INGAA Comments to EPA Regarding Implementation Plans: Start-up

The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submitted these comments on May 13, 2013 regarding the Proposed Rule, State Implementation Plans: Response to Petition for Rulemaking; Findings of Substantial Inadequacy; and SIP Calls To Amend Provisions Applying to Excess Emissions During Periods of Startup, Shutdown, and Malfunction (Proposed Rule), dated February 22, 2013 (78 FR 12460 to 12540). The Proposed Rule would require 36 states to revisit startup, shutdown, and malfunction (SSM) requirements in state implementation plans in response to an EPA SIP Call. INGAA is interested in this rulemaking because INGAA members operate natural gas transmission compressor station or storage facilities in nearly all of the affected states, and SSM provisions are inherent to numerous regulations and permits based on historical interpretation of EPA policy.


 INGAA’s Comments:

1. INGAA is concerned that evolving national SSM policy is not appropriately addressing technical issues associated with different emissions characteristics during SSM events, which are typically very short duration for T&S sources with limited emissions data available.

2. Basic tenets of EPA policy should be established so that state SIPs can adequately address perceived deficiencies in SSM requirements in SIPs while ensuring technical veracity and comporting with the historical record.

3. EPA should develop SSM policy and guidance in a transparent process that engages stakeholders.  EPA should convene a series of technical conferences to initiate that process.  The principles of SSM policy should be clearly defined before states are required to address perceived SIP deficiencies.