INGAA members operate equipment that requires continuous parameter monitoring systems (CPMS) for compliance assurance. The proposed requirements in 40 CFR 60, Appendix B, Performance Specification 17 (PS 17) and 40 CFR 60, Appendix F, Procedure 4 (Procedure 4) will affect INGAA member operations. INGAA comments discuss our concern that unnecessarily stringent audit requirements will result in unwarranted operational costs, and alternative requirements should be included for simple measurements such as temperature that have been reduced to standard practice over many years of use. These specifications will apply to CPMS required by NSPS or NESHAP regulations – e.g., temperature monitoring required by the RICE MACT.
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Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
