The Interstate Natural Gas Association of America (INGAA), a trade association that represents members of the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection Agency’s (EPA) request for input on granting a 2-year stay and a three month stay of certain aspects of the new source performance standard (NSPS) OOOOa.
INGAA member companies transport more than 85 percent of the nation’s natural gas, through approximately 200,000 miles of interstate natural gas pipelines. Across the United States, INGAA member companies operate over 6,000 stationary natural gas-fired spark ignition reciprocating internal combustion engines (RICE) and over 1,000 stationary natural gas-fired combustion turbines installed at compressor stations along the pipelines to transport natural gas to local gas distribution companies, industrials, gas marketers, and gas-fired electric generators.
These comments summarize INGAA’s support for EPA staying certain aspects of NSPS OOOOa for 2 years, in particular, staying the fugitive emission requirements at compressor stations, the delay of repair requirements associated with repairing leaks at compressor stations, and obligations related to third-party equipment and altering the phase-in periods for these requirements. INGAA also supports EPA’s proposed three-month stay of these requirements.