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Dominion Appeals Leak Detection In 2 Pipeline Compressor Station Air Permits In Clinton, Potter Counties

On August 3 Dominion Energy Transmission, Inc. filed a basic notice of appeal of an Air Quality Operating Permit issued for two compressor stations, one in Potter County containing provisions requiring a leak detection, repair and monitoring program.

The Finnefrock Compressor Station is located in Leidy Township Clinton County (Case 2017-064)

The Greenlick Compressor Station is located in Stewardson Township, Potter County. (Case 2017-065)

Both compressor stations will serve the Leidy South Pipeline Project which will transport natural gas from the Clinton County area into Maryland and Virginia.

Dominion said in both notices a requirement to perform an annual Leak Detection and Repair Program is “unreasonable and contrary to law” and it should not be subject to the requirement because other DEP Regional Offices ‘have determined that other similar DETI [Dominion] facilities are not subject to such requirements.”

The relevant permit condition requires--

-- “The permittee shall establish and perform a monthly Audio, Visual, Olfactory (AVO) inspection prior to January 1, 2017, of the facility to determine any leaks that may occur during the inspection and rectify the leak as soon as possible.

-- “The permittee shall perform an annual Leak Detection and Repair (LOAR) program which meets the following:

(1) “The use of optical gas imaging (OGI) or gas leak detector capable of reading methane concentrations in air of 0 to 5% with an accuracy of=\- 0.2%,

(2) “The program is to be conducted on valves, flanges, connectors, storage vessels/storage tanks and com press or seals in natural gas service. Any equipment or component that is designed to protect the equipment or safety of personnel is not considered a leak,

(3) “Leaks shall be repaired no later than 30 calendar days after leaks are detected unless facility shutdowns or ordering of replacement parts are necessary for repair of the leaks,

(4) “The permittee may request an extension of the deadline for repairs,

(5) “A leak shall be defined as a concentration of more than 2.5% methane or a volatile organic compound (VOC) concentration greater than 500 parts per million (ppm) using a gas leak detector or a leak is defined when using an OGI camera as a visible image as demonstrating by monitoring.

(6) “A leak shall be considered repaired if monitoring demonstrated 2.5% or less, or if established by 40 CFR Part 60, Appendix A, or no visible leak image is detected by the OGI camera.

(7) “Within 180 days after January 1, 2017, develop a LOAR plan and perform the related inspection. Annually thereafter, perform the LOAR related inspections that include either the use of an OGI camera or a gas leak detector capable of reading methane concentrations in air ofO to 5% with an accuracy of +/-0.2%.”

The permit also requires records to be kept on leak detection efforts--

-- “The permittee shall keep records of the following information:

(1) “The date and time of the monthly Audio, Visual, Olfactory (AVO) inspections and any repairs that were conducted and any repairs that were conducted pursuant to the AVO inspections.

(2) “The date and time of the annual Leak Detection and Repair (LOAR) inspections and any repairs that were conducted and any repairs that were conducted pursuant to the LOAR inspections.

-- “The permittee shall keep these records for a minimum of five (5) years and shall be made available to the Department upon request.”

The Environmental Hearing Board schedule for considering both appeals is--

-- September 25: Settlement conference

-- January 31: Discovery complete

-- March 2: Motions filed

Documents related to these appeals can be found on the Environmental Hearing Board website.

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