A trade group for the natural gas pipeline industry asked the Federal Energy Regulatory Commission to revise its draft guidance for pipeline developers submitting horizontal directional drilling plans during the federal review process.
The Interstate Natural Gas Association of America, or INGAA, said in a Dec. 28, 2018, response to the proposed guidance that it supports the agency's effort to improve the quality and consistency of such plans for horizontal directional drilling, or HDD, which could prevent or mitigate inadvertent releases of drilling fluids that might contaminate waterways crossed by pipeline construction.
But the trade group also said it was concerned that the scope of the guidance, issued by FERC staff in October 2018, might be too broad, and it said certain information that FERC would require is subject to change or may not always be available at the time of submission.
The back-and-forth between the industry and regulators came at a time when pipeline developers are looking to boost gas takeaway capacity from key shale plays to serve rising demand from Mexico and from U.S. LNG export terminals.
Meanwhile, environmental groups have increased pressure on regulators to slow the review process for pipeline projects, especially ones that involve HDD activity. The practice drew scrutiny from federal and state regulators after mishaps in 2017 in Ohio, in which an estimated 2 million gallons of drilling fluid spilled during the construction of a portion of Energy Transfer LP's Rover gas pipeline. FERC imposed a months-long block on horizontal drilling activity at river crossings while Rover's HDD plans underwent third-party review. The incident prompted more stringent oversight of the remaining HDD activities for the project.
"INGAA requests clarification that the commission's intent is to apply the guidance manual to projects with proposed HDDs, as opposed to all trenchless construction techniques," the trade group said. "For example, it would provide little to no value to develop comprehensive HDD plans for small HDDs utilized to achieve additional depth of cover or separation from foreign utilities, rather than those adopted to avoid or minimize surface impacts to environmental resources."
"Thus, the application of the guidance, once finalized, should be commensurate with the complexity of each HDD design, its location, and the specific environmental conditions," the group said.
In the draft guidance, which covers HDD monitoring, inadvertent return response and contingency plans, FERC said helping the industry make HDD plans more uniform would make the commission's environmental review process smoother and more effective.
While the guidance in its final form would not impose any new legal requirements or substitute any existing regulations under the Natural Gas Act or the National Environmental Policy Act, operators would be encouraged to follow the recommendations, particularly as they apply to mitigation measures for HDDs constructed under the automatic provisions of FERC's regulations.
"Information that is not specifically required by regulation, but is often considered during staff's environmental review, should also be considered, provided, and incorporated into these plans," the agency said.
FERC said the information should include "crossing-specific geotechnical information and crossing profiles showing the feasibility of the crossing; a hydrofracture and [inadvertent return] risk evaluation; drilling fluid composition (including the use of drilling mud additives, and source water identification and analysis) and management; HDD monitoring procedures and document retention; and unique conditions identified along proposed HDD alignments that may increase the risk of HDD construction complications, inadvertent releases, or cause other environmental concerns."
INGAA said some of this information might be unavailable for various reasons, or might be subject to change during the course of the commission's environmental analysis of a proposed project.
"Consequently, INGAA requests that the guidance be revised to ensure that the best available information is provided in the HDD plans included in certificate applications, with the understanding that the HDD plans will be supplemented, or updated, as additional information becomes available during the certificate application review process, or prior to the commencement of construction of the applicable HDD," the trade group said. (FERC docket AD19-6)
Harry Weber is a reporter for S&P Global Platts. S&P Global Platts and S&P Global Market Intelligence are owned by S&P Global Inc.