The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments regarding the proposed amendments to the new source performance standards (NSPS) for the Oil and Natural Gas Sector. INGAA represents a majority of the interstate natural gas transmission pipeline companies operating in the United States as well as comparable companies in Canada. INGAA’s members operate a network of approximately 200,000 miles of pipelines.
As with other trade groups, INGAA was concerned after reviewing the recently published rule, “Oil and Natural Gas Sector: Reconsideration of Additional Provisions of New Source Performance standards.” 79 Fed Reg 79018 (December 31, 2014). The biggest concern for INGAA member companies was the discrepancy between the definition of storage vessel that was included in the proposed version of the rule versus the final version. As such, INGAA supported other trade associations’ request for reconsideration of the above mentioned rule. The EPA granted the request for reconsideration and published: Oil and Natural Gas Sector: Definitions of Low Pressure Gas Well and Storage Vessel in the Federal Register on March 23, 2015. In these proposed amendments, EPA changed the definition of storage tank back to what was originally proposed, striking the language regarding tanks in parallel. INGAA supports this proposed change and appreciates EPA reconsidering the issue.