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Introduction to the 1981 Natural Gas Compliance Monitoring Program

EPA has been working to bring the natural gas pipeline sector into compliance with the environmental laws since January 1981, when PCBs were discovered in pipeline liquids in Long Island, NY. Consequently, EPA, the states and industry formed a cooperative task force to address this problem. Extensive sampling of pipeline transmission liquids revealed that 13 major natural gas transmission companies had PCB contamination greater than 50 ppm in their transmission lines. In late 1981, EPA instituted a Compliance Monitoring Program ("CMP") for the 13 companies. At that time, the use of PCBs at greater than 50 ppm constituted the use of PCBs in a non-totally enclosed manner, which was prohibited by 40 CFR §761.20(a). EPA decided that it would not bring enforcement actions against such companies for the improper use of PCBs as long as they participated in EPA's CMP and undertook measures to reduce PCBs in their pipeline systems.

The 13 CMP companies were required to comply with all other aspects of the PCB rule and other applicable laws and regulations. In other words, the 1981 CMP allowed the use of PCBs in natural gas transmission lines subject to certain conditions, including the proper disposal of PCB wastes and compliance with applicable federal and state laws. The 1981 CMP did not immunize 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 other participating companies, such as Texas Eastern Gas Pipeline Company, Transwestern Gas Pipeline Company, Tennessee Gas Pipeline Company, Columbia Gas Pipeline Corporation and Transcontinental Gas Pipeline Company . In addition, several states have taken enforcement actions against companies participating in the CMP.

The CMP was revised in 1996 for the ten remaining companies still participating in the program. A detailed description of the 1981 and 1996 revised CMP was sent to the Regions on December 24, 1996. Under the revised CMP, each participating company was required to submit their Annual "PCB Condensate" Compliance Monitoring Report to EPA by June 15th of each year.

Promulgation of 1998 PCB disposal amendments terminated the 1996 PCB CMP. The 1998 rule revised the use authorization for natural gas pipelines at 40 CFR Part 761.30(i) to permit the use of PCBs in natural gas pipelines at greater than 50 ppm under certain conditions.


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