NLRB Pushing Pro-Union Agenda; EPA Proposal Affects Pipeline Compressors

September 2011, Vol. 66 No. 9

In another "class-location" related issue, the House bill contains no provisions on maximum allowable operating pressure (MAOP). MAOP was an issue in the San Bruno explosion. The Senate bill does contain a provision which would require all distribution and transmission pipelines to conduct a verification of records for all class 3 and 4 locations and in class 1 and 2 HCAs to insure MAOPs there which accurately reflect the pipeline's physical and operational characteristics. If those records are not available, the companies would have to submit the location of those pipeline segments to PHMSA. Also, companies would have to report having exceeded any MAOPs within five days of that happening.

The other "hot" issue in the House bill is the provision requiring operators to notify the National Response Center (NRC) of an incident within one hour of discovering the incident. Knepper and Charles Dippo, vice president, engineering services and system integrity for the South Jersey Gas Company, opposed the one-hour dictate. Knepper argued information collected within an hour or less of discovery may not be factual and is likely to result in confusion and misrepresentation while also causing state pipeline safety agencies to spend time and resources chasing after a large number of what could be minor events. Dippo said the one hour maximum time limit will require operators to report minor events to the NRC before there is time to assess if an event meets the federal reporting threshold.

EPA air emission proposal would affect pipeline compressors
The Environmental Protection Agency (EPA) published four related air emission standards which will affect all sectors in the oil and gas industry. Interstate pipelines will be most affected by two of the proposed rules. One sets New Source Performance (NSP) Standards for Volatile Organic Chemicals (VOCs). Centrifugal compressors would have to be equipped with dry seal rod-packing systems and reciprocating compressors would have to be replaced every 26,000 hours of operation.

The NSP standards for VOCs would also regulate "fracking" for the first time. VOC emissions would be minimized through the use of “green completions,” also called “reduced emissions completions.” In a green completion, special equipment separates gas and liquid hydrocarbons from the flowback that comes from the well as it is being prepared for production. The gas and hydrocarbons can then be treated and sold. EPA estimates that use of this equipment for the three- to 10-day flowback period reduces VOC emissions from completions and recompletions of hydraulically fractured wells by 95 percent.