Last month Sen Udall (D,NM) introduced S 2469, the Methane
Emissions from Transmission Harm American Neighborhoods and the Environment (METHANE)
Act. The bill would require DOT to promulgate regulations to detect and reduce
pipeline emissions of methane.
Detection
Section 2(a) would amend 49
USC 60109; adding a new subsection (h), Leak Detection Requirements. This
would give DOT 2-years (1-year to establish regulations) to require “operators
of distribution pipelines shall use advanced leak detection technology” {new §60109(h)(1)}.
That technology would entail {new §60109(h)(2)(A)} “a high sensitivity methane
detector mounted on a vehicle or aircraft, including a drone, equipped with
Global Positioning System technology, if that high sensitivity methane detector
and Global Positioning System technology”. The detector/GPS unit would be required
to {new §60109(h)(2)(B)}:
• Collect latitude and longitude coordinates and
methane concentration data simultaneously;
• Measure methane concentrations in parts per
billion; and
• Collect data points at a rate of at least twice per
second.
Emission Reduction
Section 2(b) would add a new §60142 to 49 USC. This section
would give DOT 1-year to establish new regulations to require pipeline
owner/operators to {new §60142(a)}:
• Use the best available technology to capture
natural gas when making repairs to the pipeline facility;
• Use the best available technology, including, as
applicable, advanced leak detection technology described in section
60109(h)(2), to search for and identify leaks in the pipeline facility;
• Develop or participate in a replacement or repair
program for pipeline facilities;
• Report to the Secretary any event that involves a
release of gas from a pipeline facility that results in an unintentional
estimated gas loss of 50,000 cubic feet or more.
That ‘replacement or repair program’ would be used for
facilities that {§60142(a)(3)}:
• Are of a design, age, or material known to be
leaky; or
• Are known to be leaky based on operating history.
Section 60142(b) would require the amendment of the term ‘incident’
in 49
CFR 191.3 to include a release threshold of 50,000 cubic feet in that definition.
Moving Forward
Udall and three of his 14 cosponsors are members of the
Senate Commerce, Science, and Transportation Committee. They may have enough
influence to see the bill considered in Committee. The bill, however, has
little chance of being approved in Committee due to the lack of support from
Republicans who would object to the monitoring requirements and pipeline maintenance
requirements. Similarly, this bill would have no chance to make it to the floor
of the Senate.
Commentary
There are some problems with the assumptions used to justify
this legislation. The ‘parts per billion’ standard is not a very accurate requirement
without specifying what number of parts per billion. It could range from 1ppb a
technically challenging standard for a drone mounted detector to 100 ppb which
should be readily achievable.
The next problem is that the measurement data required to be
collected will be of little use in detecting and/or isolating any but the
largest leaks. That is because two additional data points would be necessary for
determining the source/rate of the leak. Those data points are wind direction
and speed. Without those measurements, it would be virtually impossible to
determine what the leak rate would be and difficult to track down the location.
It might not even be possible to determine if the detected methane emissions
were from a pipeline.
Finally, it is not clear if this is a pipeline safety
measure (as one would suspect from a bill that amends PHMSA related portions of
the USC) or if it is an environmental measure. For a pipeline safety bill, one
would be concerned with methane concentrations approaching the flammability
limits of methane (5% in air). If safety were the sole concern, then the ppb
detection limit would not really be required and less expensive detectors (in
the low ppm levels) could be used. If one were interested in reducing the
fugitive emissions of a strong greenhouse gas, then the ppb detection limit
would be more reasonable (still ignoring the lack of wind data). There is
nothing, however, in the legislation that would indicate that it would be an
environmental bill (which would have gone to at least one other committee for
consideration).
All in all, I suspect that this is a political campaign bill
that will be used to exemplify the environmental credentials of the cosponsors
of the bill.
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