Pipeline Security Guidelines
Pipeline Security Guidelines
1 Introduction ............................................................................................................................... 1
1.1 Background and Purpose ............................................................................................... 1
1.2 Scope .............................................................................................................................. 1
5 Criticality ................................................................................................................................... 8
5.1 Introduction .................................................................................................................... 8
5.2 Facility Criticality .......................................................................................................... 8
8 Protective Measures for National Terrorism Advisory System (NTAS) Alerts ................ 28
1 INTRODUCTION
Under the provisions of the Aviation and Transportation Security Act (Public Law 107-71), the
Transportation Security Administration (TSA) was established on November 19, 2001 with
responsibility for civil aviation security and “security responsibilities over other modes of
transportation that are exercised by the Department of Transportation.” On September 8, 2002,
TSA initiated its pipeline security efforts. Those responsibilities now reside within the Office of
Security Policy and Industry Engagement’s Surface Division.
Recognizing that the Security Circular required updating, TSA initiated a process to amend the
Federal security guidance. The 2010 Pipeline Security Guidelines were developed with the
assistance of industry and government members of the Pipeline Sector and Government
Coordinating Councils, industry association representatives, and other interested parties. This
document was soon revised resulting in the 2011 Pipeline Security Guidelines.
The advancement of security practices to meet the ever changing threat environment in both the
physical and cyber security realms required that the guidelines be updated again. Utilizing a similar
industry and government collaborative approach, TSA developed this document, which supersedes
the 2011 version of the Pipeline Security Guidelines.
The security measures in this guidance provide the basis for TSA’s Pipeline Security Program
Corporate Security Reviews and Critical Facility Security Reviews. This document is guidance
and does not impose requirements on any person or company. The term “should” means that TSA
recommends the actions described. Nothing in this document shall supersede Federal statutory or
regulatory requirements.
1.2 Scope
These guidelines are applicable to operational natural gas and hazardous liquid transmission
pipeline systems, natural gas distribution pipeline systems, and liquefied natural gas facility
operators. Additionally, they apply to operational pipeline systems that transport materials
categorized as toxic inhalation hazards (TIH). TIH materials are gases or liquids that are known or
presumed on the basis of tests to be so toxic to humans as to pose a health hazard in the event of a
release during transportation. (See the Hazardous Materials Regulations: 49 CFR parts 171-180.)
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TSA Pipeline Security Guidelines
Corporate Security Program
Operators of pipeline systems not included in the descriptions above are encouraged to implement
the security measures contained herein to the extent appropriate to their particular system.
Figure 1 identifies the major steps that each pipeline operator should take in creating and
implementing a corporate security program and the relevant sections in the guidelines where
specific details are provided.
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TSA Pipeline Security Guidelines
Corporate Security Program
Critical Facility?
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TSA Pipeline Security Guidelines
Corporate Security Plan
3.1 Introduction
Operators should develop and implement a security plan customized to the needs of the company.
The corporate security plan should be comprehensive in scope, systematic in its development, and
risk-based reflecting the security environment. At a minimum, the plan should:
• Identify the primary and alternate security manager or officer responsible for executing and
maintaining the plan;
• Document the company’s security-related policies and procedures, to include, but not
limited to, methodologies used and timelines established for conducting criticality
assessments, risk assessments, and security vulnerability assessments (SVAs), if
applicable;
• Reference other company plans, policies and procedures such as insider threat, business
continuity, incident response and recovery plans;
• Be reviewed on an annual basis, and updated as required based on findings from
assessments, major modifications to the system or any of its facilities, substantial changes
to the environment in which it operates, or other significant changes;
• Be protected from unauthorized access based on company policy; and,
• Be provided to TSA for review upon request.
• System(s) Description - Identify the pipeline system(s) to which the plan applies.
• Security Administration and Management Structure - Identify the person(s) primarily
responsible for the corporate security program, and describe the responsibilities and duties
of personnel assigned to security functions.
• Risk Analysis and Assessments - Describe the methodology used to conduct security
risk analysis to include criticality assessments and SVAs.
• Physical Security and Access Control Measures - Describe the corporate policies and
procedures employed to reduce security risks throughout the company.
• Equipment Maintenance and Testing - Discuss policies and procedures for ensuring
security systems and equipment are maintained and function properly.
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TSA Pipeline Security Guidelines
Corporate Security Plan
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TSA Pipeline Security Guidelines
Risk Analysis
4 RISK ANALYSIS
4.1 Introduction
The intent of these guidelines is to bring a risk-based approach to the application of the security
measures throughout the pipeline industry. As stated in the National Infrastructure Protection Plan,
DHS assesses risk as a function of threats, vulnerabilities, and consequences. With this in mind,
the most effective security programs employ a risk management process that facilitates planning
and decision making to mitigate risks for pipeline assets. General elements include:
Recognizing that there are multiple risk assessment methodologies, each operator should
determine the process and methodology most appropriate for implementation of the corporate
security plan at the facilities comprising their pipeline system. TSA may ask to review the
operator’s risk assessment methodology.
• Conduct facility criticality assessments on a periodic basis, not to exceed 18 months, for
all facilities;
• Document the methodology used, and retain the criticality assessment until no longer
valid;
• Conduct an SVA or the equivalent as outlined in Section 4.3 of this document for
facilities determined to be critical; and
• Maintain and secure the company’s list of critical facilities.
The operator’s list of critical facilities is subject to review and evaluation by TSA. Operators and
TSA will work together towards concurrence on the facilities listed.
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TSA Pipeline Security Guidelines
Risk Analysis
• Conduct an SVA or the equivalent on a periodic basis, not to exceed 36 months, and within
12 months after completion of a significant enhancement or modification to the facility;
• Conduct an SVA or the equivalent for newly identified or constructed critical facilities
within 12 months of designation or after achieving operational status.
• Document findings from each assessment and retain them until no longer valid;
• Implement appropriate findings from the SVA in a timely fashion but no later than 24
months after SVA completion; and
• Document the assessment methodology used and make the documentation available for
TSA review upon request.
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
5 CRITICALITY
5.1 Introduction
The objective in determining which pipeline facilities are critical is to ensure that reasonable
appropriate security risk reduction measures are implemented thereby reducing the impact of
service disruptions to critical infrastructure and the public.
To aid operators in applying the guidance, the criteria are differentiated for each of the three
major pipeline subsectors:
• natural gas distribution
• natural gas transmission (to include LNG peak shaving and satellite plants)
• hazardous liquid transmission
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
A pipeline facility is defined as new and existing pipelines, rights of way, and any equipment,
facility, or building used in the transportation of gas or hazardous liquids or in the treatment of gas
or hazardous liquids during the course of transportation. 1 Critical facilities may include, but are
not limited to:
• pipeline interconnections
• metering and/or regulating stations
• pump stations
• compressor stations
• operational control facilities
• main line valves
• tank farms, terminals
If damage or destruction of a facility has the potential to meet at least one of the following
criteria, the facility or facilities should be designated as critical.
1
Consistent with definitions in 49 CFR § 192.3, 193.2007 and 195.2.
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
2
For these guidelines, a mass casualty incident is defined as an event that overwhelms the local healthcare system, where the
number of casualties vastly exceeds the local resources and capabilities in a short period of time.
3
49 CFR, Part 192 Subpart P, Gas Distribution Pipeline Integrity Management (IM).
4
49 CFR § 192.5.
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
Criteria Subsector Guidance
3. Cause mass Natural Gas Distribution High Risk (Tiered) Facilities under DHS CFATS
injuries, casualties (Cont.) Natural gas distribution operators should review
or significant health and consider as critical all facilities designated
or environmental as high risk under the DHS Chemical Facility
effects. (Cont.) Anti-Terrorism Standards (CFATS) program.
5
49 CFR § 192.903 and Appendix E to Part 192: Guidance on Determining High Consequence Areas and on Carrying Out
Requirements in the Integrity Management Rule.
6
49 CFR § 195.450, 195.452 and Appendix C to Part 195: Guidance for Implementation of an Integrity Management Plan.
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
Criteria Subsector Guidance
extended period of Natural Gas Distribution • complexes that provide essential public
time. (Cont.) service or emergency response capability7
7
See FEMA Continuity Guidance Circular (February 2018) and particularly National Essential Functions 6 – Provide Emergency
Services, 7 – Maintain Economic Stability, and 8 – Provide Basic Essential Services.
8
See FEMA Continuity Guidance Circular (February 2018) and particularly National Essential Functions 6 – Provide Emergency
Services, 7 – Maintain Economic Stability, and 8 – Provide Basic Essential Services.
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
Criteria Subsector Guidance
5. Disrupt or Natural Gas Distribution Not applicable
significantly reduce
the intended usage Natural Gas Transmission Not applicable
of major rivers,
lakes, or waterways Hazardous Liquid Hazardous liquid transmission operators should
(for example, public Transmission designate as critical all pipeline facilities that
drinking water for could significantly impact public drinking water
large populations or sources if state or local advisories are issued.
disruption of major
Hazardous liquid transmission operators should
commerce or public
designate as critical all pipeline facilities subject
transportation
to Oil Pipeline Response Plans9 impacting a
routes).
PHMSA-defined Major River-High Volume Area
or Other Navigable Waters. 10
9
49 CFR, Part 194 – Response Plans for Onshore Oil Pipelines.
10
49 CFR, Part 194 – Response Plans for Onshore Oil Pipelines, Appendix B.
11
Section 7.2, TSA Pipeline Security Guidelines (March 2018).
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TSA Pipeline Security Guidelines
Criticality Change 1 (April 2021)
Criteria Subsector Guidance
7. Significantly Natural Gas Transmission Natural gas transmission operators should
disrupt pipeline designate as critical all pipeline facilities where
system operations the loss or disruption of facility operations lasting
for an extended more than 14 days would significantly impact
period of time. overall deliverability and system safety.
(Cont.)
Factors to consider in determining criticality of a
facility include:
• whether a facility contains components
not readily available to the operator due
to long lead times or limited geographic
sourcing
• if a facility contains critical pipeline
cyber assets12
Natural gas transmission operators should
identify as critical operational control rooms
without a hot site backup (i.e., a backup control
room that is continuously running and where all
hardware and software are run concurrently with
the primary site).
Hazardous Liquid Hazardous liquid transmission operators should
Transmission designate as critical all pipeline facilities where
the loss or disruption of facility operations
lasting more than seven days would significantly
impact overall deliverability and system safety.
12
Section 7.2, TSA Pipeline Security Guidelines (March 2018).
13
Section 7.2, TSA Pipeline Security Guidelines (March 2018).
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TSA Pipeline Security Guidelines
Facility Security Measures
6.1 Introduction
Upon completion of the risk analysis process, operators should determine the appropriate
mitigation measures for both critical and non-critical facilities.
Operators should develop and implement both baseline and enhanced security measures at each
of their critical facilities.
Table 2 identifies the baseline and enhanced security measures for operators to implement at
appropriate pipeline facilities. Recurring actions are summarized in Appendix A.
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TSA Pipeline Security Guidelines
Facility Security Measures
Close and secure perimeter gates or Monitor and escort visitors at critical facilities.
entrances when not in use.
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TSA Pipeline Security Guidelines
Facility Security Measures
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TSA Pipeline Security Guidelines
Facility Security Measures
Communication
Communication
Develop internal and external notification Ensure primary and alternate communication
requirements and procedures for security capabilities exist for internal and external reporting
events. of appropriate security events and information.
Document and periodically update contact Establish a defined process for receiving,
(who) and communication (how) handling, disseminating, and storing security and
information for Federal, state, and local threat information.
homeland security/law enforcement
agencies. (See Appendix B for TSA contact
information.)
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TSA Pipeline Security Guidelines
Facility Security Measures
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TSA Pipeline Security Guidelines
Facility Security Measures
Outreach
Conduct outreach to nearby law
enforcement agencies to ensure
Outreach
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
7.1 Introduction
The operational technology used by the operators to manage their infrastructure and products are
vital to the pipeline system's safe and efficient operation. “Operational technologies” (OT) are the
systems that detect or cause a change through the direct monitoring and/or control of physical
devices, processes and events in the pipelines. OT systems include control systems (SCADA,
process control systems (PCS), distributed control systems (DCS)), measurement systems and
telemetry systems, which are collectively referred to as “pipeline cyber assets.”
The National Institute of Standards and Technology (NIST) has developed the Framework for
Improving Critical Infrastructure Cybersecurity, a set of standards and best practices to assist
organizations in managing cybersecurity risks and to promote the protection of critical
infrastructure. To implement an effective cybersecurity strategy, pipeline operators should
consider the approach outlined in the NIST Framework and the guidance issued by DHS and the
Department of Energy along with industry-specific or other established methodologies, standards,
and best practices (see Section 7.4).
• Critical pipeline cyber assets are OT systems that can control operations on the pipeline.
Baseline and enhanced security measures should be applied to these assets.
• Non-critical pipeline cyber assets are OT systems that monitor operations on the pipeline.
Baseline security measures should be applied to these assets.
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
Business Environment
Identify
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
Establish a process to identify and evaluate Ensure threat and vulnerability information
vulnerabilities and compensating security received from information sharing forums and
controls. sources are made available to those
responsible for assessing and determining
the appropriate course of action.
Access Control
Establish and enforce unique accounts for each Restrict user physical access to control
individual user and administrator, establish systems and control networks through the
security requirements for certain types of use of appropriate controls. Employ more
privileged accounts, and prohibit the sharing of stringent identity and access management
these accounts. practices (e.g., authenticators, password-
construct, access control).
In instances where systems do not support
unique user accounts, then implement
appropriate compensating security controls
(e.g., physical controls).
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
Protective Technology
Segregate and protect the pipeline cyber assets
from enterprise networks and the internet using
physical separation, firewalls and other
protections.
Regularly validate that technical controls comply
with the organization’s cybersecurity policies,
plans and procedures, and report results to
senior management.
Implement technical or procedural controls
to restrict the use of pipeline cyber assets
for only approved activities.
Anomalies and Events
Implement processes to generate alerts and log
cybersecurity events in response to anomalous
activity. Review the logs and respond to alerts
in a timely manner.
Detect
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
Improvements
Review the organization's cyber recovery plan
annually. Update as necessary.
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TSA Pipeline Security Guidelines
Pipeline Cyber Asset Security Measures
• American Chemistry Council, Guidance for Addressing Cyber Security in the Chemical
Industry
• American Gas Association (AGA) Report Number 12, Cryptographic Protection of
SCADA Communications, Part 1: Background, Policies and Test Plan
• American National Standards Institute (ANSI)/International Society of Automation (ISA)
– 99.00.01 – 2007, Security for Industrial Automation and Control Systems:
Terminology, Concepts, and Models
• ANSI/ISA – 99.02.01 – 2009, Security for Industrial Automation and Control Systems:
Establishing an Industrial Automation and Control System Security Program
• American Petroleum Institute (API) Standard 1164 Pipeline SCADA Security
• ANSI/API Standard 780, Security Risk Assessment Methodology for the Petroleum and
Petrochemical Industries
• U.S. Department of Commerce, National Institute of Standards and Technology (NIST),
Framework for Improving Critical Infrastructure Cybersecurity
• U.S. Department of Commerce, NIST, Special Publication 800-82, Guide to Industrial
Control Systems (ICS) Security
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TSA Pipeline Security Guidelines
Protective Measures for National Terrorism Advisory System (NTAS) Alerts
TSA has developed a supplement to this document containing recommended security measures to
reduce vulnerabilities to pipeline systems and facilities during periods of heightened threat and to
establish a consistent security posture within the pipeline industry. This supplement is unclassified
but sensitive and is marked as Sensitive Security Information (SSI). The password- protected
document may be obtained by email request to [email protected].
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TSA Pipeline Security Guidelines
Appendix A – Recurring Actions
RECURRING ACTIONS
12 Months 18 Months 24 Months 36 Months Other
Perform an annual Conduct facility Periodically update
review of the criticality contact and
corporate security assessments on a communications
plan and update as periodic basis, not to information for
required. (Section 3.1) exceed 18 months. government agencies.
(Section 4.2) (Table 2
Communication)
Conduct security drills
or exercises on a
periodic basis. (Table
2 Drills and Exercises)
Periodically review
facility staffing
requirements for
implementing
additional security
measures. (NTAS
Supplement, p.1)
Provide notification of
a pipeline incident in
accordance with
Appendix B.
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TSA Pipeline Security Guidelines
Appendix A – Recurring Actions
RECURRING ACTIONS
12 Months 18 Months 24 Months 36 Months Other
Conduct a SVA within Implement Conduct periodic
12 months of appropriate findings SVAs, not to exceed
significant NLT 24 months 36 months. (Section
modification to a after SVA 4.3)
critical facility, a newly completion.
identified critical (Section 4.3)
facility or a newly
constructed facility
identified as critical.
(Section 4.3)
Review site- Conduct key Verify the proper
specific security inventories every 24 operation and/or
measures months. (Table 2 condition of all security
Enhanced
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TSA Pipeline Security Guidelines
Appendix B - TSA Notification Criteria
When contacting the TSOC, provide as much of the following information as possible:
Actual or suspected cyber-attacks that could impact pipeline industrial control systems (SCADA,
PCS, DCS), measurement systems and telemetry systems or enterprise associated IT systems
should be reported to the National Cybersecurity and Communications Integration Center
(NCCIC) at 888-282-0870.
For questions or concerns, email the TSA Pipeline Security staff at [email protected]
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APPENDIX C – LIST OF ACRONYMS
AGA American Gas Association
ANSI American National Standards Institute
APGA American Public Gas Association
API American Petroleum Institute
CFR Code of Federal Regulations
DCS Distributed Control System
DHS U.S. Department of Homeland Security
DOT U.S. Department of Transportation
FEMA Federal Emergency Management Agency
HSEEP Homeland Security Exercise and Evaluation Program
HSIN Homeland Security Information Network
ICS Industrial Control System
INGAA Interstate Natural Gas Association of America
ISA International Society of Automation
IT Information Technology
NIST National Institute of Standards and Technology
NTAS National Terrorism Advisory System
PCS Process Control System
SCADA Supervisory Control and Data Acquisition
SSI Sensitive Security Information
SVA Security Vulnerability Assessment
TIH Toxic Inhalation Hazard
TSA Transportation Security Administration
TSOC Transportation Security Operations Center
WMD Weapons of Mass Destruction
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APPENDIX D – REFERENCE DOCUMENTS
Operators should consult the current edition of these and other security references on a frequent basis
in developing and reviewing their company’s security program. Cyber planning and implementation
guidance appears in Section 7.4.
American Gas Association (AGA), Interstate Natural Gas Association of America (INGAA) &
American Public Gas Association (APGA), Security Guidelines: Natural Gas Industry, Transmission
and Distribution
American Petroleum Institute (API) & National Petrochemical & Refiners Association (NPRA),
Security Vulnerability Assessment Methodology for the Petroleum and Petrochemical Industries
U.S. Department of Homeland Security, National Cyber Security Division, Catalog of Control
Systems Security: Recommendations for Standards Developers
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