October 2015 Vol. 70 No. 10

Washington Watch

FAA Considers Restrictions On Drones For Pipeline Surveillance

The Federal Aviation Administration (FAA) is moving to restrict the use of pilotless drones, which are used by the pipeline industry for inspection of facilities in remote, mountainous areas. INGAA has taken issue with a proposed requirement limiting operation of unmanned aircraft systems (UAS) to situations where the operator maintains line-of-sight contact with the drone.

Safety concerns posed by drones such as their potential interference with commercial flights, has become a national issue. On Aug. 20, the Washington Post ran a
front-page story titled: FAA records detail hundreds of close calls between airplanes and drones. The story’s first sentence read: “On Sunday, a swarm of small rogue drones disrupted air traffic across the country on a scale previously unseen in U.S. skies.”

The FAA Modernization and Reform Act of 2012 directs the Secretary of Transportation to determine whether “certain unmanned aircraft systems may operate safely in the national airspace system.” The FAA proposed rule sets out certain standards for USAs which will be allowed to operate. The proposed rule would limit small UAS to daylight-only operations, confined areas of operation and visual-line-of-sight (VLOS) operations. Operators would have to be certified.

It is the line-of-sight visual contact requirement that INGAA objects most strongly to. “INGAA submits that this requirement is overly restrictive and inadvertently precludes pipeline operators from using UAS for operation, maintenance and construction monitoring activities,” states Terry Boss, senior vice president for environment, operations and safety.

INGAA wants the FAA to eliminate the line-of-sight requirement for pipeline operators as long as the UAS activities are conducted (1) within the pipeline corridor, (2) pursuant to the landowner easement agreement, and (3) using a UAS equipped with a forward looking camera and utilized geofencing, location and altitude sensing technology.

Sens. Cory Booker (D-NJ) and John Hoeven (R-ND) have introduced a bill, titled the “Commercial UAS Modernization Act (S. 1314) which would expand the use of
exemptions to allow UAS flights outside the operator’s line of sight.

Kenneth Marcum, regulatory supervisor, Cabot Oil & Gas Corporation, has the same concern about the proposed rule’s VLOS restriction. But he adds, “UAS will be a significant tool for our business and the oil and gas industry in the future, and we appreciate the FAA’s hard work making progress towards integrating UAS into the national airspace. We were particularly pleased to see the FAA’s proposed rules with regard to general UAS operations, and UAS and Operator Certification-VAS are different from traditional aircraft and should be treated accordingly.”

INGAA Concerned About EPA’s Proposed Methane Controls
The Interstate Natural Gas Association of America (INGAA) contends that the methane and volatile organic chemical (VOC) emission limits for transmission pipelines proposed by the EPA will in many instances be difficult to comply with. Don Santa, president and chief executive officer of INGAA, says, “While we haven’t had a chance to review fully the 500-plus page proposal, INGAA is concerned that some aspects of the EPA’s methane proposal would be impossible to implement cost-effectively and that the regulations, if implemented, could adversely affect the reliability of interstate natural gas pipelines.”
The proposed rule issued in

August would add requirements for detecting and repairing leaks, and limiting emissions from compressors, pneumatic controllers and pneumatic pumps used at compressor stations. This would be the first time the EPA would require air emission limits from transmission pipeline compression stations. The requirements would apply to “new or modified” equipment; so the existing compression at pipeline stations would not be affected unless a transmission company proposes a FERC 7C project for a pipeline capacity change. Then that facility would be considered “modified,” according to Cathy Landry, spokeswoman for the INGAA. Those applications are “not common,” she states.

However, significant numbers of new compression stations are in the industry’s future. An INGAA Foundation research report released in March 2014 estimated that the U.S. and Canada will require each year through 2035, an average of 850 miles of new natural gas transmission mainlines, 800 miles of new laterals to and from power plants, processing facilities and storage fields and almost 14,000 miles of new gas gathering lines to bring new gas supplies to growing markets.

For those new and modified compression station pieces of equipment which are affected, the EPA contends that the costs of compliance will be far outweighed by the benefits of recovered fugitive emissions of gas. The EPA has collected data from Natural Gas STAR partners, where transmission companies voluntarily interact with the EPA to reduce air emissions, which shows that instituting a DI&M program at a compressor station costs $26,248 per station and returns $88,239 per year in recovered gas. DI&M stands for Directed Inspection and Maintenance, which is a voluntary approach to reducing emissions.

It isn’t clear when the Natural Gas STAR program made that cost/benefit analysis. Jerome Blackman, who heads that EPA program, did not reply to an e-mail seeking clarification.

Some pipeline companies have participated with the Natural Gas STAR program in the past. Kinder Morgan has participated in the EPA program since 1993, and some of its acquisitions, such as El Paso Natural Gas, have also been long-time participants. Asked about the impact of the proposed rule on his company, Richard N. Wheatley, spokesman for Kinder Morgan Inc., says, “We’re monitoring and working through INGAA.”
The proposed rule requires a 95 percent reduction in VOC emissions from compressors with wet seal systems. This can be accomplished through flaring, or by routing captured gas back to the compressor intake. Compressors using dry seal systems, which have low methane and VOC emissions, would not be covered by the proposed rule.

The proposed rule provides two options for replacing rod packing in reciprocating compressors: every 26,000 hours of operation (operating hours must be monitored and documented); or every 36 months (monitoring and documentation of operating hours not required). As an alternative to changing rod packing, operators may opt to route emissions from the rod packing via a closed vent system to be reused or recycled by a process or piece of equipment.
The proposal affects continuous bleed, gas-driven pneumatic controllers which are located between the wellhead and the point where gas enters the transmission pipeline. For controllers used at natural gas compressor stations, the gas bleed limit is six standard cubic feet of gas per hour at an individual controller. Low-bleed controllers used at compressor stations (with a gas bleed rate less than six standard cubic feet per hour) would not be subject to this rule.
EPA is proposing to require that owners/operators of compressor stations use a technology known as optical gas imaging to conduct a leaks monitoring survey. Owners/operators would have to conduct the survey within 30 days after startup of a new compressor station or modification of the station, then repeat the monitoring survey twice yearly afterward.

Any leaks found during the surveys would have to be repaired within 15 days, unless the repair requires shutting down production. In that case, owners/operators would be required to fix the leak at the next scheduled shutdown. The proposed rule includes incentives for minimizing leaks.

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