Sorry for dumping info and running off...
FERC regulates Natural Gas due to the
Natural Gas Act (of 1938). For one client I've worked with, they are asking FERC, but need a letter of determination from PHMSA. So if you can convince PHMSA, FERC
might rubber stamp, assuming there are no major changes to your site, for increased production limits. What constitutes a major change? That's up for debate, mostly because no one has done it before.
Would changing out the internals of a compressor (re-wheeling) be a big change? Would changing out coalescer elements be a big change or is that maintenance? Obviously adding a new compressor or sub-system (end flash gas system where there was none, booster compressor on the inlet where there was none) would be a major change, but how does the other things mentioned affect it?
The major change that has happened regulatory-wise from about 2008-12 time frame till now is the size of lines considered for a site sitting survey. Before, lines 8" and up were considered. Now it is 4" and up. And if you have to go back to redo a site sitting survey (estimating dangers of NG/HC release on the environment and plant), you get opened up to environmental concerns, noise issues, traffic complaints, etc.
As for existing capacity, it depends on the type of facility in the USGC. Some LNG plants are tolling facilities; you buy the gas, you pay a set rate per MMSCF to process it and you own the LNG in the tank at the end. Others buy their own gas and then sell the LNG (much like a refinery, but they only make one product). Some are a hybrid (one train is wholly owned, another is a tolling facility).
The only scenario I can think (and I could be wrong) is a tolling facility that has a 'gap' in their schedule. If they were to process the contract gas at 100% processing speed, they'd have a day (or two) before the next contract starts (bad schedulers). So they can 'slow-roll' the process to make it seemless, but their site isn't running at a 100%. Now you could try to buy gas to process so they get back up to 100% (assume they are running at 85% capacity), but I doubt that site would announce to the world they are under-running and looking for someone to sell them gas at a discount.
The other issue that I see with the recent run-up in NG prices is that this will make US LNG look super great as it did after ***ushima. When Japan shut down all nuclear plants, they spooled up LNG purchases. So the JTK (Japan, Taiwan, Korea) price shot up and, coupled with a lower HH price, made US LNG look like a rockstar.
As an aside: LNG prices is HH, plus about $2-3 per MMSCF for processing (making into LNG), plus $3-8 per MMSCF for transport. So if JTK is $20 (post ***ushima) and HH is $3, you
could make about $6 per MMSCF profit. IF you had the LNG.
But for US LNG to remain competitive, you need a lower HH if the rest of the world's NG prices are lowered.
And one last thought, the US LNG pulls less than about 10% of the NG. I feel, that once you hit about 10% of the market, LNG can start demanding things and you'll get a bigger change to the system. Things like heavy HC content, CO2 content, N2 content, supply pressures, etc. will all be shifted to LNG needs rather than power needs, but that's just my $0.02.
~egon
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