Odorization of Gas Transmission & Gathering

1. Odorization of Gas Transmission & Gathering

2. About Access Midstream • Formerly Chesapeake Midstream • Gas gathering pipeline operator • Approximately 6,000 miles of pipeline • Currently operate in twelve states (9 regulated)

3. Odorization of a gas system is done with a single purpose in mind: Provide the public with an effective warning device to alert them when there is a possible problem….It’s also required by Regulation!

4. Under Part 192, Odorization is required for gas distribution, some transmission, presently not for gathering (unless you are unfortunate enough to operate in New York!) - more on that later 

5. What the Code says… (§192.625) • Combustible gas in a distribution line must: • Contain a natural odorant, or • Be odorized At ALL Times

6. What the Code says… (§192.625) • Must be detectable at one-fifth of the Lower Explosive Limit (LEL) by a person with a NORMAL sense of smell. • Operator must know the LEL of his particular gas stream. • 4-5% gas-in-air

7. Factors Which Affect Odor Intensity or Perception • Gender • Physical condition • Masking • Age • Psychological

8. Odorization for Transmission Lines • After January 1, 1977, transmission lines in class 3 and 4 areas must be odorized; unless ----

9. 2 miles Class 3 14 miles 4 miles 20 miles (total) Flow Direction Odorization for Transmission Lines • At least 50% of the length of the line DOWNSTREAM from that class 3 or 4 location is class 1 or 2. (critical for gathering) Begin here

10. Odorization for Transmission Lines • Exceptions • Pipeline transports gas to any of the following facilities which received unodorized gas prior to May 5, 1975: • Underground Storage Field • Gas Processing Plant • Gas Dehydration Plant

11. Odorization for Transmission Lines • Other Exceptions (continued) • Pipeline transports gas to any of the following facilities which received unodorized gas prior to May 5, 1975: • Industrial plant where the odorant: • Reduces activity of a catalyst • Reduces chemical reaction • Causes unfit product

12. LDC Class 3 Odorization for Transmission Lines • Other Exceptions (continued) • At least 50% of a lateral line serving a distribution center is in class 1 or 2 area. (Any 50%)

13. You Have to Odorize, Now What? • Must Select the Odorization Equipment • Must Select the Proper Odorant • Must Monitor Injection Rates • Must Establish Sampling Locations on System • Must Purchase Sampling Instrument • Must Train/OQ Personnel • Must Test Level Periodically • Must Keep Lots of Records • Must Get Ready for Lawsuits

14. Odorization Equipment • Must introduce the odorant without wide variations. • Injection pumps • Bypass Odorizers • Wick Type

15. Odorant Properties • The odorant may not be deleterious (harmful) to people, materials or pipe. • Combustion products may not be toxic to breathe or corrosive to materials exposed to combustion products. • Can’t be soluble in water COMMENT – Not a Concern with Purchased Odorant (Mercaptan)

16. Other Considerations • Which blend to use for the desired results • Soil absorption • Soil types • Reaction with gas stream composition • Heavy ends present can cause masking • Other Impurities (H2S, CO2)

17. Factors Which Affect OdorantInjection Consistency • Odorizer malfunction • Contaminants in the odorizer • Distillate or other liquids • Pipewall adsorption • Oxidation

18. Sampling • To assure the proper concentration of odorant, each Operator shall conduct periodic sampling of combustible gases using an instrument capable of determining the % of gas-in-air at which the odor becomes readily detectable. • What’s Periodic? • Sample Where? • What Instrument?

19. Sampling Equipment • Now must use equipment to determine this quantitative measurement. • All Instruments rely on individual’s sense of smell • “Sniff tests” and tracking leakcomplaints may be good supplemental records.

20. Records and Documentation • Injection rates • Amounts and types of odorant purchased • Odorizer inspection reports • Test results from odor concentration meter tests

21. Records and Documentation • Training records • Types of odor calls received • Results of odor call investigations • Total number of odor calls received

22. Personnel Qualifications • Training on Test Instruments • Sense of Smell • Variations in Sensitivity

23. Let’s Talk Gathering & Odorization • Since some pipelines associated with gathering qualify as transmission (discharge lines from compressor stations and plants) must they be odorized based on class location? • The public wants to know -- Why aren’t all gathering lines required to be odorized?

24. Question 1 Two PHMSA Interpretations Help Here – • Letter to Mary McDaniel, TRRC, dated 6/7/89: “Essentially, your question is whether an operator must odorize a gathering line that is totally located within a Class 3 area and connected to a transmission line that is not odorized and cannot accept odorized gas…. Since the gathering line in question is regulated as a transmission line and feeds directly and only into the transmission line, downstream must be taken in this case to refer to the transmission line being fed by the gathering line. Thus, the gathering line would not need to be odorized.”

25. Question 1 (Continued) 2. Letter to Northern Border Pipeline Co. dated April 5, 2004: Question “Northern Border Pipeline Company owns only the first 2.7 miles (more than 50% Class 3) of a continuous 86.3 mile pipeline segment serving an underground gas storage facility. The remaining 84 miles of the line is owned by Peoples Gas Light and Coke Company and is predominately Class 1. The question is whether odorization is required in the NBPL portion of this pipeline because more than 50% of the NBPL-owned pipeline is in a Class 3 location.”

26. Question 1 (Continued) 2. Letter to Northern Border Pipeline Co. dated April 5, 2004: Response: The odorization requirements of 192.625 are not dependent on pipeline ownership…but rather on the configuration and operations of a pipeline segment, which will remain relatively fixed. NBPL would not have to odorize gas in the 2.7 mile segment because it is an integral part of an 86.3 mile line to a gas storage facility. If this line were under a single ownership, it is clear that odorization would not be required, and there is no reason to make odorization dependent on ownership Therefore, odorization is not required by § 192.625 if at least 50 percent of the ENTIRE line downstream from a Class 3 or Class 4 location is in a Class 1 or Class 2 location.

27. Bottom Line • Letters imply that transmission lines associated with gathering can use the downstream mileage of the transmission customer in determining Class 3 or 4 % • State agencies have not challenged this conclusion • CAVEAT ~ PHMSA cautions that all interpretations only pertain to the company and circumstances outlined in that request

28. Question 2 – Public Perception • Points why gathering should not be odorized: • Odorization works best with clean, dry gas • No water, heavy hydrocarbons, impurities • Odorization is intended for closed systems • Abnormal Events, e.g. Leaks and RV releases • Not blowdowns, vents, pig traps, etc. • Transmission Customers don’t want it • Must be filtered out before delivery • “Tree” Concept

29. Odorization Like a Tree Distribution – Trunk is Town Border Station ; Branches are Mains and Services Gathering – Branches are Flow Lines Trunk is Transmission Line

30. Now for New York Code 255 • All Lines Leaving Well Pad are Gathering • Gathering Operating ≥ 300psi are Transmission and must be Odorized in Entirety • Gathering ≥ 125 psi < 300 psi within 150 ft of a residence are Transmission and must be Odorized • Gathering < 125 psi is Distribution and must be Odorized MESSAGE ~ DON’T DRILL IN NEW YORK

31. QUESTIONS ???? Don McCoy Senior Advisor – Pipeline Safety Access Midstream Partners Phone: (405) 727-1555 Fax:  (405)  727-3555 Mobile: (405) 706-0832 Email:  don.mccoy@accessmidstream.com