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Dina Abate (EH] <br />From: Germann, David [DJGk@pge.com] <br />Sent: Wednesday, May 12, 2004 2:24 PM <br />To: Dina Abate [EH] <br />Subject: FW: Natural Gas Storage Waste Exemption <br />Dina, <br />It was good to meet you today! Please find below Rex Bell's follow up regarding the <br />production fluid exemptions. If you need additional information, please call me at (925) <br />974-4083. <br />Dave Germann <br />> -----Original Message----- <br />• From: Bell, Rex <br />> Sent: Wednesday, May 12, 2004 2:15 PM <br />> To: Germann, David; Alioto, Pam <br />> Cc: Promani, Rudy <br />> Subject: Natural Gas Storage Waste Exemption <br />> Dave, Pam - <br />> The clarification on the exemption for wastes associated with natural gas storage is in <br />Section II D. of Federal Register Vol. 58, No. 53 dated March 22, 1993. It clearly states <br />that wastes derived from natural gas brought to the surface at gas storage fields are <br />exempt from regulation as RCRA waste. The Federal Register clarification refers to the <br />regulatory exemption in 40CFR, Part 261.4(b). <br />> In addition California regulations in 22CCR66261.20(a) exempt those wastes that are also <br />exempted under 40CFR261.4(b). <br />> The conclusion is that waste generated by the thermal oxidizers at McDonald Island is <br />exempt from both state and federal hazardous waste regulation because it is directly <br />associated with natural gas that is brought to the surface <br />> Please let me know if there are additional questions about this. <br />> REX <br />> 223-6904 <br />> Below is the pertinent clarification in the Federal Register cited above and a link to <br />the Federal Register article. <br />> http://www.epa.gov/epaoswer/other/oil/og93wp.pdf. <br />> "Finally, wastes uniquely associated with operations to recover natural gas from <br />underground gas storage fields are covered by the exemption just as if the gas were being <br />produced for the first time. This is because operations to store and retrieve natural gas <br />from natural underground formations, as well as the types of wastes generated, are <br />virtually identical to those involved with the production of natural gas for the first <br />time, although the volume of <br />> wastes generated by natural gas storage and retrieval is typically smaller than the <br />volume generated by the initial production. In effect, in the context of the E&P <br />exemption, the storage of natural gas in natural underground formations returns the gas to <br />the beginning point of the production process". <br />1 <br />