Federal Excavation Requirements Imminent

February 2013, Vol. 68 No. 2

INGAA member companies operate approximately 1,000 natural gas-fired stationary combustion turbines and 6,000 natural gas-fired spark ignition reciprocating engines, according to Lisa Beal, vice president, Environment and Construction Policy, INGAA. The majority of turbines used in natural gas transmission are manufactured by Solar Turbines. Their turbines are designed with the three primary sections – the inlet compressor, combustion section and turbine – in three modular sections.

With like-kind replacement, a module can be exchanged with an analogous unit to limit down time. This allows routine overhaul to be completed at an off-site plant with special tooling and minimizes downtime for overhaul. EPA's concern is that when an industrial turbine is fixed offsite, the owner (pipeline company) has no control over the replacement parts used. Those parts can have a big impact on emissions once the turbine is back at the compressor station.

Auxiliary Pipeline Facilities May Require FERC Approval

Pipelines won't be able to build "auxiliary" facilities outside certificated rights of way and those work spaces if the FERC finalizes a proposed rule it issued in January. The issue focuses on whether interstate transmission companies have to come back to FERC and file a section 7 construction application if they want to add cathodic protection, electrical and communication equipment, pig launchers and receivers, and buildings beyond the existing right-of-way and work space. At issue is section 2.55 of the Commission's regulations which defines facilities that may be added, altered or replaced under a company's existing Natural Gas Act (NGA) section 7(c) certificate authorization, without the need for any additional authorization.

There appears to be some confusion in the industry in part because of some past, apparently erroneous FERC staff guidance. The Commission, in proposing to clarify what it says is existing policy, wants to have the chance to insure that construction work outside an approved right of way does not cause environmental damage. The FERC is not worried about valves being installed outside right-of-ways. More extensive modifications are a concern, though.

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