EPA GHG Emission Requirements Could Affect Interstate Pipelines

By Stephen Barlas, Washington Editor | November 2009 Vol. 64 No. 11

"These alternatives will provide similar coverage of vented and fugitive methane and other GHG emissions in the oil and gas sector, while concurrently taking into account industry burden," the agency said. "Where applicable, EPA will also consider the applicability of engineering estimates, emissions modeling software and emissions factors rather than relying so extensively on the use of direct measurement. EPA will consider optimal methods of data collection in order to maximize data accuracy, while considering industry burden."

PHMSA Changes to Incident and Registry Reporting Raise Hackles
The Pipeline and Hazardous Materials Safety Administration (PHMSA) wants to change some of its rules on that topic too. Actually, INGAA is indirectly to blame for some of the new proposed requirements, such as when a interstate pipeline has to report an "incident." INGAA filed a petition in 2005 with PHMSA asking the agency to change the definition of incident, which was tied to the value of gas that was lost due to a "reportable incident." Under the current definition, a reportable incident includes estimated property damage, including cost of gas lost, of the operator or others, or both, of $50,000 or more.

In its petition, INGAA asserted that the current definition effectively freezes the dollar amount of the cost of an incident to 1984/1985 levels. Therefore, INGAA claims that, although less gas is being released, more incidents are being reported because the price of gas has escalated over time. The Government Accounting Office agreed with the INGAA contention in a report it issued in 2006.

INGAA recommended PHMSA establish a volume based threshold for a reportable incident and suggested 20,000 MCF (20 million standard cubic feet) as a reporting threshold. But PHMSA came back with 3,000 MCF because it more accurately represents the median volume of gas loss reported through transmission incident reports since 2002.

The other sore point in the PHMSA proposed rule, according to INGAA, is the creation of a National Registry of Pipeline and LNG Operators. This data will provide PHMSA with timely updates on significant and potential safety impacting changes occurring under its purview, and help PHMSA to better monitor and assess operator performance. In comments INGAA submitted in September, it said: "Unfortunately, the proposed regulations governing registry updates do not accord with basic business practices and far exceed similar requirements that have long been imposed by the Federal Energy Regulatory Commission."