Underground Infrastructure - October 2023 - 16

Washington Watch
intrastate activities that require federal permits and authorities
remain subject to Section 401.
Again, while the changes had not been announced when the
Senate hearings took place, testimony at those hearings from
representatives of the electric power and alternative energy industries
seemed to downplay concern about permitting lawsuits.
If opposition to the Biden NEPA changes is something less
than energetic, that will leave the pipeline industry to carry water
by itself. This will be a heavy political lift, especially given a unified
environmental industry support for the Biden-proposed changes.
Proposed PHMSA leak detection changes
run into pipeline opposition
While CEQ's proposed NEPA changes would affect how all federal
agencies review potential GHG emissions for various industry
energy construction projects, the Pipeline and Hazardous
Materials Safety Administration (PHMSA) wants to restrict
methane emissions for already-installed pipelines, as well as
new ones. PHMSA issued a proposed rule in July implementing
a couple of key sections in the Protecting our Infrastructure of
Pipelines and Enhancing Safety Act of 2020.
A host of provisions in that proposed rule included
strengthened performance standards for advanced leak detection
programs, leak grading and repair criteria with mandatory
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repair timelines, and requirements for mitigation of emissions
from blowdowns.
PHMSA would give the industry six months to comply with
the new control requirements. INGAA says the industry would
need three years to assess numerous considerations prior to
purchase or rental of temporary compression units, such as
mechanical capability, infrastructure siting, air compressor or
compressor power, and much more.
INGAA estimates that the costs for gas transmission operators
to comply with these new proposals will range between
$228 to $516 million annually. It maintains these cost totals are a
stark contrast to PHMSA's assumption of $14.9 million per year.
It comes as no great surprise that pipeline groups are now
complaining the proposal went too far in numerous places,
and environmentalists are arguing it did not go far enough in a
couple of places.
A key area of disagreement is how far PHMSA should be
able to go beyond addressing public safety concerns, the agency's
traditional mandate, to trying to also address environmental
concerns. The 2020 law gives PHMSA a bit of leeway here.
Where PHMSA deploys this latitude is the part of the
proposal that sets out how a pipeline operator should handle
blowdowns or venting for scheduled repairs, construction,
maintenance and operations tasks. Flaring is one option which
PHMSA, with the support of environmental groups, is trying to
limit as opposed to venting.
The Environmental Defense Fund, for example, says while
flaring is clearly preferable to venting gas, it should only be used
as a last resort to reduce emissions, after other options to reduce
gas releases during blowdowns and similar processes have
all been fully utilized.
It argues PHMSA should strengthen its proposal to clearly
require that operators use as many of the non-flaring methods
as are applicable in each situation to reduce the volume of gas
released to the greatest extent possible, and then utilize flaring
to reduce emissions from the residual gas release.
PHMSA proposes six methods pipelines may use to reduce
the release of gas to the environment:
* Isolate the smallest section of the pipeline needed
to complete the task
* Route gas from the nearest isolation valve or control fitting
to a flare as fuel gas
* Reduce the pressure by using in-line compression
* Reduce the pressure by using mobile compression
* Transfer the gas to a segment of a lower pressure pipeline
system adjacent to the nearest isolation valve
* Employ an alternative method that will result in a release
volume reduction of at least 50 percent compared to
venting gas directly to the atmosphere
INGAA responds that restricting flaring increases methane
emissions. Flaring can reduce the effect of emissions on climate
change by up to 25 times. If operators were to flare instead of
venting, with 95-percent flare efficiency, the industry would reduce
the global warming potential of the emissions by almost
91 percent. UI
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Underground Infrastructure - October 2023

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