Government Guidelines

Pipeline & Gas Journal, August, 1999 by Stephen Barlas

OPS Wants To Create Excavation Council

The Office of Pipeline Safety (OPS) is trying to get various industry groups to buy into the idea of creating a new independent industry group which would be responsible for building national support for safe excavation practices. Secretary of Transportation Rodney Slater announced the effort June 30 during a meeting in Washington, D.C. held to coincide with the release of the Common Ground report.

Prepared by a joint industry committee, the report makes 137 recommendations on how to prevent accidents where underground pipelines and cables are punctured by excavators. The report was required by the Transportation Equity Act for the 21st Century (TEA-21), which Congress passed in 1998.

The new independent council would ostensibly propagate these recommendations and take over some of the programs such as "Dig Safely" which have been funded by OPS with taxpayer dollars. Terry Boss, vice president of environmental programs for the Interstate Natural Gas Association of America (INGAA), says that since the interstate pipeline industry essentially funds those OPS programs through the user fees it pays, it would be nice to have the programs relocated to the new agency which would be funded by a number of sectors, including the telecommunications, railroad and construction industries.

Slater indicated he would kick in some federal funds.

Boss says setting up a private group is "a great idea" but it is important "that everyone get involved." He notes that at the meeting in Washington when Slater discussed the new group, the American Petroleum Institute and INGAA vocally supported the concept. "But no one else jumped up at that time," he adds.

Loren Sweatt, a spokeswoman for the Associated General Contractors (AGC), states that the AGC is considering whether it will get involved. "I am not so sure that all industry groups think we need to put dollars into this," she says. "States are already funding one-call centers and there is federal grant money authorized by TEA-21, which maybe this new group could get some of," Sweatt adds.

While INGAA's boss likes the idea, he says the new entity--whatever form it takes--must be focused and have adequate resources. "We are not necessarily pessimistic," he explains. "We are just trying to be realistic." --Stephen Barlas

EPA Refuses to Back Off On Emissions

INGAA failed to get the EPA to reduce pending air emission control requirements for glycol dehydration units. INGAA had argued that the 95 percent reduction requirement that EPA had been promising to impose on already-built "dehy" units could only be met by installing condensers on them. INGAA said the cost/benefit analysis was out of whack.

But in its final rule of June 17, the EPA declined to establish a separate standard, perhaps 70 percent hazardous air pollutant (HAP) reduction, which would have to be reached by dehy units using combustion technology. The EPA did, however, give the industry two alternatives to reducing HAPs (mostly benzene) by 95 percent. Companies could reduce emissions to an outlet concentration of 20 parts per million by volume (ppmv) or less for combustion devices or cut benzene emission levels to 0.90 Megagram/year or less.

These HAP reduction requirements apply only to major sources. They are defined as a unit which emits more than 10 tons of HAP a year, or a facility whose HAP emissions in total exceed 25 tons a year. Greg Nizich, the EPA official who worked on this rulemaking, says that the EPA based its three options on a study of 112 dehy units. The EPA believes those 112 represent about one-seventh of the market based on natural gas transported. So his assumption is that there are about 800 dehy units in the U.S. Of those, the EPA guesses that there are seven "major" sources. Some of them are probably already controlled, so they won't be affected by this rule.

The big question, however, is how many of the other dehy units are situated at sites with other sources of HAPs. For example, compressor engines emit HAPs. If the total HAP emissions from the dehy unit and compressors exceed 25 tons a year, then the dehy unit, even though a minor contributing source, is deemed to be a major source by virtue of the overall facility's emissions. The dehy unit would then probably have to meet one of the three control options.

Compliance dates are based on whether a facility or dehy unit was built before, or construction started before Feb. 6, 1998. If so, then the major source has until June 17, 2002 to get its emissions down. If construction on a facility or unit was started after that date, emissions have to be cut at the time the unit goes into operation or June 17, 1999, whichever date is later.

The agency did give a little in response to INGAA's contention that dehy units using condensers need flexibility in terms of measuring HAP levels. It said that a pipeline company could establish compliance with the 95 percent reduction via a 30-day rolling average.

The EPA also established a ceiling below which dehy units did not have to reduce emissions. That tripwire is: actual flowrate of natural gas to the dehy unit is less than 85 thousand m3/day, on an annual average basis; or the actual average benzene emissions from the dehy unit are less than 0.90 Mg/yr.