A major natural gas producer and two marketers have called on FERC to reject Wyoming Interstate Co.’s (WIC) proposal to “significantly tighten” the sulfur specifications for producer gas to be accepted into its system.
Tighter gas specifications would render existing production that satisfied previous specifications “now out-of-spec,” and would require producers to invest considerable capital to treat that out-of-spec gas, said BP America Production Co., ChevronTexaco Natural Gas and BP Energy Co. in their protest of WIC’s tariff proposal.
Lower sulfur specs would force producers to shut in gas production, which would damage producing wells and disrupt pipeline service for shippers and markets, warned the trio, referred to as Indicated Shippers.
WIC bears the burden of providing a “detailed explanation of the need for” cutting back its sulfur specifications, they said, adding that the pipeline “has not even come close to satisfying this burden.” In fact, in light of the current shortfall in domestic gas supply, the BP companies and ChevronTexaco believe “there must be an extra burden on a pipeline to fully justify a proposal to tighten gas specifications.”
Given the “lingering concerns” expressed by the Commission about the gas supply outlook, they said now was not the time for FERC to allow interstate pipes to impose stiffer specs on the gas that will be accepted into their systems.
WIC, which serves the Rocky Mountain region, is seeking to reduce the total allowable sulfur from 20 grains per cubic foot to five grains, and to cut total allowable hydrogen sulfide (H2S) from 1 grain/cf to one-quarter of a grain [RP03-480].
“WIC says that ‘H2S and sulfur in the gas stream can interfere with the safe and efficient handling and transportation of gas.’ But WIC has used the current sulfur specifications for years without apparent trouble. Nowhere in its [proposal] does WIC say that the current specifications are now causing operational problems,” the Indicated Shippers said.
From September 2001 through August 2002, approximately 56% of WIC’s deliveries were made to Trailblazer Pipeline at the Dullknife interconnection, noted the BP companies and ChevronTexaco. “Trailblazer’s sulfur specifications are the same as WIC’s current specifications. Therefore, the proposed specifications are not needed for WIC to deliver gas into downstream entities.”
Indicated Shippers claim WIC is creating a problem where none exists. “If a problem emerges [later] with the existing sulfur specifications, WIC could then seek to tighten the specifications. But that is not the situation now, and it might never be the situation.”
WIC noted its proposed lower sulfur specs matched those of the upstream pipelines that connect with its system, but the BP companies and ChevronTexaco said that still didn’t justify the pipeline’s action. “An upstream pipeline’s gas specifications cannot possibly justify WIC’s proposal to tighten its own gas specifications. Indeed, the tight sulfur specifications on the upstream pipelines make it easier for WIC to accommodate higher sulfur gas from producers on its system while still satisfying the specifications of downstream entities.”
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