Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballot initiative in November 1986. The Proposition was intended by its authors to protect California citizens and the State's drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals.
Information on this page . . .
1. When liquids are encountered by customers, who is responsible for the management of these liquids?
The policy has been that any liquids encountered by the customer in his/her own facility are his/hers to manage. The customers should be warned of the hazard of the liquids and the existence of regulations that apply.
The high pressure customer letter is sent to 100 psi or greater customers because such customers are most likely to reduce pressure in their operation and cause liquids to form. It is the reduction of pressure that causes cooling and condensation. Note that there is a sharp distinction between pipeline liquids flowing into a customers operation and preventing delivery of gas, and a high pressure customer condensing liquids as part of an operational process. We deal with the former, but the latter should be managed as part of the customers operations.
2. If liquids are burned as part of the normal operating process of an equipment, is this acceptable practice?
If liquids are burned incidentally to the combustion of natural gas (as with droplets of liquid entrained in the gas flow), then that burning is not treatment of the liquids. If liquids are separated out from the natural gas and subsequently burned somewhere in the process, then it is up to the customer to decide if they are "treating" the liquid. However, note that SoCalGas has sold pipeline liquids for use as off-spec fuel, so that if a customer decides to use it as fuel, such a use of high btu liquids is reasonable. The notification letter warns the customer of the Prop 65 hazard. It is the customers responsibility to check the regulations and requirements to see if there is an issue regarding the quality of the liquids, and whether it may be used as fuel or disposed of as a hazardous waste. Once again, the Company does not wish to take on the responsibilities of deciding what the customer must do with the liquids.
3. Who is responsible for cleanup and disposal as a result of liquid seepage and contamination of soil/dirt around the gas line?
The Gas Company is responsible for liquids seeping out of “its” lines, and should handle the cleanup of soil contaminated from its operations. Unless there is something else in the soil, I believe that it would be handled as hydrocarbon contaminated soil.
If there are "house lines" (customer lines) that leak, then it is the customer's responsibility to address cleanup. Just as we would not handle liquids collected from a customer's process, we would not dispose of soil that has become contaminated because the customer's piping is leaking.
Customers receiving “high-pressure” gas, defined as 100 pounds per square inch (psi) and greater, are warned about the presence of PCBs in natural gas lines. PCBs are present on both the State of California’s Proposition 65 lists for cancer-causing characteristics and for reproductive toxicity.
Where PCBs are present in natural gas pipelines, they are generally found with pipeline liquids. PCBs were used as a turbine compressor lubricant from about 1968 to 1972 in some locales. Some of that lubricant entered into the gas pipelines. The pipeline liquids act as a solvent for PCB residuals in the pipeline. High-pressure customers are warned about pipeline liquids and possible harmful constituents, such as PCBs and benzene, because pressure reductions of the gas result in cooling, which is likely to cause pipeline liquids to form by condensation.
PCBs are listed as a family of carcinogens (cancer-causing compounds). PCB exposure, as well as exposure to other chlorinated chemicals, has been linked to the onset of chloracne, a severe type of skin acne or skin eruption. People exposed to PCBs who are concerned about the exposure should be advised to see their physicians.
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