The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments in response to the Environmental Protection Agency’s (EPA) proposed rulemaking (Proposed Rule), “Revisions to Test Methods, Performance Specifications, and Testing Regulations for Air Emission Sources.” The Proposed Rule was published in the Federal Register on September 8, 2015 at 80 FR 54146. This action proposes technical and editorial corrections and revisions to regulations related to stationary source emissions testing, such as NSPS and NESHAP performance tests.
INGAA’s members represent the vast majority of the interstate natural gas transmission pipeline companies in the United States, operating approximately 200,000 miles of pipelines, and serving as an indispensable link between natural gas producers and consumers. INGAA and its members have a long history of working collaboratively with a variety of stakeholders on emissions issues related to equipment such as natural gas-fired reciprocating internal combustion engines (RICE) and combustion turbines. This includes extensive and long-term engagement with the EPA Office of Air Quality Planning and Standards (OAQPS) staff responsible for developing NSPS and NESHAP regulations for RICE and turbines, including the spark-ignition internal combustion engine NSPS (40 CFR, Part 60, Subpart JJJJ). INGAA members will be directly impacted by the Proposed Rule, especially proposed revisions to delete currently allowed test methods for VOC emission tests required by Subpart JJJJ.
EPA indicates that the Proposed Rule does not impose substantive new requirements on source owners or operators. However, since Subpart JJJJ was adopted in 2008, many operators and their service providers have conducted numerous Subpart JJJJ VOC tests using methods that EPA proposes to delete from the rule. The companies will incur significant costs if that proposed revision is retained in the final rule.