORTATION (DOT) REGULATIONS
DOT has promulgated regulations for the construction, operation and maintenance of carbon
dioxide pipelines that could affect a high consequence area, as defined in the regulations
(49 CFR Part 195). Pursuant to Section 195.452, a pipeline operator must develop a written
integrity management program before commencing operation of the pipeline. Although the
Projects carbon dioxide pipeline may not affect a high consequence area, the Project will
develop an integrity management program in accordance with the regulatory requirements prior
to operation. In addition, operators must perform a risk assessment of the carbon dioxide
pipeline using the applicable criteria set forth in the regulation. The Project performed a risk
assessment as set forth in this Appendix.
1.2 REGULATORY FRAMEWORK GOVERNING CARBON DIOXIDE
The Project also examined the following federal and state statutes and regulations to determine
whether carbon dioxide is regulated as a hazardous substance under the project conditions:
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA)
Superfund Amendment and Reauthorization Act (SARA)
Emergency Planning and Community Right-to-Know Act of 1986
Risk Management Program for Chemical Accidental Release Prevention
California Accidental Release Prevention Program
Title 22, California Code of Regulations, Section 66261.20 et seq.
Carbon dioxide captured and distributed by the Project was not identified as a regulated
substance based on any of the regulations referenced above.
As an additional measure to be compliant with emerging rules and/or regulations dealing with
the use and/or generation of carbon dioxide, the Project also examined the proposed amendments
to the Clean Air Act proposed by the U.S. Environmental Protection Agency (USEPA) Proposed
Greenhouse Gases (GHG) Endangerment Finding. At this time regulatory requirements are
being developed to limit the emission of man-made GHGs, such as carbon dioxide, due to the
potential harm and health impacts those GHGs may present. Although pertinent to carbon
dioxide, the proposed rules/regulations focus on GHG emissions from new motor vehicles
instead of an accidental release from a facility, making this emerging rule/regulation not directly
applicable to the Project. Additionally, although these GHGs are being deemed to pose potential
harm and health impacts, the GHGs are not being identified as regulated hazardous substances
by the endangerment findings.
1.3 INDUSTRIAL EVALUATIONS FOR CARBON DIOXIDE PIPELINES
The Project examined the environmental and risk evaluations conducted by other projects
designing a carbon dioxide pipeline. The carbon dioxide pipeline project data examined relates
directly to the application of carbon dioxide for EOR and sequestration processes (USDOE,
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2007). In addition, risk assessments are regularly conducted for the evaluation of facilities
separating, compressing, and/or transporting carbon dioxide to injection sites. The risk
assessment approach is based on qualitative and quantitative estimates of carbon dioxide releases
under different failure scenarios. Failures of the engineered system include catastrophic events,
leakage, and fugitive releases of captured carbon dioxide. The dispersion of the released carbon
dioxide in the air is estimated using analytical modeling for heavy gas. Estimated concentrations
of carbon dioxide in air are then used to estimate the potential for exposure and any resulting
impacts on human and ecological receptors.
1.4 RISK DEFINITION
For the purpose of this study, risk was defined as a combination of the probability of occurrence
of a scenario versus the severity of its consequences. The following methodology was used to
define the magnitude of risk for this study:
Identify scenarios or events that may occur and have adverse consequences;
Estimate potential consequences from the release;
Estimate the likelihood of this event occurring; and
Evaluate the risk.
For this study, a semi-quantitative analysis based on historical data was used to develop a risk
matrix that determines the risk to the surrounding community from the proposed carbon dioxide
pipeline. Methodology for the development of this risk matrix followed accepted quantitative
risk assessment criteria (Deshotels and Zimmerman 1995) and hazardous materials transportation
risk analysis (Rhyne 1994). Indices of frequency (i.e., frequently, likely, rare, etc.) and
consequences (acceptable, severe, negligible, etc.) were combined to develop a risk matrix for
the Project (Tables 1-1 through 1-4). As presented in the risk matrix, Table 1-3, risk levels of 35
and above are considered an unacceptable risk category, levels of 21 and above present
undesirable risk levels, levels of 8 through 20 present a risk that is acceptable with controls or
mitigation, and the rest of the levels of risks are acceptable based on standard industrial
practices.
Table 1-1
Frequency Index
Range Frequency Description
7 Continual Expected to present itself during every point of operation
6 Very Frequent Once a month; Can be expected to occur in most operational circumstances
5 Frequent Once in three month ; May occur in most operational circumstances
4 Infrequent Once a year; May occur at some time
3 Possible Once in 5 years; Could occur at some time
2 Rare Once in 50 years; May only occur in exceptional circumstances
1 Extremely Rare Once in 100 years; May only occur in exceptional circumstances
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Table 1-2
Consequence Index
Range Consequences Health Impacts
Critical
Services
Interruption
Organizational
Outcomes/
Objectives Non-Compliance
7 Extreme
(Catastrophic)
Multiple deaths
and serious
prolonged health
impacts
Facility
closure and
cessation of all
activities
Complete
performance
failure
Serious, willful
breach; criminal
negligence or act
6 Large
(More than
Severe)
Multiple severe
health
crises/injury or
death
Indeterminate
prolonged
suspension of
work;
nonperformanc
e
Nonachievement
of objective/
outcome;
performance
failure
Serious, willful
breach; criminal
negligence or act
5 Medium
(Severe)
Severe health
crisis
Prolonged
suspension of
work
additional
resources
required;
performance
affected
Significant
delays;
performance
significantly
under target
Deliberate breach or
gross negligence;
formal investigation
4 Small
(Moderate)
Routine medical
attention
required
Short term
temporary
suspension
backlog
cleared <1
day
Minimal impact
on
organizational
objectives
Breach;
objection/complaint
lodged; minor harm
with investigation
3 Low
(Minute)
First aid or
equivalent only
No material
disruption
Minor impact on
organizational
objectives
Innocent procedural
breach; evidence of
good faith and proper
mitigation measures;
minor offsite impact;
no impact on sensitive
receptors (schools,
hospitals,
playgrounds, daycare
centers, residences,
etc.)
2 Limited
(Negligible)
May require first
aid or equivalent
only
No material
disruption
Insignificant
impact on
organizational
objectives
Innocent procedural
breach; evidence of
good faith and proper
mitigation measures;
no offsite impact
1 None
(No Consequence)
None None None None
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Table 1-3 Risk Index
Range Consequences Description
1 to 7 Acceptable Acceptable risk without requiring any changes
8 to 20
Acceptable with
Controls
Acceptable risk after recommended changes and modifications are
made to reduce risk
21 to 34 Undesirable Undesirable risk requires design changes or safety evaluation
35 and above Unacceptable Unacceptable risk major modifications and design changes required
Table 1-4 Sample Risk Matrix Combination of the Above-Mentioned Indices
Frequency
Extremely
Rare Rare Possible Infrequent Frequent
Very
Frequent Continual
Consequence 1 2 3 4 5 6 7
Extreme (Catastrophic) 7 7 14 21 28 35 42 49
Large (More than
Severe) 6 6 12 18 24 30 36 42
Medium (Severe) 5 5 10 15 20 25 30 35
Small (Moderate) 4 4 8 12 16 20 24 28
Low (Minute) 3 3 6 9 12 15 18 21
Limited (Negligible) 2 2 4 6 8 10 12 14
None (No Consequence) 1 1 2 3 4 5 6 7

1.5 CAUSE AND EFFECT ANALYSIS
This section provides a cause and effect analysis based on certain upset conditions that can lead
to a release of carbon dioxide from pipelines and associated equipment. The list presented below
is representative but not all inclusive. Some of the parameters identified that could cause an
upset condition are as follows:
High pressure/temperature conditions
Pipeline corrosion
External conditions
Human errors
Abnormal operation and maintenance
A cause and effect analysis of process deviations on piping and valves of the carbon dioxide
pipeline system are presented in Table 1-5.
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Table 1-5
Pipes and Valves
Deviation Cause Consequence Example Safeguards
Pipe & Valve
Failure
Corrosion
Maintenance errors
External impacts
(including third-party
damage)
Release of carbon
dioxide
Pipeline controls; Pressure
and temperature indicators
Automated block valves for
isolation
Inspections and
preventative maintenance
Cathodic protection
Pipeline will be pressure
rated to greater than the
maximum discharge
pressure of carbon dioxide
centrifugal compressor
Operator
Error
Maintenance errors
External impacts
(including third-party
damage)
Release of carbon
dioxide
Supervision of all
personnel; including
inspection of maintenance
and operation activities
Appropriate training and
experience requirements for
all personnel

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2.0 Quantitative Failure Analysis
The following sections describe the risk of upset assessment for the proposed carbon dioxide
pipeline and estimate the probability of failure and adverse consequences based on historical
accident records of carbon dioxide pipelines.
2.1 DATABASES USED IN THE STATISTICAL ANALYSIS
In order to estimate the historical failure rate of carbon dioxide pipelines, two sets of information
(databases) are necessary: (1) accident/spill records of carbon dioxide pipelines in the United States;
and (2) corresponding carbon dioxide pipelines currently in operation. At present (2009), more than
3,500 miles of carbon dioxide pipelines are operating in the United States (see Figure 1 and
Table 2-1) (Duncan 2009). These pipelines, at diameters ranging from 8 inches to 30 inches, are
mainly used to carry carbon dioxide from naturally occurring underground reservoirs to oil fields for
use in CO
2
EOR and Sequestration operations. These pipelines operate at conditions similar to those
proposed for the Project carbon dioxide pipeline. The pipelines are largely situated in the
midwestern to western portions of the United States where most of the EOR is occurring.
Table 2-1
Existing Long-Distance Carbon Dioxide Pipelines in United States
Pipeline Location Operator
Capacity
(Million Metric Tons of
Carbon Dioxide per year)
Length
(mile)
Year
Finished
Cortez Colorado to
Texas
Kinder Morgan 19.3 502 1984
Sheep
Mountain
Colorado to
Texas
Occidental 9.5 410 -
Bravo Colorado to
Texas
Occidental,
Kinder
Morgan,
Crosstimbers
7.3 217 1984
Canyon Reef
Carriers
Texas Kinder Morgan 5.2 139 1972
Val Verdes Texas Petrosource 2.5 81 1998
Weyburn North Dakota,
United States
to Canada
North Dakota
Gasification
Co.
5 203 2000
North East
J ackson Dome
Mississippi Denbury 11.5 182 1986
Free State Mississippi Denbury 6.7 86 2005
Delta Mississippi Denbury 7.7 31 2008
Cranfield Mississippi to
Louisiana
Denbury 2.88 51 1963
Total 77.58 1,902
Source: Duncan et al., 2008.
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The accident/spill records of carbon dioxide pipelines were obtained from the data provided by
the Office of Pipeline Safety at the DOT. Incident failure rate was also obtained from the
European Gas Pipeline Incident Data Group and analysis in the Oil and Gas J ournal. Based on
these data, the failure and accident frequency of carbon dioxide pipelines may be calculated.
2.1.1 Historical Failure Rates
Records covering the period 1986 to 2008 were obtained from DOTs Office of Pipeline Safety
through the National Response Center (NRC). For each reported accident, the database contains
information on such parameters as accident date, location, system component that failed, cause
of failure, commodity spilled, and failure consequences (fire, explosion, fatality, injury, and the
amount of property damage).
According to the NRCs accident database, a total of 13 accidents regarding carbon dioxide
pipelines occurred in the United States between 1986 and 2008 (Table 2-2). Of these 13
accidents, none had reported human injuries or fatalities, compared to the more than 5,000
accidents and 107 fatalities in the same period caused by natural gas and hazardous liquid
pipelines (Parfomak and Folger 2007). This information on carbon dioxide pipeline incidents
was used to estimate the failure rate (i.e., 13 accidents in 22 years in 3,500 miles of pipelines).
Table 2-2
Detailed Report on Carbon Dioxide Pipeline Accidents between 1986 and 2008
Date of
Incident Description Cause Location
Suspected
Responsible
Party
Medium
Affected
02/27/1994 Hazardous Liquid Pipeline/Gasket Failure Equipment
Failure
Texas Inron Liquids
Pipeline Co.
Air
04/15/1994 8-Inch Pipeline/External Corrosion Equipment
Failure
Oklahoma Arco Permian Air
06/15/1998 12-Inch carbon dioxide pipeline/DOT
Regulated/semi-truck ran into a structure
Operator
Error
Oklahoma Transpectco Air
11/19/2000 Strong odor reported from private citizen
and confirmed release from pipeline
12 inches below ground
Equipment
Failure
North
Dakota
Dakota
Gasification Co.
Air
01/13/2001 8-Inch transportation line discovered
leaking into the atmosphere due to a
unknown cause
Unknown North
Dakota
Dakota
Gasification Co.
Air
02/25/2001 14-inch distribution line leaked carbon
dioxide and hydrogen sulfide into the
atmosphere
Equipment
Failure
Texas Borger CO
2

Pipeline LLC
Air
03/07/2002 Third-party company contracted a
backhoe and hit a carbon dioxide
underground pipeline during digging.
Operator
Error
Oklahoma Air
02/25/2003 8-Inch transmission pipeline failed due to
corrosion and caused material to release
Equipment
Failure
Texas Chaparral
Energy
Air
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Table 2-2
Detailed Report on Carbon Dioxide Pipeline Accidents between 1986 and 2008
Date of
Incident Description Cause Location
Suspected
Responsible
Party
Medium
Affected
11/14/2003 Release of carbon dioxide due to valve
failure
Equipment
Failure
Mississippi Denbury
Resources
Air
10/14/2004 A leak was found on the CRC pipeline
releasing carbon dioxide
Under
Investigation
Texas Kinder Morgan
CO
2
Co.
Land
09/22/2006 A magnetic flux leakage (MFL) pig was
struck in a pipeline and when efforts were
made to remove the object, the line
developed a crack and discharged carbon
dioxide in to the air.
Equipment
Failure
North
Dakota
Dakota
Gasification Co.
Air
01/09/2007 Carbon dioxide was released to the
atmosphere from a 20-inch underground
pipeline.
Unknown Mississippi Denbury
Onshore LLC
Air
03/15/2007 An ice mound formed on a line used for
liquid carbon dioxide injection from
Texas to Oklahoma due to a pinhole leak.
Equipment
Failure
Texas Chaparral
Energy
Other
Table 2-3 shows that 46 percent of the accidents were caused by equipment failure. Close
examination of these accidents revealed that the majority were caused by failure of a
subcomponent (such as valve or gasket). The second most common cause was Unknown,
accounting for approximately 23 percent of all accidents. The average failure rate for this period
of time was 0.000169 failure per mile of carbon dioxide pipeline per year.
Based on these data, the upper bound of the projected failure rate for the approximately 4 miles
of carbon dioxide pipeline at the Project is 0.0007 failure per year.
Table 2-3
Failure Rates for Carbon Dioxide Pipelines
Failure Mode
Total Number of Accident
Between 1986 and 2008 Percentage
Historical Failure Rate per
Mile of Carbon Dioxide
Pipeline per year
Equipment Failure 6 46 7.77E-05
Corrosion 2 15.5 2.70E-05
Operation Error 2 15.5 2.70E-05
Unknown 3 23 3.89E-05
Total 13 100 1.69E-04
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2.1.2 European Gas Pipeline Incident Data Group/Oil and Gas Journal
In 2002, the European Gas Pipeline Incident Data Group reported that gas pipeline incidents had
been significantly reduced between 1970 and 2001. An analysis performed by Guijt in 2004
(Guijt 2004), which was published in the Oil and Gas Journal, also reported similar data. Guijt
presented an incident rate of almost 0.0010 kilometer (km)
-1
year
-1
(0.0016 mile
-1
year
-1
) in 1972,
which decreased to below 0.0002 km
-1
year
-1
(3.22E-04 mile
-1
year
-1
) in 2002. These incidents
include all unintentional releases outside of the limits of facilities originating from pipelines
whose design pressures are greater than 1.5 million-Pascals (MPa).
Applying the Guijt figures for European pipelines, the projected failure rate for the carbon
dioxide pipeline at the Project is 1.32E-03 failures per year.
2.2 POTENTIAL ADVERSE CONSEQUENCES
A carbon dioxide pipeline failure could result in loss of product containment, causing a release,
and, in rare instances, a large-scale rupture. According the incident statistics for carbon dioxide
pipeline compiled by Gale and Davison (2002), ten accidents occurred between the period from
1990 to 2002, with property damage totaling US$ 469,000, and no injuries or fatalities, since
unlike oil and gas, carbon dioxide is not flammable or explosive. As presented in Table 2-3, the
major reasons for the incidents were equipment failures and corrosion. This is contrary to
natural gas pipeline incidents, where an outside force, such as an excavator, is the principal cause
of incidents.
Carbon dioxide leakage can also be a potential physiological hazard for humans and animals.
The consequences of carbon dioxide incidents are modeled in the next section.
2.3 STANDARD INDUSTRY PRACTICES
Due to the adverse consequences that may occur from a possible carbon dioxide pipeline failure,
the industry has developed standard means to control the integrity and safe operation of
pipelines. These practices include routine inspections of the pipeline rights-of-way for third-
party actions, internal pipe inspections performed by in-line inspection tools (e.g., pigs), cathodic
protection programs, as well as leak detection systems. The specific industry practices for the
mitigation of carbon dioxide pipeline releases that will be used in the Project are presented in
Section 5 of this appendix.
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3.0 Potential Hazard Impacts and Consequence Modeling
The risk assessment methodology for the carbon dioxide pipeline and the regulatory reference
for conducting the assessment are presented in Sections 1 and 2 of this appendix. This section
presents an evaluation of a hypothetical worst-case release scenario to assess the maximum
potential consequence from the proposed pipeline as a precursor to the overall risk analysis
presented in Section 4, Offsite Consequence Analysis
An Offsite Consequence Analysis (OCA) was performed, using the methodology prescribed
under the California Accidental Release Prevention program and the federal Clean Air Act Risk
Management Program, to address the maximum potential consequence from a worst-case release
from the carbon dioxide pipeline. The models provide an examination of the dispersion of
carbon dioxide in the form of a vapor cloud. The modeling assumptions for a worst-case release
scenario are that the total contents from the largest inventory are accidentally released into the
atmosphere.
The modeling assumed worst-case atmospheric conditions during such a release, where
applicable. These conditions provide conservative results because these extreme and unlikely
climatic conditions maximize the vaporization to create the vapor cloud and minimize its
dispersion. For purposes of this analysis, the worst-case climate condition consists of an ambient
temperature of 115 degrees Fahrenheit (F) (the highest average temperature in the Project area),
a 50 percent average humidity, a wind speed of 1.5 meters per second, and a level F atmospheric
stability.
2

3.1 CARBON DIOXIDE EXPOSURE LIMITS
The modeling conducted to evaluate the potential impact area associated from a worst-case
carbon dioxide pipeline release used exposure limit concentrations levels of carbon dioxide as
established by the U.S. Occupational Safety & Health Administration (OSHA), the American
Conference of Governmental Industrial Hygienists (ACGIH), and the National Institute for
Occupational Safety and Health (NIOSH). The concentrations were examined to determine
which concentration levels would present the greatest hazard during a worst-case release
scenario.
These concentrations are stated in terms of (1) Permissible Exposure Limit (PEL), (2) Threshold
Limit Value (TLV), (3) Short Term Exposure Limit (STEL), and (4) Immediately Dangerous to
Life or Health (IDLH). Both the PEL and TLV specify airborne concentration levels under
which nearly all workers may be repeatedly exposed without potential adverse effects. The
STEL represents the concentration to which workers can be exposed continuously for a short
period of time without suffering from irritation, chronic or irreversible tissue damage, or narcosis
of sufficient degree to increase the likelihood of accidental injury, impaired judgment, or
materially reduction in work efficiency.

2
Level F atmospheric stability provides the most stable atmospheric environment where the tendency of the
atmosphere is to resist or enhance vertical motion and/or turbulencethis also contributes to minimum dissipation
of the vapor cloud.
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Table 3-1
Concentrations of Concern for Carbon Dioxide
Exposure Limit for
Carbon Dioxide Concentration Exposure Period
OSHA PEL 5,000 ppm
Time weighted average
concentration for 8-hour work
day
ACGIH TLV 5,000 ppm
Time weighted average
concentration for normal 8-hour
work day or 40-hour work week
OSHA STEL 30,000 ppm
Maximum concentration for
15-minute period (maximum of
4 periods per day with at least
60 minutes between exposure
periods)
NIOSH IDLH 40,000 ppm
The maximum level to which a
healthy individual can be exposed
to a chemical for 30 minutes and
escape without suffering
irreversible health effects or
impairing symptoms
Notes:
ACGIH = American Conference of Governmental Industrial Hygienists
IDLH = Immediately Dangerous to Life or Health
NIOSH = National Institute for Occupational Safety and Health
OSHA = Occupational Safety & Health Administration
PEL = Permissible Exposure Limit
ppm = parts per million
STEL = Short Term Exposure Limit
TLV = Threshold Limit Value
3.2 CONSEQUENCE MODEL AND METHODOLOGY
The extent of potential impact from the hypothetical accidental release was computed by using
the Areal Locations of Hazardous Atmospheres (ALOHA) 5.4.1 air dispersion modeling
program. ALOHA is a Gaussian plume model that incorporates continuous source and
meteorological parameters.
The ALOHA model was selected to model the release, as it is suitable for modeling the release
of a heavy gas (i.e., gas that is heavier than air) such as carbon dioxide. All the basic phenomena
associated with a heavy gas release, such as horizontal spreading, the mass exchange between the
plume and the plume temperature are considered through the ALOHA program. Operating
through Gaussian plume dispersion, the ALOHA model also takes into consideration the specific
atmospheric conditions that may affect a potential release.
SECTIONTHREE Potential Hazard Impacts and Consequence Modeling
R:\09 HECA Final\App E\App E.doc 3-3
3.2.1 Carbon Dioxide Worst-Case Release Scenario
In order to provide conservative results as to the extent of impact of a carbon dioxide release
from the Project, OCA models for hypothetical worst-case scenario releases were examined.
The modeling for the worst-case release scenario examined an instantaneous release from a
complete lateral shear and de-pressurization of pipeline sections isolated by emergency block
valves. Models were conducted to evaluate the release from four segments of the carbon dioxide
pipeline:
Segment 1: 200 linear feet of 12-inch-diameter aboveground pipeline from the
compressor discharge to the first block valve;
Segment 2: 2,904 linear feet of 12-inch-diameter underground pipeline from the first
block valve to the second block valve;
Segment 3: 2693 linear feet of 12-inch-diameter underground pipeline from the second
block valve, under the aqueduct, to the third block valve; and
Segment 4; 15,893 linear feet of-12-inch-diameter underground pipeline from the third
block to the final block valve at the custody transfer point.
The carbon dioxide will be transported as a supercritical fluid under highly pressurized
conditions. Due to the highly pressurized conditions, a complete shear or rupture of the pipeline
may displace the soil above the pipeline. Upon release and adiabatic expansion, it is estimated
that approximately 75 percent of the carbon dioxide volume within the affected pipeline segment
will be discharged as a gas. The remaining 25 percent of the carbon dioxide volume will
solidify, then vaporize slowly, resulting in a gaseous release into the atmosphere (GPSA, 2004.)
Since the weight of the soil above the pipeline would decrease the release rate, the worst-case
scenario of carbon dioxide release at each pipeline section was assumed to occur at the piping
connecting to the valve boxes, which are located near the ground surface level, resulting in a release
to the atmosphere. Additionally, the evaluation of the worst-case release scenario focused on the
estimated gas volume of the supercritical carbon dioxide released, because the carbon dioxide gas
volume presents the greatest potential for dispersion upon release into the atmosphere. Based on
these assumptions, this OCA analyzed the potential impacts of the carbon dioxide within the affected
pipeline segment being modeled at a ground-level elevation, which is the worst-case scenario.
For the worst-case release scenario, the rupturing of the carbon dioxide pipeline was assumed to
produce an 0.8-square-foot aperture (meaning a complete severing of the 12-inch-diameter
pipeline) at the connection to the valve box through which carbon dioxide would escape. The
worst-case scenario assumes that the total carbon dioxide volume of each section will release
through the rupture within 1 minute (the minimum duration used by the ALOHA model for
immediate releases). The atmospheric conditions modeled represent the least favorable
conditions for the normal dissipation of a concentrated carbon dioxide release.
In addition to the gas volume released from each isolated pipeline segment, the analysis also
accounted for the additional carbon dioxide that would be released during the reaction time for
activation of the automated emergency block valves. It would take approximately 20 seconds for
the carbon dioxide pipeline emergency block valves to activate based on pressure loss conditions
SECTIONTHREE Potential Hazard Impacts and Consequence Modeling
R:\09 HECA Final\App E\App E.doc 3-4
identified for the pipeline. Based on the foregoing, the total quantities of carbon dioxide released
for each segment of pipeline were calculated and are provided in Table 3-2.
Table 3-2
Potential Quantities of Carbon Dioxide Released Per Pipeline Segment
After Worst-Case Scenario Release
Length of Carbon Dioxide
Pipeline
(feet)
Total Potential Quantity
Released
(pounds)
200 8,817
2904 86,824
2693 80,736
15,893 461,540
Modeling results derived from the use of the ALOHA modeling program are provided in
Section 3.3 of this appendix.
3.3 MODELING RESULTS
The modeling of the worst-case scenarios demonstrated the following concentrations may be
reached at the following approximate distances during the hypothetical release. This information
was used for the risk analysis.
Table 3-3
Approximate Distances to Concentrations of Concern
Length of CO
2
Pipeline
(feet)
Concentration
of Concern
(ppm)
Approximate Distance to
Concentration of Concern
(feet)
30,000(STEL) 864
200
40,000 (IDLH) 756
30,000(STEL) 1,701
2,904
40,000 (IDLH) 1,452
30,000 (STEL) 1,668
2,693
40,000 (IDLH) 1,431
30,000(STEL) 2,409
15,893
40,000 (IDLH) 2,058
The area surrounding the pipeline route is mainly composed of native terrain and agriculturally
developed lands. As such, U.S. Census data shows minimal population density levels to be
present in areas that would potentially be impacted from the hypothetical worst-case scenario
release. No sensitive receptors were identified to be present within the potential area of impact.
SECTIONTHREE Potential Hazard Impacts and Consequence Modeling
R:\09 HECA Final\App E\App E.doc 3-5
Individuals who may be present in potential areas of impacts primarily include occasional
agricultural and oil production workers. The likelihood of a release occurring during the
presence of an occasional worker is low and remote.

SECTIONFOUR Risk Analysis
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4.0 Risk Analysis
The Risk Analysis provided in this appendix is based on the OCA evaluation of the worst-case
release scenario for the carbon dioxide pipeline and historical data regarding the operation of
carbon dioxide pipelines throughout the country. The worst-case release scenario OCA provided
the most conservative results as to the potential maximum area of impact that may be affected
from a total release of carbon dioxide from each of the individual pipeline segments. This
analysis was supplemented by historical data from government records on recorded carbon
dioxide releases, which was used to calculate the potential for such a release to occur.
The information gathered in the prior sections and the modeling results from the OCA were used
to perform the risk analysis described below.
4.1 RISK PROBABILITY
Based on historical data obtained from the DOTs Office of Pipeline Safety covering the period
1986 to 2008 through the National Response Center, the failure rate for this period of time was
determined to equal about 0.000169 failure per mile of carbon dioxide pipeline per year. No
record of catastrophic explosion or rupture has been recorded since the 1970s.
The probability of occurrence of an actual failure event was calculated using the incident data
from 1986 through 2008. As calculated in Section 2.1.1, the historical failure rate for the 4-mile
carbon dioxide pipeline is estimated to be about 0.0007 failures per year, which will not present a
significant likelihood of occurrence. The projected failure rate for each Failure Mode is
calculated through the equation below and presented within Table 4-1.
Projected Failure Rate
of each Failure Mode
=

Historical Failure Rate per Mile of Carbon Dioxide Pipeline
per Year Total length of Carbon Dioxide Pipeline
Table 4-1
Failure Rates for Carbon Dioxide Pipelines
Failure Mode
Historical Failure Rate per 4
Miles of Carbon Dioxide
Pipeline per year
Equipment
Failure
3.19E-04
Corrosion 1.11E-04
Operation Error 1.11E-04
Unknown 1.59E-04
Total 7.0E-04
SECTIONFOUR Risk Analysis
R:\09 HECA Final\App E\App E.doc 4-2
4.2 RISK EVALUATION
The OCA modeled worst-case releases assuming worst-case conditions and scenarios. These
modeling assumptions by definition present a very rare occurrence and thus have a very low risk
factor as set forth in the Risk Matrix presented in Table 4-2. In addition, various potential
scenarios that have a higher probability of occurrence, as confirmed by historical industry
experience in Section 2, were analyzed in the risk calculations for the Project. All potential
failures described in Section 2.1.1 were assessed for the Project and compiled in Table 4-2.
Table 4-2
Project Risk Matrix
Deviation Potential Scenario Consequence Frequency Risk
Equipment Failure Complete release of carbon
dioxide volume within pipeline.
7 1 7
Equipment Failure Partial carbon dioxide pipeline
breach and moderate release
5 1 5
Equipment Failure Minor leak in carbon dioxide
pipeline.
3 1 3
Operator Error Complete release of carbon
dioxide volume within pipeline.
7 1 7
Operator Error Partial carbon dioxide pipeline
breach and moderate release.
5 1 5
Operator Error Minor leak in carbon dioxide
pipeline.
3 1 3
Based on Table 4-2, a catastrophic incident has a value of 7 on the Consequence Index.
However, since a catastrophic incident, where the entire contents of the pipeline are immediately
released, is extremely rare, it is rated a 1 on the Frequency Index. This scenario will result in a
risk factor of 7 on the Risk Matrix (Table 4-2). In the case of moderate carbon dioxide releases
and minor leaks, the frequency value is calculated based on the historical data presented in
Table 4-1, which still shows a frequency of less than 1 incident per year per mile of carbon
dioxide pipeline. These releases have similar frequency, resulting in a risk rating ranging from 3
to 7. This range of risk values is acceptable based upon the standard risk methodology, as shown
in Tables 1-3 and 1-4, and demonstrates that the carbon dioxide pipeline will have a less-than-
significant risk. Results from this evaluation showed that the potential impact of any release
occurring from the Projects carbon dioxide pipeline will be less than significant.
SECTIONFIVE Proposed Mitigation Measures
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5.0 Proposed Mitigation Measures
Although the carbon dioxide pipeline for the Project will pose less-than-significant risks, in order
to reduce the potential impacts from an accidental release, the Project will incorporate various
mitigation measures to reasonably prevent and control any potential accidental carbon dioxide
releases. The Project will design, construct, operate, and maintain the carbon dioxide pipeline in
accordance with applicable laws, ordinances, regulations, and standards (LORS). The following
factors were considered in defining control and mitigation measures for pipeline safety:
Pipeline Design Pressure and Temperature: The design pressure and temperature will be
selected in accordance with prudent engineering practice and applicable LORS.
Depth of Burial: The carbon dioxide pipeline will be buried approximately 5 feet below
grade. This is an additional 2 feet greater than required by the DOT.
Pipeline Routing: Pipeline route identification markers will be placed at regular intervals or
prescribed locations to identify the buried pipeline and the Project will comply with
applicable regulatory requirements to reduce the likelihood of third-party damage. Most of
the pipeline route will pass through private property. HEI will enter into arrangements with
property owners for controlled access of the area.
Pipe Material Selection: The pipe will be constructed with steel that meets design criteria
for operations internal pressures and external loads, and pressures anticipated for the pipeline
system. The pipe will be constructed with materials in accordance with prudent engineering
practice and applicable LORS.
Internal-Corrosion Control: The Project will employ internal-corrosion control measures
in accordance with prudent engineering practice and applicable LORS. An internal-corrosion
inspection, monitoring, and assessment program will be established.
External Internal-Corrosion Control: The Project will employ external internal-corrosion
control measures in accordance with prudent engineering practice and applicable LORS. An
internal-corrosion inspection, monitoring, and assessment program will be established.
Block Valves: Block valves will be installed on the carbon dioxide pipeline to block-in the
pipeline in the unlikely event of a loss of integrity.
Pipeline Control: A Project control system will provide reliable and responsive controls to
detect potential leaks. Real-time monitoring of key parameters, including pressure,
temperature, and flow rate, enables timely intervention in the event of a release.
Right-of-Way Inspections: At intervals not exceeding 3 weeks, but at least 26 times each
calendar year, the Project will inspect the surface conditions on or adjacent to each pipeline
right-of-way.
SECTIONFIVE Proposed Mitigation Measures
R:\09 HECA Final\App E\App E.doc 5-2
Industry experience to date demonstrates that carbon dioxide can be safely handled and stored,
and suggests that the likelihood of an accidental release of carbon dioxide to be remote when
proper handling procedures are effectively applied. The implementation of the appropriate
prevention and control mitigation measures noted above will further reduce the likelihood and
potential impact of an accidental pipeline release, thereby further reducing the potential risk from
the operation of the carbon dioxidepipeline.
SECTIONSIX References
R:\09 HECA Final\App E\App E.doc 6-1
6.0 References
Deshotels, Robert and Robert Zimmerman, 1995. Cost Effective Risk Assessment for Process
Design.
Duncan, Ian, Nicot, J ean-Philippe and Choi, J ong-Won, 2008. Risk Assessment for future CO
2

Sequestration Projects Based CO
2
Enhanced Oil Recovery in the U.S. November 16-20,
2008 (April 23, 2009). http://www.beg.utexas.edu/gccc/bookshelf/2008/GHGT9/08-03i-
Final.pdf.
Duncan, Ian, 2009. Statement by Ian Duncan The Future of Coal under Climate Legislation
Carbon Sequestration Risks, Opportunities, and Learning from the CO
2
-EOR Industry.
March 10, 2009. (April 23, 2009). http://www.energycommerce.house.gov/
Press_111/20090310/testimony_duncan.pdf.
Gale, J . and J . Davison, 2002. Transmission of CO
2
safety and economic considerations.
GPSA (Gas Processor Association), 2004. Properties of Carbon Dioxide. GPSA Engineering
Data Book FPS Volume II.
Guijt, W., 2004. Analyses of incident data show U.S., European pipelines becoming safer. Oil
and Gas J ournal, J anuary 26, 2004, pp. 68-73.
Parfomak, Paul W. and Peter Folger, 2007. CRS Report for Congress Carbon Dioxide (CO
2
)
Pipelines for Carbon Sequestration: Emerging Policy Issues. April 19, 2007. (J uly 2,
2008). http://ncseonline.org/NLE/CRSreports/07May/RL33971.pdf.
Rhyne, William R., 1994. Hazardous Materials Transportation Risk Analysis Quantitative
Approaches for Truck and Train.
Stromberg, Professor Lars, 2005. CO
2
Capture and Storage Part of the Solution to the
Climate Change Problem?, European Energy Forum. J anuary 17, 2005. (April 23,
2009). http://www.europeanenergyforum.eu/archives/european-energy-forum/
environmental-matters/co2-capture-and-storage-2013-part-of-the-solution-to-the-climate-
change-problem.
USDOE (U.S. Department of Energy), 2006. Final Risk Assessment Report for the FutureGen
Project Environmental Impact Statement.
Willbros Group Inc., 2000. Cortez Carbon Dioxide Pipeline Shell Pipeline Company J uly
24, 2000. (April 27, 2009). http://www.willbros.com/_filelib/FileCabinet/Projects/
North_America/Cortez.pdf?FileName=0025.pdf.

May 2009
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Hydrogen Energy California (HECA)
Kern County, California
FIGURE 1
CARBON DIOXIDE PIPELINES IN THE U.S.
5/20/09 vsa..T:\HECA\GRAPHICS\Appx E_CO2\Fig 1_CO2 pipelines.ai
Source: Stromberg, 2009