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Show ..... vv.... vv'J "/...L 2 natural gas produced outside the state ,(or produced outside of production", as described below) would be considered to be part of transportation and would be regulated. rn Appalachia, ··those compressor stations handling only "Loca L production" wou Ld "local qualify for the exeption as the equivalent of gas plants.1 in this lettar, the term "local production" refers produced from a single nea.rby gas field or several nearby fields, as determined by the state oil and gas regulatory agency. Once gas fron outside the local production area (again, as defined by the state regulatory agency) is commingled with gas from within the·local area, then the pipeline facilities and copresso stations beyond that point would no longer be E&P operations, and wastes generated are no longer considered exempt wastes (with the footnoted exception for gas storage !ields) even if additional. local production .,feeds into the system downstream from the point of commingling. Similarly; once gas leaves the As to used gas gathring system would no subject for transportation ox sale to a conser, it be part of E&P and any wastes generated would be subtitle C if they exihibited one or more hazardous longer to ·--characteristics. The second issue concerns exempt 'wases that are mismanaged and that may pose an environmental threat. You have expressed your desire that the environmentally unsound handling or disposal of exempt wastes should result in the loss o the exemption for these wastes since there are no other schemes requ1atory designed to address the hazardous nature of these wastes. . In light of Congressional intent, EPA does not classify a the way in which that particular waste is manaqed (or mismanaged) "I nor does EPA base its definition of what constitutes an exempt waste on whether or not the waste is managed in compliance with state regulations. As far as Federal regulations are conce:rned, once a waste as exempt exempt waste regardless was or not exempt based generated, of the trea'tme.nt on that waste would or particular remain exept disposa lIlethod employed (unless certain requlated hazardous wastes). The mishandling or exept wastes is a state regulatory and enforceent issue. states are free to develop regulations which are more stringent mixed with As gas discussed in stored in FR notice,. operations to recover natural underqround natural geological formations (not the are considered part of production, not This is becaue these facilities are operated if the gas ere being produced for the first underground tanks) transportation. the same way as time. Therefore, uniquely associated wastes from compressor stations dedicated solely to the retrieval of natural gas from underground storage facilities origin of that gas. are exempt regardless of the in |
