The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to submit these comments in response to the California Air Resources Board (ARB) proposed rule, “Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities” (Proposed Rule). An overview of INGAA comments and recommendations includes:
1. It is premature for the ARB to propose monitoring standards for natural gas storage facilities until recommendations from the Aliso Canyon natural gas task force and Federal minimum standards are issued, per the PIPES Act of 2016. In the interim, INGAA recommends the use of established consensus standards for pipeline safety to minimize methane emissions from leaks.
2. Technologies for continuous ambient and wellhead monitoring of natural gas storage facilities are currently not technically proven. The performance of these technologies is still being evaluated, and they have not been commercially demonstrated at this scale. Continuous ambient and wellhead monitoring should not be required. INGAA recommend the use of established consensus standards for pipeline safety to minimize methane emissions from leaks.
3. The Proposed Rule includes leak detection and repair (LDAR) requirements that differ from established regulatory approaches and recent federal regulatory requirements (e.g., NSPS Subpart OOOOa). For natural gas transmission and storage (T&S) facilities, INGAA recommends: eliminating performance criteria that limit the number of leaks based on component population counts, revising requirements related to survey frequency and operator training, and, revising delay of repair provisions.
4. The Proposed Rule includes requirements for upstream storage tanks, separators, and production wells, which do not appear to apply to natural gas transmission and storage (T&S). For T&S segments, applicability of tank and separator requirements should be clearly indicated. Production wells and underground natural gas storage wells should be clearly differentiated.