MEMORANDUM

TO:		Amy Hambrick, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	April 18, 2016

SUBJECT:	Summary of the February 10, 2016, Meeting with the Interstate Natural Gas Association of America (INGAA) and the U.S. Environmental Protection Agency
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I.	INTRODUCTION

The Interstate Natural Gas Association of America (INGAA) requested this meeting with EPA to present an overview of their comments on the September 18, 2015 proposed Oil and Natural Gas Sector NSPS (80 FR 56593). This summary addresses those comments and other concerns regarding this action.

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Carey Bylin (by phone)
Justin Pryor (by phone)
Jody Howard (by phone)
Bruce Moore
Eric Goehl
Matthew Witowsky
Brenda Shine
Amy Hambrick
Lisa Thompson
David Cozzie
Penny Lassiter

INGAA Members
Theresa Pugh, INGAA
Dee Bennett, Kinder Morgan
Tom Bach, Kinder Morgan
Reagan Mayces, Spectra
Anand Yegnan, Dominion
Jim McCarthy, IES
Steve Wright Questar
Alex Bosilievac, EQT
Alexia Martinez, National Fuel
Alice Pryor, Dominion
Ann Loomis, Dominion
Carol Butero, Kinder Morgan
David Nichel, Boardwalk
Carrie Towns, Vector Pipeline
Emily Nieding, National Fuel
Geoff Renberg, ONEOK
Laura Guthrie, Enable
Jim Tangeman, Kinder Morgan
Jeff McCombs, Columbia Pipeline Group
Jessica Toll, Kinder Morgan
Judy Neason, Williams
Mary Beth Whitfield, Williams

EC/R Incorporated
David Hendricks (by phone)

III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting and explained to the attendees that since the EPA is in the post-proposal phase of the NSPS and CTG, EPA personnel would listen to their comments but cannot respond to any of the issues raised. However, the EPA welcomed the comments. The attendees offered the following comments.

NSPS Proposal
 Leaks
 Expressed concern that the main focus of the leak survey should be on those components with highest potential for significant leak emissions rather than looking at every component at an affected facility. Noted that many compressors have a minimum number of leaks, if any, therefore, surveying of them would be excessive.
 Asserted that subpart W supports the 80/20 concept of leak survey philosophy.
 Described INGAA's direct inspection and maintenance (DI&M) program, and noted this was submitted with their comments on the proposed rule. Stated this program meets EPA's objectives with OOOOa regulations, but is more focused on those compressors with the most significant leaks. Noted that the DI&M program is derived, in part, from work member companies have performed under subpart W and their previous experience with the Natural Gas STAR program.
 Agreed that some leak threshold is needed. Supported 10,000 ppm should be defined as a leak with regard to methane emissions.
 Noted that there is a difference between methane and VOC emissions LDAR.
 Stated they would like the rule to allow for flexibility between use of OGI or M21. Noted that cameras are generally used to conduct the initial leak surveys.
 Suggested that those compressors with a low probability of leaking and having a low consequence if do, should be excluded from the LDAR program.
 Stated that there can be issues/challenges with employing OGI camera at some low consequence compressor stations, thus, these should be excluded from the requirements.
 Asserted that use of the 10,000 ppm threshold for a leak definition, ensures there would be no significant consequences if these compressor stations were exempt.
 Asserted that if there is a small leak, under 10,000 ppm, it is being watching as part of monitoring program.
 Stated it is important to note the distinction between the issue of the definition of leak and delay of repair.
 Explained that rod packing and higher pressure, larger diameter components (such as blowdown valves), have the highest potential for leaks.
 Stated there is a diminishing return in surveying smaller diameter components.
 Explained that, under their proposed DI&M program, individual member company's would define and implement their own plans, with established INGAA guidelines and framework.
 Pointed out that subpart VVa's 500 ppm leak definition was developed for streams more laden with VOC, which is a different emission stream than what is being monitored here in compressor stations, which is 90-95% methane. Thus, asserted that use of subpart VVa definition is inappropriate here.
 Stated that to make a repair at most compressors would require a blowdown, at least of the piping, if not the entire facility in some cases. These blowdowns can range from 25k c.f. to 150k, sometimes more. The consequence of this is that a small leak with a repair requirement could cause a release of a greater magnitude of emissions than those created by the leak.
 Noted that, in practice, they do not make any repair under pressure due to safety concerns and that it is generally better to perform a blowdown.
 Expressed that they would like a more focused list of subject components based on screening that has been done in subpart W and other program, which identify where the issues are in their industry.

 Leak Repair
 Requested the flexibility to schedule when to repair leaks. Stressed the importance of looking at the impacts that leak repair can have on a company and its customers and material delivery timeframes; impacts need to be considered in scheduling a repair.
 Believed that surveying all compressors on a quarterly basis would be excessive.

 Delay of Repair
 Stressed the importance of a degree of flexibility necessary for a company to schedule and make a leak repair. Appropriate scheduling and performance of a repair must be done on a case-by-case basis due to the nature of leaks.
 Noted that while a repair may not be performed on initial finding, leak survey operators look at all leaks and catalog them so that when there is an opportunity to make a repair, such as when a pipeline goes down, they can fix all leaks no matter how small.
 Explained that drivers affecting the timing of repair are economic, environmental and scheduled facility maintenance.
 Pointed to an INGAA white paper, prepared by the Pipeline Research Council on leaks for subpart W, which found sources of larger compressors are associated with the greatest compressor leaks; other sources of emissions included rod packing on reciprocating compressors. Also pointed to compressors under high pressure, such as interstate pipeline and isolation valves, as having potential for large leaks.
 Stated that delay of repair should factor in the time it takes to diagnosis a leak and procure any necessary parts. Valves can have 20-30 week lead time from time of determination of replacement.
 Asserted that major leaks are addressed immediately.
 Noted that there can be a seasonal component to when making a repair works best, such as weather issues and customer demand issues and stated that other regulations allow for these components.
 Stressed again the importance of an environmental component to the delay of repair provision. If a small leak is found and a facility would have to blowdown a large volume of gas to complete the repair, then the repair should be delayed due to the environmental consequence. All leaks would then be repaired the next time a blowdown is conducted.

 Definition of Modification
 Concerned that, with the new definition of a modification, if you add compression, you are subject to the LDAR requirements for the entire compressor station.
 Explained there could be cases where a compressor site has a physical change or change in its method of operation that does not result in an emission increase and may, in fact, decrease emissions. Stated that if you are not adding a fugitive component, you are not really increasing emissions. For example, a site may choose to replace 3 smaller compressors with one larger one, resulting in less emissions or at least no increase in emissions.
 Recommended that only the compressor unit not the compressor station be the affected facility for LDAR with regard to the definition of a modification.

 Cost Issues
 Stated some of the cost effectiveness and cost impacts found in the proposed rule were not as accurate as could be; perhaps reflecting older data.
 EPA assumptions on the number of affected compressor stations in the rule and TSD seem to be based on estimates for new compressor stations that would be installed. However, when INGAA looked at the total population of transmission facilities vs. storage facilities, the projections do not line up. In the assumptions, the number of storage facilities is greater than the number of transmission stations projected out and that does not match with what INGAA finds as the overall population size.
 Noted that service disruption and liability impacts are cost issues but also important factors in delay of repair.
 Asserted the cost of performing a survey appears to be based on M21, whereas there is a significantly higher cost associated with OGI; cost of approximately $10,000 to perform M21 vs. $85-90,000 cost to purchase an OGI camera.

 Implementation Time Issues
 Stated that new or modified facilities will need additional time  -  to get contractors up to speed, hire personnel to perform LDAR, etc.
 Requested a 180 day time period to complete hiring, training and scheduling and perform survey correctly.
 Noted that monitoring plans require a level of detail and knowledge of site is necessary to conduct surveys.