Spectra Energy Watch

Are Cancer-Causing PCBs Part of the Problem at Steckman Ridge?

Spectra Energy’s Amazing History with PCB Contamination:

Paid EPA $15 Million Penalty; Still #7 on EPA’s Top 21 List;

Subject of National News Coverage

Is it possible that Polychlorinated Biphenyls (PCBs) have contaminated Spectra Energy’s Steckman Ridge underground gas storage facility in Bedford County, Pennsylvania?

Sounds farfetched since Congress banned PCBs in 1979, correct?  Stayed tuned.

What Are PCBs?

PCBs are man-made chemicals, known as chlorinated hydrocarbons.  The U.S. Environmental Protection Agency (EPA) has concluded that PCBs cause cancer in animals and is a probable human carcinogen.¹ (See also “Links & References” below for a list of sources.)

Link:  http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/about.htm

PCBs — Threat to Health

Regarding the “Health Effects” of PCBs, the EPA’s website notes (emphasis added):

“PCBs have been demonstrated to cause a variety of adverse health effects. PCBs have been shown to cause cancer in animals. PCBs have also been shown to cause a number of serious non-cancer health effects in animals, including effects on the immune system, reproductive system, nervous system, endocrine system and other health effects. Studies in humans provide supportive evidence for potential carcinogenic and non-carcinogenic effects of PCBs.” ²

Link:  http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/effects.htm

Since Congress banned PCBs in 1979, how could it be a problem today?  As the EPA website notes (emphasis added):

PCBs Last a Lo-o-o-ng Time

“Once in the environment, PCBs do not readily break down and therefore may remain for long periods of time cycling between air, water, and soil.  PCBs can be carried long distances and have been found in snow and sea water in areas far away from where they were released into the environment. As a consequence, PCBs are found all over the world.  In general, the lighter the form of PCB, the further it can be transported from the source of contamination. PCBs can accumulate in the leaves and above-ground parts of plants and food crops. They are also taken up into the bodies of small organisms and fish. As a result, people who ingest fish may be exposed to PCBs that have bioaccumulated in the fish they are ingesting.” ³

Is it reasonable to ask whether PCBs are in the Steckman Ridge compressor station since it was installed approximately 30 years after the ban?

According to Toni Beck, Spectra Energy’s Group Vice President of Internal and External Affairs (emphasis added):

“We manage PCB contamination on our system in compliance with applicable EPA regulations, including the use of engineering controls and operational practices that prevent the migration of PCB contamination into uncontaminated pipeline segments or interconnects.”

What if the Steckman Ridge station is not a source but a conduit?  What if you have a contaminated pipeline system (i.e., Spectra Energy’s Texas Eastern system) connected to a new facility (Steckman Ridge)?  How long does it take to contaminate the new facility?  How would it be possible?

Staggering $15 Million Dollar Federal Penalty for PCBs

First, Spectra Energy’s Texas Eastern pipeline division is very familiar with PCBs. It has more than $15 million worth of experience with the toxic chemical.

Even today, Texas Eastern ranks number 7 on EPA’s hit parade of the 21 “Top Civil Penalty Cases of All Time.”  This list is known as the National Enforcement Trends (NETs) document and you can review it here: nets-top-civil-penalty-cases-w-texas-eastern1

The company’s PCB contamination was so bad and so extensive along its entire pipeline system that Texas Eastern, a division of Spectra Energy, agreed to pay a federal penalty of $15 million in 1987.  Said to be the “largest settlement of an EPA case in history” — at that time — it was a major story covered by national media outlets like The New York Times and TIME magazine.

For example, according to The New York Times (Nov. 10, 1987; emphasis added):

“The Texas Eastern Corporation tentatively agreed today to clean up PCBs and other toxic wastes disposed of at 89 sites in 14 states along its 10,000-mile natural gas pipeline.  The cleanup will cost an estimated $400 million. …  Texas Eastern will also pay penalties and costs of $15 million for violating regulations on the disposal of PCB’s, or polychlorinated biphenyls, along the pipeline. … The pipeline … stretches from Texas and Louisiana into the Northeast.”

Link:  http://www.nytimes.com/1987/11/10/us/pipeline-company-to-clean-pcb-sites.html

By the way, 19 of those sites are in Pennsylvania, according to a 1991 federal court ruling.⁴

Link: http://bulk.resource.org/courts.gov/c/F2/923/923.F2d.410.89-6307.html

According to a source knowledgeable about gas operations:  ”Long ago, PCB’s were used in the oils and greases at the compressor stations and valves on the pipeline and would get carried out of the station or valve by gas flow.  PCBs are no longer used, but they are extremely hard to get rid of once you get them into your system.  The only way to get rid of them is to completely replace an existing pipeline system with a 100% new system in the affected area.”

“This problem is bigger than it appears because we are talking about contaminated compressor stations, valves, and pipe from South Texas to the tip of the Northeast; and there are lots of compressor stations, valves, and pipe between these two points,” he continued.

“PCBs don’t discriminate and will move freely within the system and follow gas flow, which generally moves from South Texas to the Northeast.  They also have the option of reversing gas flow at the compressor stations and flowing in the other direction.”

“This is a big problem,” the source familiar with gas operations concluded.  ”It could be such a problem that testing for PCBs in South Texas could be nothing compared to the amount of PCBs in the Northeast.  One might even see an exponential increase of PCBs in the Northeast compared to South Texas.”

How Could PCBs Escape to the Environment?

The release of PCBs inside a pipeline or compressor station to the outside environment can happen in two ways, according to our source:  below ground or above ground.

1) Below Ground - The components of natural gas inside a pipeline can form a liquid; OR liquids are brought into the pipeline from a third-party interconnection; OR oils and greases are released from compressor stations, pipeline valves, or other processes.  It is the liquids and oils that pick up the PCBs; and if there is a release of liquid or oil from a contaminated system, it will contaminate the environment.  Gas migration underground is an issue that is receiving serious attention from geologists in Pennsylvania and elsewhere.  If gas and contaminated liquids and oils migrate out of the underground storage field reservoir, it can contaminate other nearby reservoirs and water aquifers.

2) Above Ground - These same contaminated liquids and oils can escape by opening the pipeline or compressor system when doing repairs or routine maintenance activities.  Automated shutdowns such as the emergency shutdown that occurred at the Steckman Ridge compressor station can release contaminated oils and liquids.

Solutions Not Gift Certificates

Finding answers is important.  Spectra Energy’s safety and environmental problems are piling up faster than the gift certificates it gives to area residents so they will “like” them.

Every month we learn more bad news about this company’s performance record over time — from a $15 million federal penalty for massive PCB contamination to a catastrophic failure that turned into an inferno at its Moss Bluff underground gas storage field.  Link to Moss Bluff Incident: http://www.spectraenergywatch.com/blog/?p=390

Meanwhile, there are persistent reports of contaminated water supplies in Bedford County and across Pennsylvania in connection with increased drilling and storage of gas in underground formations (through the use of injection wells).

It may or may not be fair, but a reasonable finger of suspicion points to the gas industry.  Bad water is a nightmare no property owner wants to face.  And where family farms are concerned, contamination threatens the destruction of income and property value.  Worse, none of the industry experts has a clue so far.

Instead of answers and transparency, property owners get gift certificates and promises.

Yet the activity goes on.

Every Drilling Mud & Frack Component It Could Use

In its pre-filing draft for the Steckman Ridge project (6-29-07), Spectra Energy told the Federal Energy Regulatory Commission (FERC) that the site would have 23 “storage wells.”

To date, Spectra Energy has converted five of the existing production wells, and drilled 8 new wells - for a current operating total of 13 injection/withdrawal wells, according to FERC.  Presumably, the company will drill 10 additional wells for a total of 23.

In addition, Spectra Energy filed for the record, on April 7, 2008, nearly 300 pages of Material Safety Data Sheets (MSDS) for every drilling mud and hydraulic fracturing component it could possibly use. spectra-report-to-ferc-4-7-08-fracking-drilling-chemicals1

Most of the data sheets are from Halliburton; and several of the chemical compounds are listed as cancer causing or probably carcinogenic, including chemicals with such trade names as Aquagel®, Baracarb® (a family of compounds), Baroid®, N-Seal^TM, Halliburton Gel, Oriskany Flush Cement, and Frack Sand.

It is time for Spectra Energy to engage in a grown-up conversation with its neighbors.  Not, why don’t you like us; or why do you keep picking on us?

Instead, send in the adults and answer questions:  What chemicals are you using?  Is the pipeline contaminated with PCBs or other toxic compounds?  How many property owners are having water problems you haven’t disclosed?  Fully disclose the risk factors involved in this underground gas storage operation.  How often do you test for hazardous chemicals and what are the results?  Have you fracked, or when are you going to frack (or use alternative stimulation)?

In our next blog, we will continue to pursue the issue of PCBs and related health and safety factors in natural gas operations.

Links & Resources

^{1,  3} EPA’s Basic Information on PCBs:  http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/about.htm

² EPA’s “Health Effects of PCBs”:  http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/effects.htm

⁴ Federal Court Ruling — 1991; see Section 1, “Facts And Proceedings Below” (emphasis added):

“The facts in this case are undisputed. Texas Eastern operates an interstate natural gas pipeline system that extends over 9,600 miles through 16 states from Texas to New York. The pipeline system passes through Pennsylvania. In 1985 or 1986, the EPA learned that Texas Eastern was allowing polychlorinated biphenyls (PCBs) to escape into the environment at 89 sites in 14 states along the pipeline system. Nineteen of these sites were in Pennsylvania. Accordingly, the EPA commenced an investigation and entered into discussions with Texas Eastern concerning appropriate responses to the contamination.” http://bulk.resource.org/courts.gov/c/F2/923/923.F2d.410.89-6307.html

Background:  The 1991 federal court action (referenced above) was triggered when Pennsylvania Department of Environmental Protection (DEP) apparently appealed in federal court (U.S. Court of Appeals, 5th Circuit) for the right to intervene in EPA action against Texas Eastern (a Division of Spectra Energy).  It appears that the DEP was concerned that the $15 million consent decree with the EPA might preempt state environmental laws.  The federal judge ruled that, “the consent decree itself should have no preemptive effect on state laws and that any preemption of state environmental laws would result from existing federal statutes or regulations that are not affected by the disposition of this action.”

EPA PCB Inspection Manual (August 2004) Page 2 (G-1): “PCBs pipeline liquids were illegally disposed of in unlined earthen pits, vented to the atmosphere and surface soils at various equipment blowdowns, used as herbicides on station fence-lines, and used for dust control on roads.  Examples of past cases/settlements involving the use of PCBs in turbine compressors include the Texas Eastern Gas Pipeline Company [division of Spectra Energy] and Transwestern Pipeline Company.”  (See link below next citation.)

Page 4 (G-3): “The 1981 CMP [EPA's Compliance Monitoring Program for PCBs] did not grant immunity to any of the participating companies from enforcement if violations were discovered.  The 1981 CMP has not prevented EPA from taking judicial or administrative enforcement actions against participating companies such as Texas Eastern Gas Pipeline Company [division of Spectra Energy] ….  Several states have also taken enforcement actions against companies participating in the CMP.”  http://www.epa.gov/compliance/resources/publications/monitoring/tsca/manuals/pcbinspect/pcbinspectappg.pdf

Views of Steckman Ridge Compressor Complex near Clearville in Bedford County, PA.  (Click on image to enlarge.)

Steckman Ridge nearly 5,000 HP compressor & nearby home, Bedford County, PA

Steckman Ridge underground gas storage complex (part of it) -- lots of pipe and other equipment sitting on top of a 12 billion cubic feet underground gas storage field.

Spectra Energy’s Response to DEP’s Notice of Violation:

Promises to do what it should have done by law, next time;

5 Recommendations for Penalties

Spectra Energy promises to follow the law the next time there is an emergency at its huge Steckman Ridge underground gas storage field, located in Bedford County, PA.

The company’s recent “unlawful conduct” violated air quality and clean stream regulations of the Pennsylvania Code, according to the Pennsylvania Department of Environmental Protection (DEP).

The DEP issued a “Notice of Violation” to the Houston-based company on September 16.  It required Spectra Energy to respond in 15 days with “a detailed summary of the events that caused the malfunction, emissions and reporting failures as well as Steckman Ridge’s plan to prevent future occurrences.”  [Emphasis added.]  [See pdf file below under "Links & References.]

Spectra Energy’s October 2 two-page response to the DEP offered what could be viewed as a surprise plan to avoid future “reporting failures.”  It offered a “new reporting procedure” in the event of another emergency at its Steckman Ridge underground gas storage field. [See pdf file below under "Links & References.]

The crux of its plan appears based on a promise to follow the law next time!  On August 23, when the nearly 5,000 horsepower compressor station shut down following a gas leak:

• Pennsylvania Code already requires companies to report emergencies to the DEP by telephone within two hours of an incident.  Spectra Energy failed to do that, but now promises it will follow the law next time.

• Pennsylvania Code already requires companies to follow up with a written report of the incident to DEP within three days.  Spectra Energy failed to do that, but now promises it will follow the law next time.

In a curious (next-to-the-last) paragraph in its report to DEP, the company wrote [emphasis added]:

“In addition to the above [technical steps], we have implemented a new reporting procedure for any future emergency shutdowns to address malfunction reporting issues.  The procedure requires immediate reporting to PA DEP by telephone of all emergency shutdown gas releases, regardless of any associated oil release.  A written report of such instances of malfunctions will be submitted to PA DEP within three days of the incident.”

Essentially, the company’s “new reporting procedure” boils down to a promise to follow the law next time.  With all due respect to the executive team responsible for this $5 billion company, one wonders how much time was spent around the legal and environmental conference table in order to brainstorm such “a new reporting procedure.”

With homage to Mad Magazine’s “Scenes We’d Like to See”

Picture little Johnny Steckman excitedly waving his hand in the air.  “I’ve got it, I’ve got it,” he burbles.  “How ‘bout if we tell ‘em next time we’ll follow the law - but we call it a New Reporting Procedure?”

Next, regarding Spectra Energy’s plan “to minimize the potential for a recurrence” of the emergency shutdown, the company identifies five engineering or mechanical steps it has taken.  (See page two of the “Steckman Ridge” response in the pdf file below.)

A source familiar with gas operations offered this blog the following comments, based on reviewing the Spectra Energy report and his own experience in the field.  He has not visited the Steckman Ridge storage field.

He speculates, for example, that more was involved in the emergency shutdown than a “cracked pipe fitting.”

“I believe the root cause of the compressor station shutdown and release of natural gas, oil and liquid into the atmosphere was due to liquid shutting down the system — an overload slug of liquids/oil from those wells.  In other words, they got a big slug of liquid at the compressor and it automatically shut down to prevent damage.  Then the station piping blew down, and all the liquids that were in the piping vented to the atmosphere.

“The Spectra Energy report contains several references to actions designed to minimize the amount of liquid in the station piping, and ‘to remove oil from the piping.’  This suggests that liquids were to blame.

“The company said it is evaluating installation of an additional filter separator to aid in removal of liquids from the gas stream.

“In addition, here is an excerpt from, followed by a link to, a Department of Transportation (DOT) inspection form which mentions ‘slugs of liquids’ and the need for automatic liquid removal, compressor shutdown, or high liquid level alarm to combat the slugs.”

The excerpt reads:

Do liquid separators have a manual drain and if slugs of liquid could be carried into the compressor, automatic liquid removal, compressor shutdown, or high liquid level alarm?

Are liquid separators manufactured in accordance with Section VIII of the ASME Boiler and Pressure Vessel Code or a design factor less than or equal to 0.4 if constructed of pipe and fittings with no internal welding?

Link to DOT inspection form:

http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/PHMSA_Form_5_2009.pdf

[See page 4 of the DOT inspection form, under the subhead ‘Design Requirements,' Section .165(b)]:

1 Million Cubic feet of Natural Gas, But Only 20 Gallons of Liquid?

The Notice of Violation was issued to Spectra Energy on September 16 following the company’s poor safety and environmental response surrounding the August 23 emergency shutdown of its nearly 5,000 horsepower compressor station.

In its October 2 response to DEP, the company reported that 967,000 standard cubic feet of natural gas was released into the atmosphere, along with what it estimates was about 20 gallons of oil which showered onto surrounding properties.

Our source, who is familiar with gas operations, raises questions with the estimate that only 20 gallons was released into the atmosphere.  He believes it could have been much higher, perhaps as much as 100 gallons of liquid and oil.

He notes:  “The company’s estimate is based on a review of oil usage, but that is insufficient to conclude that only 20 gallons was released and compressor/motor oil was the only component.  It is likely that all the liquids and natural gas in the piping system were vented to the atmosphere.

Currently the DEP is in the important penalty assessment phase, as it evaluates the company’s response regarding its “unlawful conduct.”

Risky Premise

Some reports are circulating that, because the emergency shutdown did not result in catastrophic failure, it is safe to return to business as usual with, perhaps, a modest fine and a slap on the wrist to Spectra Energy.

It is nice to be lucky, but that should not determine DEP’s penalty assessment.  Spectra Energy demonstrated the equivalent of what strikes many area residents as reckless indifference - and/or reckless incompetence.  (For details, read “Emergency Shutdown” at this link): http://www.spectraenergywatch.com/blog/?p=372

This is the company that promises:  “Safety of the residents and the environment is our primary priority.”  Instead, their performance in the midst of an “emergency shutdown” due to a gas leak in a huge compressor station sitting on top of a 12 billion cubic feet underground gas storage field is a dramatic failure.

Please - No Rerun of 2004 Moss Bluff Incident

In addition, this company did experience a catastrophic failure in 2004 at its Moss Bluff gas storage field outside of Houston.  This involved two explosions, six days of fire with flames as high as 1,000 feet and two evacuations.

Spectra Energy has declined to share what it learned from that experience in order to demonstrate that it provides improved performance at its Steckman Ridge field.  (For details, read “Moss Bluff Incident” at this link): http://www.spectraenergywatch.com/blog/?p=390

Its “new reporting procedure” with its commitment to follow the law next time suggests that Spectra Energy still does not get it.

What if we’re not lucky next time?  It is always in the public interest to take a tough stand on behalf of safety and the environment.

The Steckman Ridge station is approximately three miles from an elementary school.

And there is a bonus here for Spectra Energy.  It could demonstrate tangible commitment to the safety of residents and the environment.  This could mark a new phase in its community relations that go far beyond handing out gift certificates.

Following are recommendations for DEP to consider in its evaluation.

5 Penalty Recommendations

1)    Consideration of a fine should start at $100,000 and only move up.

2)    One-year probation of the facility with unannounced inspections and visits.

3)    DEP to staff one of its engineers at the site - with all compensation and other expenses to be paid by Spectra Energy for this person.  The DEP staffer would remain on site for one year, then the DEP could decide whether to extend its presence there, based on Spectra Energy performance and quality improvement.

4) A full-time site manager to be assigned to Steckman Ridge.  This person must be an employee of Spectra Energy (FTE, versus a contract person).  This person must be on site at the Steckman Ridge facility and be the responsible leader at that site.

5) Keep the Steckman Ridge compressor station fully staffed until the liquid  problem is resolved and additional equipment is installed and proven effective.

We want Spectra Energy to be a responsible member of our community - to be the best it can be in that regard.  Keep the gift certificates.  Make sure that our environment is safe and clean; and that our families and properties are safe.

LINKS & REFERENCES

Spectra Energy Response to DEP’s Notice of Violation: steckman-ridge-response-ltr

DEP’s Notice of Violation to Spectra Energy: dep-violation-notice-p1 dep-violation-notice-p2

Pennsylvania Code Citations

25 PA Code Citations:

http://www.pacode.com/secure/data/025/articleICIII_toc.html

91.33. Incidents causing or threatening pollution:

http://www.pacode.com/secure/data/025/chapter91/s91.33.html

Air Pollution Control Act:

http://www.dep.state.pa.us/DEP/DEPUTATE/airwaste/aq/regs/apca.pdf

Clean Streams Law:

http://www.dep.state.pa.us/dep/deputate/minres/oilgas/CSLawuc.htm