Current Environmental Issues for Natural Gas Operators

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Current Environmental Issues for Natural Gas
Operators

• By Diane Walsh
• Dominion
• The Ohio Gas Association 2005 Technical Seminar

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• PCBS
• SPCC
• NPDES Storm water Permits
• Clean Air update

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PCBs
PCBs, or Polychlorinated Biphenyls, were
discovered in natural gas pipeline liquids in
Long Island NY in 1981. EPA, states and industry
formed a cooperative task force to look into this
problem. Extensive sampling revealed 13 major
natural gas transmission companies had PCB
contamination of gt 50 ppm in their lines. These
companies were subject to a Compliance
Monitoring Program (CMP) which allowed the
continued use of natural gas lines with certain
operating conditions.
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PCBs
The CMP was revised in 1996 and later replaced
with the 1998 PCB disposal amendments which
permitted the use of PCBs in natural gas
pipelines gt 50 ppm under certain conditions.
This was also called the PCB Mega Rule The
Mega Rule affected the way natural gas companies
replace, abandoned, remove and dispose of
pipeline and appurtenances.
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PCBs
PCB Rule Amendments are currently postponed,
pending the Dioxin Reassessment. EPAs Dioxin
Reassessment project could have a significant
impact on the PCB program if this assessment
includes proposed risk numbers for so-called
dioxin-like PCBs. If dioxin-like PCBs are
included in the Dioxin Reassessment along with
more stringent health impact numbers, this
would require EPA to make the PCB Mega Rule
requirements much more stringent.
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PCBs
Examples clean up levels are currently lt 10 ppm
could be dropped to 1 ppm.
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PCBs other fix it rule topics

• PCB Waste Storage in Satellite accumulation areas
  align PCB rules with RCRA storage rules (30
  days too short)
• Proposed PCB phase out
• Elimination of secondary containment requirement
  for non-liquid PCB storage
• Small Natural Gas Pipe Disposal in Landfills
  clarify that small diameter pipe (lt 4) need not
  comply with RCRA manifesting, recordkeeping and
  reporting requirements.

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• Wipe sampling to characterize PCB Levels in
  Natural Gas pipe. There is a movement to push for
  an alternative method for classifying natural gas
  pipeline when there are no available liquids at
  the sampling points for at least two consecutive
  years after initial round of characterization.

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PCB
Additional resources can be found on the EPA
website. The PCB Home page contains an
Interpretive Guidance Document called the PCB
Questions Answer Manual which addresses
specific questions and answers related to
natural gas operations. www. epa.gov/opptintr/pc
b/guidance.html
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NPDES
National Pollutant Discharge Elimination System
Storm water permit for oil and gas construction
activity that disturbs one to five acres of land.
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NPDES
On December 8, 1999 U.S. EPA published a final
rule which expanded the then-existing NPDES
permitting program to require permit coverage by
March 10, 2003 for construction sites that
disturb one to five acres. (64 FR 68722)
March 10, 2003, U.S. EPA published a final rule
which Expanded this deadline to March 10, 2005.
(68 FR 11325)
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NPDES
Activities are defined as construction activities
at oil and gas exploration, production,
processing, and treatment operations and
transmission facilities that disturb between one
and five acres.
Earth disturbance defined generally as clearing,
grading and excavating.
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NPDES

• March 8, 2005 EPA has announced it will extend
  the March 10, 2005 compliance deadline until June
  12, 2006 for storm water permit coverage for
  construction activities.

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NPDES
March 10, 2003 (68 FR 11327) defines the
following
Distribution lines are those pipelines that
deliver natural gas to homes, businesses, etc and
operate at relatively low pressures. EPA does
not consider distribution lines to be
transmission lines, and as such, are not
includedin the rule as potentially eligible
for the two year postponement
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NPDES
Transmission lines are typically major pipelines
that transport crude oil and natural gas over
long distances and are large-diameter pipes
operating at relatively high pressure. many of
these pipelines traverse long distances and
disturb over five acres (and as such are covered
by EPAs permitting requirements for large
construction sites).
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NPDES

• Are Distribution facilities subject to the Phase
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• storm water permitting requirements for
• construction activities?

2. Does the subject postponement apply?
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NPDES

• Option 1 Individual NPDES permit application.
• Option 2 File NOI form requesting coverage
  under a general permit
• Option 3 Routine Maintenance Exclusion from
  small Construction Activity Permitting
• For forms and general permit language www.epa.sta
  te.oh.us/dsw/storm

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SPCC
On July 17, 2002 U.S. EPA passed a final rule
which revised the Oil Pollution Prevention
regulations. These regulations outline certain
requirements for facilities to prepare, amend and
implement Spill Prevention, Control and
Countermeasure Plans (SPCC). These rules apply
to facilities that store and handle petroleum
based liquids in excess of 1320 gal. SPCC
Plans are part of the EPAs strategy to prevent
oil spills from reaching our nations waters.
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SPCC
The final rule required facilities to have their
SPCC plans updated to the new requirements by Feb
17, 2003 and to have all physical pollution
prevention measures to be in place by August 16,
2003. January 9, 2003 EPA extended the
compliance deadlines for 60 days to April 17,
2003 and October 18, 2003 (to allow more time
for facilities to comply) New extension was
promulgated as an amendment August 11, 2004
which extended some of the requirements to August
18, 2006.
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SPCC

• The final rule contained favorable and
  unfavorable changes that affected the natural gas
  industry. Although EPA believes their changes to
  be clarifications, the replacement of the word
  should with the word must has made a
  significant impact.

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SPCC

• Tank Loading/Unloading Areas
• Aboveground piping
• Engineering controls
• Tank Inspections
• Fencing
• Lighting
• Mechanical and Electrical Oil-containing
  Equipment
• SPCC Applicability Threshold (deleted 660 gallon)

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SPCC
Operators of natural gas pipelines and local
distribution systems are having difficulty
determining which facilities are covered by the
EPAs current SPCC rules for non- Transportation-
related facilities. Industry is pushing for
clarification from EPA to better define the rule
for these facilities or eliminate the
confusion of EPA vs DOT jurisdiction with respect
to pressurized vessels needed to operate
pipeline systems.
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SPCC
Additional information can be found on the EPA
website which provide resources to help you
understand, implement and develop SPCC Plans.
SPCC Compliance Assistance Guides and SPCC
reference Material is available to help natural
gas operators stay Current on relevant Agency
memoranda. www.epa.gov/oilspill/spcc.htm
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CAA
On March 10, 2005, the EPA announced the Clean
Air Interstate Rule (CAIR), a rule that will
achieve the largest reduction in air pollution
in more than a decade. CAIR achieves substantial
reductions in sulfur dioxide (SO2) and nitrogen
oxides emissions (NOx). SO2 and NOx Contribute
to the formation of fine particles and NOx
Contributes to the formation of ground level
ozone.
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CAA
States must meet required emission reductions
using one Of two options 1) meet the states
emission budget by requiring power plants to
participate in an EPA interstate cap and trade
system or 2) meet an individual state
emissions budget through measures of the states
choosing.
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CAA
Does this affect natural gas operators? The
answer is that it all depends on how each state
implements CAIR. States can choose to include
gas sources in the reductions necessary to meet
their CAIR requirements or they can choose not
to. No indications right now of how states
plan to address this. States could choose to
include gas emission reductions in their plans
to implement CAIR. More information
www.epa.gov/cair