Biennial Methane Leak Abatement Compliance Plan · 2018-04-06 · Gill Ranch Gas Storage Facility...

Biennial Methane Leak Abatement

Compliance Plan

March 2018

For Submittal to:

California Public Utilities Commission

Gill Ranch Gas Storage Facility Biennial Methane Leakage Abatement Compliance Plan

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Table of Contents

1. Introduction and Purpose ..................................................................................................................... 3

2. Facility Description ................................................................................................................................ 3

3. Executive Summary ............................................................................................................................... 6

4. Best Practice Compliance Plan .......................................................................................................... 12

4.1 Summary ............................................................................................................................ 12

4.1.1 BP 1 – Compliance Plan ..................................................................................................... 13

4.1.2 BP 2 – Methane GHG Policy .............................................................................................. 15

4.1.3 BP 3 – Pressure Reduction Policy ...................................................................................... 17

4.1.4 BP 4 – Project Scheduling Policy ....................................................................................... 19

4.1.5 BP 5 – Methane Evacuation Procedures ........................................................................... 21

4.1.6 BP 6 – Methane Evacuation Work Orders Policy ............................................................... 24

4.1.7 BP 7 – Bundling Work Policy .............................................................................................. 26

4.1.8 BP 8 – Company Emergency Procedures .......................................................................... 28

4.1.9 BP 9 Recordkeeping ........................................................................................................... 31

4.1.10 BP 10 – Minimize Uncontrolled Natural Gas Emissions ..................................................... 33

4.1.11 BP 11 – Methane Emissions Minimization Policies Training .............................................. 36

4.1.12 BP 12 – Knowledge Continuity Training Programs ............................................................ 39

4.1.13 BP 13 – Performance Focused Training Programs ............................................................ 42

4.1.14 BP 14 - Formal Job Classifications ..................................................................................... 45

4.1.15 BP 15 - Gas Distribution Leak Surveys .............................................................................. 47

4.1.16 BP 16 – Special Leak Surveys ........................................................................................... 49

4.1.17 BP 17 – Enhanced Methane Detection .............................................................................. 52

4.1.18 BP 18 – Stationary Methane Detectors .............................................................................. 55

4.1.19 BP 19 – Above Ground Leak Surveys ................................................................................ 57

4.1.20 BP 20a – Quantification & Geographic Tracking ................................................................ 59

BP 20b – Geographic Tracking ........................................................................................... 61

4.1.21 BP 21 – Find It / Fix It ......................................................................................................... 63

4.1.22 BP 22 – Pipe Fitting Specifications ..................................................................................... 65

4.1.23 BP 23 – Minimize Emissions from Operations, Maintenance and Other Activities ............ 67

4.1.24 BP 24 – Dig-Ins / Public Education Program ...................................................................... 70

4.1.25 BP 25 – Dig-Ins / Company Standby Monitors ................................................................... 72

4.1.26 BP 26 – Dig-Ins / Repeat Offenders ................................................................................... 74

SUPPLEMENTAL DOCUMENTS .............................................................................................................. 72


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1. Introduction and Purpose

This Biennial Methane Leakage Abatement Compliance Plan (Biennial Compliance Plan) was

prepared in accordance with California Public Utilities Commission (Commission or CPUC) Decision

(D.) 17-06-015, Approving Natural Gas Leak Abatement Program Consistent with Senate Bill (SB)

1371. SB 1371 requires the adoption of rules and procedures to minimize natural gas

leakage from Commission-regulated natural gas pipeline facilities consistent with Pub. Util.

Code § 961(d), § 192.703(c) of Subpart M of Title 49 of the Code of Federal Regulation, the

Commission’s General Order (GO) 112-F, and the state’s goal of reducing greenhouse gas

(GHG) emissions.

Gill Ranch Storage, LLC (GRS), along with the other Independent Storage Providers

(ISPs), participated actively in providing comments throughout the regulatory proceeding

and in the workshops hosted by the CPUC and the California Air Resources Board (ARB).

On June 19, 2017, the CPUC issued D.17-06-015, which provides significant detail

regarding the process to arrive at the final list of best practices.

The purpose of this Biennial Compliance Plan is to document the efforts by GRS to

minimize the methane emissions from the Gill Ranch Gas Storage Facility (Gill Ranch

Facility) as directed by SB 1371 without compromising the safety of its employees or the

general public. Safety is always of paramount importance and regardless of the best

practices adopted by GRS as detailed in this Biennial Compliance Plan, safety must remain

the highest priority.

2. Facility Description

The Gill Ranch Facility is owned by GRS and Pacific Gas and Electric Company (PG&E).

GRS is an Oregon limited liability company formed in 2007 for the purpose of developing

the Gill Ranch Facility, located primarily in Madera, California. GRS owns a 75% undivided

interest in the Facility, and PG&E owns a 25% undivided interest. The CPUC granted GRS’

and PG&E’s consolidated applications for certificates of public convenience and necessity

(CPCN) on October 29, 2009, in Decision 09-10-035. The Division of Oil, Gas, and

Geothermal Resources (DOGGR) issued a project approval letter for the Facility on

September 2, 2010. GRS is the operator of the Facility, which began commercial operation

in October 2010.

The Gill Ranch Facility was designed and constructed with safety as a key priority and is

being operated to maintain that focus on providing safe, reliable, and cost-effective gas


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storage service. Reservoir and gas storage well integrity are cornerstones of our overall

pipeline safety program.

GRS, as an owner and operator of the Gill Ranch facility is committed at every level to a

culture and operations that value public and worker safety as a first priority. As operator of

the Facility, GRS, under the direction and supervision of its Executive Management Team,

has developed safety performance expectations, policy principles, and goals and objectives

for safety performance and environmental stewardship.

As shown in Figure 1 below, the Gill Ranch Facility is located primarily in western Madera

County in central California’s San Joaquin Valley, approximately 20 miles west of Fresno

and approximately 7 miles northeast of the city of Mendota. It is required to comply with

any applicable rules of the San Joaquin Valley Air Pollution Control District (SJVAPCD). A

portion of the Gill Ranch Facility spans the San Joaquin River into Fresno County. The

town of Firebaugh is located approximately 11 miles northwest of the Gill Ranch Facility,

and the town of Kerman is located approximately 8 miles southeast. The Gill Ranch Facility

land area is approximately 5,020 acres. Flat agricultural space surrounds the Gill Ranch

Facility. The predominant geological feature nearby is the San Joaquin River, which travels

from the southeast to the west side of the Gill Ranch Facility.

The Gill Ranch Facility receives natural gas via a 26.7 mile gas transmission pipeline that is

connected to PG&E’s backbone transmission system. GRS operates five compressors at a

centralized facility to inject natural gas into an underground reservoir for storage. Eight well

pads are located onsite. Observation wells are located on individual well pads, while

injection wells are clustered on well pads with up to four wells per pad. The Gill Ranch

Facility has a working gas capacity of 20 billion cubic feet. Peak deliverability is a maximum

of 650 million cubic feet per day.


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Figure 1: Location Map of Gill Ranch Facility in Madera County


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3. Executive Summary

The Gill Ranch Facility was commissioned and commenced gas storage operations in

2010. It is a modern facility designed, constructed and operated based on current

standards. Safety and environmental stewardship are key priorities for GRS, the operator

of the Facility.

Specifically regarding methane emissions, when constructed the Facility incorporated

numerous design elements that minimize the volume of methane released to the

atmosphere. These key design elements include:

Electric driven compressors (5 total) - These 9,000 BHP electric motor drivers

eliminate the need for natural gas as a fuel for compression as well as the resulting

air pollutants from the combusted fuel. This also limits the potential for natural gas

leaks in the associated piping and the need for high pressure natural gas as a

power source for starting the engines.

Limited number of bleed devices – The technology available at the time of

construction allowed for the incorporation of a limited number of bleed devices, both

low rate continuous bleed controllers used for the flow control valves, and

intermittent bleed controllers for gas/water separator dump operations.

Dehydration system thermal oxidizer – The dehydration system is equipped with

a thermal oxidizer that utilizes reclaimed methane as fuel and eliminates the

emission of any natural gas stripped from the tri-ethylene glycol during its

regeneration process.

The Facility was designed with variable frequency drives (VFD) for the electric motors

driving the compressors. While the VFDs do not directly reduce air emissions, they

reduce the large current required when starting the compressors and thereby help to

reduce upstream electric generation requirements.

Operations to Reduce Emissions - In addition to the design elements that limit the level

of methane emissions, GRS operates the Facility with an eye to limiting the volume of gas

vented to the atmosphere. With respect to its portion of the Gill Ranch Facility, GRS

provides gas storage services to consumers in the wholesale California gas market at

market-based rates. Accordingly, GRS does not own the gas in the Gill Ranch Facility

storage reservoirs, but rather provides a service to store it on behalf of its customers. As

custodian of its customers’ gas, GRS is responsible for any lost volume and, therefore,

very focused on minimizing venting operations and eliminating leaks as soon as

practicable. GRS performs a daily leak inspection with an optical scanner instrument

(Heath RMLD-IS) at each of the wellpads to provide an early indication of any leak. GRS


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also conducts a quarterly leakage survey of various specified locations across the surface

of the entire storage field to ensure that no gas leakage is occurring from the reservoirs

and escaping to the surface.

Current Emission Reduction Initiatives in Progress – GRS has four projects currently

underway or in the planning stages that will assist in its efforts to reduce methane

emissions. These are:

1) Installation of Ambient Air Monitoring System – In accordance with regulations

recently adopted by the ARB1, GRS has designed an ambient air monitoring

system and filed a plan with ARB for its review and approval. That system will

continuously monitor the ambient air at two locations in the gas storage field and

compare levels of detected methane to baseline data to determine if there is a

source of methane leakage. If so, the source of the leak can be investigated and

repaired as soon as practicable. If the plan is approved as submitted, this system

is expected to be installed before yearend 2018. The expected cost of the system

is in excess of $200,000.

2) Compressor Rod Packing Leak Detectors – GRS is currently in the process of

installing rod packing leak detectors on each of the five gas compressors at the Gill

Ranch Facility. Once this system is operational, any natural gas leakage at a rod

packing will be detected immediately and plans can be made to isolate the leak

and repair it as soon as practicable given the operational requirements. The

expected cost of the rod packing leak detection system is $200,000

3) Well Pad Control Air – GRS is investigating the installation of air compressors at

each injection/withdrawal well pad. The compressed air would be used to replace

the natural gas as a control medium for the low flow rate continuous bleed flow

control valves and the intermittent bleed gas separator dump controllers. This

would eliminate approximately 450 Mscf of emitted methane, or 12.5% of the total

reported in 2015.

4) Slug Catcher Coupon Removal Tool – Twice each year GRS removes the

corrosion coupons from each of the three slug catchers. Currently this requires the

slug catchers to be blown down to atmospheric pressure. GRS is investigating the

installation of a tool that would allow for the coupons to be removed without venting

the contents of the slug catchers to atmosphere. The 2015 reported volume from

these operations was 102 Mscf, or 2.8% of the total.

1 California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities.


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As the result of the modern and efficient design and prudent ongoing operations, the Gill

Ranch Facility emission history is excellent. In 2015 the total methane emissions reported

was 3,636 MSCF. The primary source of methane emissions is from blowdowns related

to compressor startup operations, from maintenance on pressurized equipment, and from

the yearly test of the compressor station Emergency Shutdown System (ESD). All of

these operations are expected to continue in the future.

The Gill Ranch Facility, similar to the facilities of the other ISPs, has a very low baseline

emission level which makes achieving meaningful reductions very difficult. Based on the

2015 data as reported to the CPUC, the emissions from the four ISPs totaled 30,083 Mscf,

which is only 0.4% of the methane emissions from all natural gas utilities. As noted, the

Gill Ranch Facility’s total for 2015 was 3,636 Mscf, or only 0.06% of the statewide utility

total.

In the Commission Decision D.17-06-015, Approving Natural Gas Leak Abatement

Program Consistent with Senate Bill (SB) 1371, the unique challenges facing the ISPs

was recognized by the Commission in its Findings of Fact as follows:

#15 - ISPs in total emit less than one-half of a percent (0.5%) of all reported gas utility methane emissions, according to reports submitted to CPUC in 2016.

#16 - ISPs vary in size, type of infrastructure assets, and deployment of emissions monitoring technology.

#17 - ISPs earn revenues from competitive market-based service contracts, not cost-of-service rates.

Additionally, in Conclusions of Law #11:

“Applicability of best practices should take into account the different

infrastructure, operational characteristics and emission levels of each

Commission-regulated gas corporation and/or pipeline facility, including

ISPs, as defined in Pub. Util. Code § 975, et seq.”

The Commission recognizes that gas storage operations such as the Gill Ranch Facility

have limited ability to achieve significant future emission reductions; however it is GRS’

intention to achieve emission levels that are less that those reported in 2015 by the time of

the next biennial report in 2020. There are, however, several key challenges facing the

Gill Ranch Facility to accomplish reductions are:


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The Gill Ranch Facility is a single operation, one facility, based on a modern

design. As such, there is a limited number of equipment and operations that

require venting to the atmosphere. The very low baseline emission data is

reflective of the facility’s relatively new equipment. Unlike larger utilities with

multiple facilities of varying ages and a significantly higher leakage rate history, the

opportunities for emission reductions at the Gill Ranch Facility are extremely

limited.

A single emission event caused by a dig-in, significant aboveground leak or

unexpected facility blowdown could cause a large increase in the total annual

volume as compared to the very low baseline.

Pending changes in regulations governing underground gas storage, primarily from

the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) and

DOGGR are likely to require more frequent downhole inspections of gas storage

wells. These operations often require the blowdown of a volume of gas to

depressurize the well. Historically, blowdowns of this type are the largest source of

methane emissions at the Gill Ranch Facility.

Increased throughput will have an impact on emissions. The demand for

gas storage is driven by the marketplace which has constantly changing

requirements. The Gill Ranch Facility is capable of cycling its full volume of

stored gas multiple times annually. As the throughput volume increases, so

do the emissions, primarily from blowdowns associated with equipment that

cycles on and off such as the compressors.

Cost-Effectiveness and Cost Recovery – Because GRS’ share of the Gill Ranch Facility

is a market-based gas storage facility, there is no ready mechanism for GRS to recover

any incremental costs associated with the implementation of these Best Practices. Unlike

gas distribution companies, ISPs are 100% at risk for the success or failure of their

facilities; they do not have a captive customer base from which prudently incurred

incremental costs may be recovered through increases in rates. The ISPs’ costs of

operation are totally independent of the rates that can be charged to their customers.

Therefore, the only mechanism for cost recovery is through savings of natural gas that

would have otherwise been lost to the atmosphere, or through operational efficiency and

offsetting other costs. Regarding the value of the gas emitted, for the Gill Ranch Facility

with 3,636 MSCF at an assumed price of $3.00 per MMBtu, this equates to less than

$11,000 per year in potential savings. The cost-effectiveness to implement emission

reduction initiatives will need to come from elsewhere.


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Based on consideration of the facts relating to the relatively low methane emissions from

ISP facilities, and the market-based nature of ISP operations, the Commission

acknowledged that methane emissions reduction targets and certain best practices may

not be appropriately applied to ISPs.

Methane Emission Reduction Targets: With respect to methane emission reduction

targets, the Commission stated:

“We support Joint Staff’s recommendation that the compliance plans

include information on how each party plans to achieve a 40% reduction

below 2013 levels by 2030, what level of reduction would be necessary by

2020, and how they plan to achieve the 2020 reduction level. Because

ISPs’ underground storage facilities are relatively new, we acknowledge

than (sic) many ISPs already incorporate measures to reduce emissions.

Therefore, the 40% soft target may not appropriately apply to ISPs.

However, we are reluctant to eliminate this compliance plan requirement

now until we evaluate the results of the first filing in March 2018. The

Commission will be able to rely on its review of ISP compliance plans to

ensure ISPs are taking appropriate feasible and cost effective measures to

continue to minimize methane emissions and leaks.”2

Based on the information in this Biennial Compliance Plan, GRS requests that the

Commission find that GRS is “taking appropriate and feasible cost effective measures to

continue to minimize methane emissions and leaks,” such that a 40% target is not

applicable to GRS.

Exemptions from Best practices - In D.17-06-015, the Commission concluded the

following regarding the ISPs provision for requesting and being granted exemptions from

certain Best Practices:

“We agree with the ISPs that reporting data and analysis show that ISPs’ methane emissions are on a different scale than utilities’ emissions. (ISPs February 10, 2017 Comments at 3.) Because of this, the Best Practices provide ISPs with exemptions from certain Best Practices and other flexibility measures as appropriate.”

2 D.17-06-015, p. 102.


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In accordance with the process set forth in D.17-06-015, GRS requests exemptions from the Best Practices listed below. Justification for each request is included in the report on each respective Best Practice.

BP 14: Formal Job Classifications

BP 15: Gas Distribution Leak Surveys

BP 16: Special Leak Surveys

BP 17: Enhanced Methane Detection

BP 18: Stationary Methane Detectors

BP 19: Above Ground Leak Surveys

BP 20 (a and b): Leak Quantification & Geographic Evaluation / Tracking

BP 21: “Find It / Fix It Policy”

BP 22: Pipe Fitting Specifications

BP 24: Dig-Ins / Public Education Program

BP 26: Dig-Ins / Repeat Offenders

Certified by:

David A. Weber, Date

President & CEO

Gill Ranch Storage, LLC


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4. Best Practice Compliance Plan

4.1 Summary

Gill Ranch’s progress and status for each of the 27 Best Practices have been prepared

in accordance with the D.17-06-015 Compliance Plan Guidance Document provided

by the Commission and on the prescribed template.


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4.1.1 BP 1 – Compliance Plan

PART 1: OVERVIEW

a) Best Practice: 1 b) Status: Ongoing 2018

Written Compliance Plan identifying the policies, programs, procedures, instructions, documents, etc. used to comply with the Final Decision in this Proceeding (R.15-01-008). Exact wording TBD by the company and approved by the CPUC, in consultation with CARB. Compliance Plans shall be signed by company officers certifying their company’s compliance. Compliance Plans shall include copies of all policies and procedures related to their Compliance Plans. Compliance Plans shall be filed biennially (i.e. every other year) to evaluate best practices based on progress and effectiveness of Companies’ natural gas leakage abatement and minimization of methane emissions.

PART 2: BEST PRACTICE DETAILS

a) Historic work: Described in detail in BPs 2 thru 26

b) Alternative Proposal to BP or exemption? NA

c) Proposed Plan: The entire document, including the detailed plans provided in BPs 2 thru 26 d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

1) Overlap with California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. The extent of the overlap is TBD.

2) Potential overlap with pending DOGGR regulations “California Code of Regulations, Title 14 Chapter 4. Development, Regulation and Conservation of Oil and Gas Resources, Subchapter 1. Onshore Well Regulations”. The extent of the overlap will not be fully known until the new regulations are adopted

3) DOT 49 CFR Part 192 – Specific incremental requirements vary depending on the BP 4) CPUC General Order 112-F - Specific incremental requirements vary depending on the BP

e) What technology is required to implement the best practice and why? NA f) Will work require additional personnel and/or contract support? If so, please provide details. Yes. Contract personnel will be required to prepare biennial reports, review current O&M and emergency procedures emergency, revise as necessary, and train personnel. g) What changes to existing operations are required? How will those changes be implemented? Specific changes are identified in the details provided for each Best Practice. h) What are the new procedures to develop or existing procedures to modify? Please provide details.


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Specific changes to existing procedures or the development of new procedures are identified in the details provided for each Best Practice. i) Timeline for implementation (Milestones): Specific timelines, where applicable, are identified in the details provided for each Best Practice. j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: Where applicable, the cost-effectiveness of each measure to be adopted is identified in the details provided for each Best Practice. k) Identify any cost benefits from this BP, when cost estimates are known: Where applicable, the cost benefit of each measure to be adopted is identified in the details provided for each Best Practice. l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA m) Anticipated Emissions Reductions from this BP: Where applicable, the anticipated emission reductions are identified in the detailed description of the applicable BP. In total the emission reductions are difficult to quantify; however, the intent is to have emission levels below that reported in 2015 by the time of the next biennial report in 2020. 2015 Baseline Emissions affected, where known: Where applicable, the anticipated emission reductions as compared to the 2015 baseline data are identified in the detailed description of the applicable BP. n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: The overlap with safety is identified in the detailed description of the applicable BP.

SUPPLEMENTAL INFORMATION

a) Technology: Varies by specific BP

b) Changes to Operations: Any changes to operations are identified in the detailed description of the applicable BP.

c) Research or Studies: None

d) Other: None


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4.1.2 BP 2 – Methane GHG Policy

PART 1: OVERVIEW

a) Best Practice: 2 b) Status: Policy complete – Procedure development project ongoing

Written company policy stating that methane is a potent Green House Gas (GHG) whose emissions to the atmosphere must be minimized. Include reference to SB 1371 and SB 1383. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of Compliance Plan filing.


a) Historic work: A new policy, “Methane Leakage Abatement Policy” M-001, has been adopted to address the requirements of BP2. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS staff and consultants are engaged in a project to update construction, operating and maintenance procedures to address this BP. Specifically the project team intend to: 1) Identify specific procedures that will require modification to be consistent with this policy 2) Revise procedures accordingly 3) Train personnel

d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?


2) Potential overlap with pending DOGGR regulations “California Code of Regulations, Title 14 Chapter 4. Development, Regulation and Conservation of Oil and Gas Resources, Subchapter 1. Onshore Well Regulations”. The extent of the overlap will not be known until the new regulations are adopted

e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. Contract personnel will be required to review current O&M procedures, revise as necessary, and train personnel g) What changes to existing operations are required? How will those changes be implemented?


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Undetermined as yet. h) What are the new procedures to develop or existing procedures to modify? Please provide details. To be determined based on the review of all O&M procedures. i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Not known at this time m) Anticipated Emissions Reductions from this BP: None – The adoption of the policy will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. Those benefits are identified in the detailed description of the applicable BP. 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: Unknown, however safety as a first priority will be emphasized in the training program


a) Technology: None

b) Changes to Operations: Unknown at this time


d) Other: Policy M-001 – Methane Leakage Abatement Policy

4.1.3 BP 3 – Pressure Reduction Policy

PART 1: OVERVIEW


Written company policy stating that pressure reduction to the lowest operationally feasible level in order to minimize methane emissions is required before non-emergency venting of high-pressure distribution (above 60 psig), transmission and underground storage infrastructure consistent with safe operations and considering alternative potential sources of supply to reliably serve customers. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of Compliance Plan filing.


a) Historic work: GRS has historically reduced the pressure in equipment prior to venting it to atmosphere. A new policy, “Methane Leakage Abatement Policy” M-001, has been adopted to address the requirements of BP3. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted. GRS has also adopted policy V-001 – Methane Evacuation & Venting which addresses the requirement to reduce the pressure in high pressure facilities prior to venting to the atmosphere. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan:

GRS staff and consultants are engaged in a project to update construction, operating and maintenance procedures to address this BP. Specifically the project team intend to: 1) Identify specific procedures that will require modification to be consistent with this policy 2) Revise procedures accordingly 3) Train personnel




e) What technology is required to implement the best practice and why? Unknown

f) Will work require additional personnel and/or contract support? If so, please provide details.

Yes, contract personnel will be required to review current O&M procedures, revise as necessary, and train personnel

g) What changes to existing operations are required? How will those changes be implemented?

Undetermined as yet.


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h) What are the new procedures to develop or existing procedures to modify? Please provide details.

To be determined based on the review of all O&M procedures.

i) Timeline for implementation (Milestones):

July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel

j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA

k) Identify any cost benefits from this BP, when cost estimates are known: NA

l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do

they overlap, what are they, and how do they overlap? Not known at this time

m) Anticipated Emissions Reductions from this BP:

None – The adoption of the policy will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. Those benefits are identified in the detailed description of the applicable BP. 2015 Baseline Emissions affected, where known: Total blowdown volume in 2015 was 3,180 Mscf n) Calculation Methodology: NA

o) Additional Comments: None

p) Overlap with Safety:

Unknown, however safety as a first priority will be emphasized in the training program


a) Technology: None



d) Other: GRS Policy M-001 – Methane Leakage Abatement Policy GRS Policy V-001 – Natural Gas Evacuation & Venting


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4.1.4 BP 4 – Project Scheduling Policy

PART 1: OVERVIEW


Written company policy stating that any high pressure distribution (above 60 psig), transmission or underground storage infrastructure project that requires evacuating methane will build time into the project schedule to minimize methane emissions to the atmosphere consistent with safe operations and considering alternative potential sources of supply to reliably serve customers. Projected schedules of high pressure distribution (above 60 psig), transmission or underground storage infrastructure work, requiring methane evacuation, shall also be submitted to facilitate audits, with line venting schedule updates TBD. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: Project work at Gill Ranch has historically been scheduled well in advance and at times of lower pressure operations in order to minimize the volume of gas vented to the atmosphere. A new policy, “Methane Leakage Abatement Policy” M-001, has been adopted to specifically address the need to plan and schedule projects to minimize methane emissions to the atmosphere. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS staff and consultants are engaged in a project to update construction, operating and maintenance procedures to address this BP. Specifically the project team intend to: 1) Identify specific procedures that will require modification to be consistent with policies M-001 and V-001 2) Revise procedures accordingly 3) Train personnel




e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details.


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Yes, contract personnel will be required to review current O&M procedures, revise as necessary, and train personnel g) What changes to existing operations are required? How will those changes be implemented? Undetermined as yet. h) What are the new procedures to develop or existing procedures to modify? Please provide details. To be determined based on the review of all O&M procedures. i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? m) Anticipated Emissions Reductions from this BP: Not known at this time 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: GRS Policy M-001 – Methane Leakage Abatement Policy


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4.1.5 BP 5 – Methane Evacuation Procedures

PART 1: OVERVIEW


Written company procedures implementing the BPs approved for use to evacuate methane for non-emergency venting of high pressure distribution (above 60 psig), transmission or underground storage infrastructure and how to use them consistent with safe operations and considering alternative potential sources of supply to reliably serve customers. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: (1) GRS currently has in place a Blowdown log and a Compressor Blowdown Volume calculation

worksheet. These tools are used to log all blowdowns and to determine the amount of gas that was blown down. This process of logging and calculating blowdowns will be incorporated into the revised Blowdown/Venting Procedure which will include item (2) below.

(2) Two new policies have been adopted that address the requirements of this BP. “Methane Leakage Abatement Policy” M-001 and “Methane Evacuation & Venting Policy” V-001 have been adopted to address the need to evacuate natural gas from pressurized equipment and piping in a manner that minimizes methane emissions to the atmosphere. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted.

b) Alternative Proposal to BP or exemption? NA

c) Proposed Plan: GRS is in the process of completing a procedure which will include:

(1) A worksheet to be used when planning and conducting non-emergency blow-down operations. This worksheet follows the guidance of the Methane Leakage Abatement Policy M-001, the Natural Gas Evacuation and Venting Policy V-001 along with the existing GRS Blowdown Log and Compressor Blowdown calculator.

GRS staff and consultants are engaged in a project to update construction, operating and maintenance procedures to address this BP. Specifically, the project team intends to: 1) Identify specific procedures that will require modification to be consistent with policies M-001 and V-001 2) Complete the development of the GRS Blowdown Log and Compressor Blowdown Calculator 3) Train personnel



2) Potential overlap with pending DOGGR regulations “California Code of Regulations, Title 14 Chapter 4. Development, Regulation and Conservation of Oil and Gas Resources, Subchapter 1.


22

Onshore Well Regulations”. The extent of the overlap will not be known until the new DOGGR regulations are adopted

e) What technology is required to implement the best practice and why? None at this time f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, contract personnel will be required to review and revise (as needed) current O&M and Construction practices, procedures, and recordkeeping requirements. Additionally, GRS personnel shall be trained in the use of this procedure. g) What changes to existing operations are required? How will those changes be implemented? 1. The use of the Gas Blow-down/Venting procedure is an operational, maintenance and possible construction related activity as this procedure requires taking existing operating practices and expanding them to fully address this Best Practice. 2. This procedure will be implemented once it is accepted via the existing Management of Change Program and personnel have been trained.

h) What are the new procedures to develop or existing procedures to modify? Please provide details. A GRS Blowdown Log and Compressor Blowdown Calculator procedure will be developed based on existing GRS Policies and Practices. This procedure shall incorporate a log to track all blowdown/venting operations as well as calculating the amount of gas being vented/blown down. i) Timeline for implementation (Milestones):

June 8, 2018 – Complete the revised gas blowdown/venting worksheet based on the Methane Leakage Abatement Policy M-001, the Natural Gas Evacuation and Venting Policy V-001

July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel

j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Not known at this time m) Anticipated Emissions Reductions from this BP: None – The adoption of the policy will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. Those benefits are identified in the detailed description of the applicable BP. 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: Excel spreadsheet volume calculator


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o) Additional Comments: None



a) Technology: None

b) Changes to Operations: (1) New Gas Blowdown/Venting Procedure to include piping and compressors.




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4.1.6 BP 6 – Methane Evacuation Work Orders Policy

PART 1: OVERVIEW


Written company policy that requires that for any high pressure distribution (above 60 psig), transmission or underground storage infrastructure projects requiring evacuating methane, Work Planners shall clearly delineate, in procedural documents, such as work orders used in the field, the steps required to safely and efficiently reduce the pressure in the lines, prior to lines being vented, considering alternative potential sources of supply to reliably serve customers. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: Two new policies have been adopted that address the requirements of this BP. “Methane Leakage Abatement Policy” M-001 and “Methane Evacuation & Venting Policy” V-001 have been adopted to address the need to evacuate natural gas from pressurized equipment and piping in a manner that minimizes methane emissions to the atmosphere. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted. b) Alternative Proposal to BP or exemption? None




2) Potential overlap with pending DOGGR regulations “California Code of Regulations, Title 14 Chapter 4. Development, Regulation and Conservation of Oil and Gas Resources, Subchapter 1. Onshore Well Regulations”. The extent of the overlap will not be known until the new DOGGR regulations are adopted

e) What technology is required to implement the best practice and why? Unknown f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, contract personnel will be required to review current O&M procedures, revise as necessary, and train personnel


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g) What changes to existing operations are required? How will those changes be implemented? Undetermined as yet h) What are the new procedures to develop or existing procedures to modify? Please provide details. To be determined based on the review of all O&M procedures i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Not known at this time m) Anticipated Emissions Reductions from this BP: None – The adoption of the policies will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. Those benefits are identified in the detailed description of the applicable BP. 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None





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4.1.7 BP 7 – Bundling Work Policy

PART 1: OVERVIEW


Written company policy requiring bundling of work, whenever practicable, to prevent multiple venting of the same piping consistent with safe operations and considering alternative potential sources of supply to reliably serve customers. Company policy shall define situations where work bundling is not practicable. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: GRS has historically combined work to the greatest extent possible to avoid multiple venting of the same equipment. However, due to operational constraints, this is not always possible. A new policy, “Methane Leakage Abatement Policy” M-001, has been adopted to specifically address the need to plan and schedule projects to minimize methane emissions to the atmosphere. Specific operations and maintenance procedures affected by this policy are being identified and will be modified during 2018. Operators and maintenance personnel will be trained on any revised procedures once adopted b) Alternative Proposal to BP or exemption? None





e) What technology is required to implement the best practice and why? Unknown f) Will work require additional personnel and/or contract support? If so, please provide details. Undetermined as yet g) What changes to existing operations are required? How will those changes be implemented?


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Undetermined as yet h) What are the new procedures to develop or existing procedures to modify? Please provide details. To be determined based on the review of all O&M procedures i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Not known at this time m) Anticipated Emissions Reductions from this BP: None – The adoption of the policy will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. Those benefits are identified in the detailed description of the applicable BP. 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: GRS Policy M-001 – Methane Leakage Abatement Policy


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4.1.8 BP 8 – Company Emergency Procedures

PART 1: OVERVIEW


Written company emergency procedures which describe the actions company staff will take to prevent, minimize and/or stop the uncontrolled release of methane from the gas system or storage facility consistent with safe operations and considering alternative potential sources of supply to reliably serve customers. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: Fundamental to any GRS emergency response operation involving an uncontrolled natural gas release is to: (1) stop the release as soon as possible or (2) reduce the amount of gas being released as soon as possible. The prevention of an uncontrolled gas release is part of GRS’ existing Emergency Response Plan as required by PHMSA and the CPUC (see 49 CFR 192 Subpart N – Qualification of Pipeline Personnel). GRS has in place contractual obligations and commercial opportunities to utilize gas marketing options when considering alternative potential sources of natural gas supply to ensure reliable service to its customers. b) Alternative Proposal to BP or exemption?

c) Proposed Plan: GRS staff and consultants are engaged in a project to review applicable operating, maintenance and emergency procedures to address this BP. Specifically the project team intends to: 1) Identify specific PHMSA/CPUC pipeline safety programs and procedures that will require modification to be consistent with this BP. 2) Revise the programs and procedures accordingly. 3) Develop additional policies, programs and/or procedures to address the specific elements of this BP. 4) Train personnel to the revisions.

d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? Overlaps with 49 CFR 192.615(a)(6) – Emergency Plans. This regulatory requirement also requires GRS to take the necessary emergency response actions to prevent, minimize and/or stop the uncontrolled release of methane from the gas system or storage facility consistent with safe operations by requiring the emergency shutdown and pressure reduction of any section of the operator’s pipeline system necessary to minimize hazards to life or property. e) What technology is required to implement the best practice and why? No new technology is required. f) Will work require additional personnel and/or contract support? If so, please provide details. GRS staff and consultants will have to review and update existing operations, maintenance and emergency response procedures to ensure that the language of this BP is clearly stated. GRS personnel will have to be trained accordingly.


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g) What changes to existing operations are required? How will those changes be implemented? No changes to existing operations are anticipated. GRS will have to update policies, programs and/or procedures and train accordingly. h) What are the new procedures to develop or existing procedures to modify? Please provide details. All regulatory references identified in section d (Overlap with other regulations) will have to be reviewed and updated accordingly. Based on the completion of this review, the safety plan may require updating to identify and cross-reference appropriate policies, programs and/or procedures. i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: GRS will not have any cost-benefit associated with this BP. GRS will incur additional changes to review its existing policies, programs and procedures to ensure that this BP is appropriately referenced. l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: This BP generally requires what the spirit and intent of 49 CFR 192 requires. GRS believes that the entirety of 49 CFR 192 generally and specifically requires GRS to operate its pipelines safely for the purpose of protecting the public and property in such a way as to prevent, minimize and/or stop the uncontrolled release of methane from the gas system or storage facility.

p) Overlap with Safety: This BP generally requires what the spirit and intent of 49 CFR 192 requires. GRS believes that the entirety of 49 CFR 192 generally and specifically requires GRS to operate its pipelines safely for the purpose of protecting the public and property in such a way as to prevent, minimize and/or stop the uncontrolled release of methane from the gas system or storage facility.


a) Technology: None


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b) Changes to Operations: GRS expects no changes to operations as compliance with this PB is associated with the reinforcement of existing policies, plans and procedures.


d) Other: GRS Emergency Response Plan


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4.1.9 BP 9 Recordkeeping

PART 1: OVERVIEW


Written Company Policy directing the gas business unit to maintain records of all SB 1371 Annual Emissions Inventory Report methane emissions and leaks, including the calculations, data and assumptions used to derive the volume of methane released. Records are to be maintained in accordance with G.O. 112 F and succeeding revisions, and 49 CFR 192. Currently, the record retention time in G.O. 112 F is at least 75 years for the transmission system. 49 CFR 192.1011 requires a record retention time of at least 10 years for the distribution system. Exact wording TBD by the company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing.


a) Historic work: GRS currently recognizes and follows the GO 112 F requirement to retain transmission pipeline system records for 75 years. GRS (to date) has retained all of its Annual Emissions Inventory Reporting beginning in 2015 in accordance with the CPUC GO 112-F compliance requirements. b) Alternative Proposal to BP or exemption?

c) Proposed Plan: 1) GRS has updated its safety plan to formally establish the requirement to retain SB 1371 Annual Emissions Inventory Reports (including methane emissions and leak records, with the calculations, data and assumptions used to derive the volume of methane released) 2) GRS staff and consultants are engaged in a project to update it Emissions Inventory procedure to address this BP. Specifically the project team intends to: 1) Evaluate existing emissions inventory procedures 2) Revise procedures accordingly 3) Train personnel d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. The extent of the overlap is TBD. e) What technology is required to implement the best practice and why? None at this time f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, compliance consultants will be required to review current emissions inventory procedures, revise as necessary, and train personnel. g) What changes to existing operations are required? How will those changes be implemented?


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Undetermined as yet. h) What are the new procedures to develop or existing procedures to modify? Please provide details. GRS is in the process of reviewing and updating existing emissions inventory procedures as detailed in this BP. i) Timeline for implementation (Milestones): July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA, as GRS does not expect any cost-efficiencies as a result of this BP k) Identify any cost benefits from this BP, when cost estimates are known: GRS does not expect any cost-efficiencies as a result of this BP l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA m) Anticipated Emissions Reductions from this BP: GRS does not expect any emission reductions as a result of this BP. 2015 Baseline Emissions affected, where known: NA, as baseline emissions are not affected as a result of this BP. n) Calculation Methodology: NA o) Additional Comments: NA

p) Overlap with Safety: NA


a) Technology: None

b) Changes to Operations: None anticipated


d) Other: None


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4.1.10 BP 10 – Minimize Uncontrolled Natural Gas Emissions Training

PART 1: OVERVIEW


Training to ensure that personnel know how to use company emergency procedures which describe the actions staff shall take to prevent, minimize and/or stop the uncontrolled release of natural gas from the gas system or storage facility. Training programs to be designed by the Company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing. If integration of training and program development is required with the company’s General Rate Case (GRC) and/or Collective Bargaining Unit (CBC) processes, then the company shall file a draft training program and plan with a process to update the program once finalized into its Compliance Plan.


a) Historic work: GRS has traditionally trained its operators and maintenance personnel on the job until they are deemed to be qualified, and then periodically through monthly staff and safety meeting as well as specialized training associated with operator qualification requirements, emergency response training and controller trainings. GRS currently conducts annual emergency table-top exercises where personnel receive training in recognizing and responding to emergencies. GRS currently conducts annual training in the recognition and response to Abnormal Operating Conditions. The company has plans to engage a regulatory compliance consultant to assist in the development of a comprehensive training program based on existing pipeline safety requirements, both for new hire employees as well as ongoing training for existing qualified staff members. This program shall require the training program to be maintained and updated based on applicable regulatory changes and/or lessons learned by GRS. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS will engage a consultant, specializing in regulatory compliance and training requirements, to develop a comprehensive training program for all operating and maintenance personnel. This new training program will meet the requirements of this BP. Training Summary Training to ensure that personnel know how to use company emergency procedures which describe

the actions staff shall take to prevent, minimize and/or stop the uncontrolled release of natural gas from the gas system or storage facility.


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A. The Existing Emergency Response Training will be strengthened to include the prevention, minimization and/or elimination of an uncontrolled release of natural gas; regardless of causation. This will include all transmission line piping, compressor station, valve isolation stations, interconnects and well pads.

B. This enhanced training will be fully developed using a gap analysis to identify areas of improvement and provide the necessary background information to revise existing training materials. Consideration shall be given to both instructor led and distance learning training processes.

C. Staff meeting materials will be updated to ensure GRS personnel have an appropriate level of awareness of the BP 10 requirements

D. Retraining of workers on the updated Emergency Response Training (ERT) specific to minimizing and abatement of natural gas releases will be conducted

E. This Emergency Response Training will specifically address what measures the worker must take to reduce methane emissions during emergency operations by training on:

i. The identification and selection process used to select specific isolation points (pipeline and/or equipment) based on the nature and extent of the emergency.

ii. The use of alignment sheet, maps, and other documentation to better evaluate emergency conditions, identify response options and effectively implement emergency responses to protect life and property (including the environment) and minimizing emissions whenever possible.

iii. Emergency shut-down procedures with an emphasis on the isolation and/or pressure reduction processes.

iv. Emergency response communications with gas control personnel to optimize gas deliveries (when possible) to enhance gas supply and reliability during emergencies.


DOT 49 CFR Part 192 – Regulatory language within this statue currently specifies qualification and training requirements associated with emergency procedures and other operations and maintenance procedures designed to prevent, minimize and/or stop the uncontrolled release of natural gas from the gas system or storage facility.

CPUC General Order 112-F – Same overlap as DOT 49 CFR Part 192 e) What technology is required to implement the best practice and why? Standard office computers and AV equipment f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, contract personnel will be required to develop the training program and assist in the training of GRS personnel. g) What changes to existing operations are required? How will those changes be implemented? GRS does not anticipate changes to existing operations. h) What are the new procedures to develop or existing procedures to modify? Please provide details. No new identified procedures identified at this time.


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i) Timeline for implementation (Milestones):

May 1, 2018 – Engage consultant to develop comprehensive training program August 1, 2018 – Review and identify specific requirements of applicable regulations September 1, 2018 – Develop training program January 1, 2019 – Commence train program for GRS operators and maintenance personnel

j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Yes, overlap with BPs 11, 12 & 13 m) Anticipated Emissions Reductions from this BP: Not known at this time 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: Safety as a first priority will be emphasized in the training program


a) Technology: None



d) Other: None


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4.1.11 BP 11 – Methane Emissions Minimization Policies Training

PART 1: OVERVIEW


Ensure that training programs educate workers as to why it is necessary to minimize methane emissions and abate natural gas leaks. Training programs to be designed by the Company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing. If integration of training and program development is required with the company’s GRC and/or CBC processes, then the company shall file a draft training program and plan with a process to update the program once finalized into its Compliance Plan.


a) Historic work: GRS has traditionally trained its operators and maintenance personnel on the job until they are deemed to be qualified, and then periodically through monthly staff and safety meetings as well as specialized training associated with operator qualification requirements, emergency response training and controller training. GRS currently has its field operations personnel estimate gas blowdown and venting operations as well as calculate emissions associated with compressor blowdowns. The company has plans to engage a regulatory compliance consultant to assist in the development of a comprehensive training program, both for new hire employees as well as ongoing training for existing qualified staff members. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS will engage a consultant, specializing in regulatory compliance and training requirements, to develop a comprehensive training program for all operating and maintenance personnel. This new training program will meet the requirements of this BP.

Training Summary

Training will be developed to educate workers as to why it is necessary to minimize methane emissions and abate natural gas leaks. Training shall include:

A. The importance of methane emissions reduction and abatement (whenever possible) during natural gas leaks/emergencies. This will include a review of existing regulatory and operating requirements relating to emissions monitoring, leak inspection, leak identification, continuing surveillance and leak reporting.

B. Identification of potential higher opportunity methane release and emission sources

C. Methane emission abatement opportunities, practices and procedures d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? None e) What technology is required to implement the best practice and why? Standard office computers and AV equipment


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f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, contract personnel will be required to develop the training program and assist in the training of GRS personnel. g) What changes to existing operations are required? How will those changes be implemented? GRS does not anticipate changes to existing operations. h) What are the new procedures to develop or existing procedures to modify? Please provide details. No new identified procedures identified at this time. i) Timeline for implementation (Milestones):

May 1, 2018 – Engage consultant to develop comprehensive training program August 1, 2018 – Review and identify specific requirements of applicable regulations September 1, 2018 – Develop training program January 1, 2019 – Commence training program for GRS operators and maintenance personnel




a) Technology: None



d) Other: NA


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4.1.12 BP 12 – Knowledge Continuity Training Programs

PART 1: OVERVIEW


Knowledge Continuity (Transfer) Training Programs to ensure knowledge continuity for new methane emissions reductions best practices as workers, including contractors, leave and new workers are hired. Knowledge continuity training programs to be designed by the Company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing. If integration of training and program development is required with the company’s GRC and/or CBC processes, then the company shall file a draft training program and plan with a process to update the program once finalized into its Compliance Plan.


a) Historic work: GRS has traditionally trained its operators and maintenance personnel on the job until they are deemed to be qualified, and then periodically through monthly staff and safety meetings as well as specialized training associated with operator qualification requirements, emergency response training and controller training. The company has plans to engage a regulatory compliance consultant to assist in the development of a comprehensive training program, both for new hire employees as well as ongoing training for existing qualified staff members. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS will engage a consultant, specializing in regulatory compliance and training requirements, to develop a comprehensive training program for all operating and maintenance personnel. This new training program will meet the requirements of this BP. Training Summary: A training program will be created to ensure the proper transfer of knowledge occurs between GRS operating, maintenance, and contractor personnel. This training shall include existing operations and maintenance personnel, and contractors. New hires and leave personnel and contractors shall also be trained as part of the hiring and/or assignment process. Training shall include:

A. The regulatory requirements and reason for reducing and eliminating (when possible) methane emissions.

B. The processes and procedures to follow to reduce and eliminate (when possible) methane releases.

C. How to identify, document and communicate lessons learned. Note this further supports the incorporation of lessons learned into the training process.

D. How to report to GRS management, nonconformance with the GRS methane reduction policies and procedures.

E. A complete gap analysis of the GRS Operations and Maintenance operations, plans, policies and procedures to identify those plans, policies and procedures that have potential to cause a methane release.


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F. Updating plans, policies and procedures as needed to ensure the required Best Practices training has been developed and performed.

G. Effectiveness measures to be used in updating the Methane Leakage Abatement Compliance Plan.

d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? None e) What technology is required to implement the best practice and why? Standard office computers and AV equipment f) Will work require additional personnel and/or contract support? If so, please provide details. Yes, contract personnel will be required to develop the training program and assist in the training of GRS personnel. g) What changes to existing operations are required? How will those changes be implemented? None anticipated h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones):


j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Yes, overlap with BPs 10, 11, & 13 m) Anticipated Emissions Reductions from this BP: Not known at this time 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None



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Safety as a first priority will be emphasized in the training program


a) Technology: None



d) Other: None


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4.1.13 BP 13 – Performance Focused Training Programs

PART 1: OVERVIEW


Create and implement training programs to instruct workers, including contractors, on how to perform the BPs chosen, efficiently and safely. Training programs to be designed by the Company and approved by the CPUC, in consultation with CARB, as part of the Compliance Plan filing. If integration of training and program development is required with the company’s GRC and/or CBC processes, then the company shall file a draft training program and plan with a process to update the program once finalized into its Compliance Plan.


a) Historic work: GRS has traditionally trained its operators and maintenance personnel on the job until they are deemed to be qualified, and then periodically through monthly staff and safety meetings as well as specialized training associated with operator qualification requirements, emergency response training and controller training. The company has plans to engage a regulatory compliance consultant to assist in the development of a comprehensive training program, both for new hire employees as well as ongoing training for existing qualified staff members. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: GRS will engage a consultant, specializing in regulatory compliance and training requirements, to develop a comprehensive training program for all operating and maintenance personnel. This new training program will meet the requirements of this BP. Training Summary A training program will be created to ensure company personnel and contractors understand:

A. The regulatory requirements and responsibilities for compliance with all applicable Best Practices

B. How to execute the plans, policies and procedures of these best practices efficiently and safely

C. How other regulatory and/or GRS required programs, policies and/or procedures not associated with these best practices may be impacted in the future

D. How to integrate these best practices into GRS’s daily operating and maintenance activities

d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? None e) What technology is required to implement the best practice and why? ? Standard office computers and AV equipment f) Will work require additional personnel and/or contract support? If so, please provide details.


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Yes, contract personnel will be required to develop the training program and assist in the training of GRS personnel. g) What changes to existing operations are required? How will those changes be implemented? None anticipated h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones):





a) Technology: None

b) Changes to Operations: None


d) Other: None


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4.1.14 BP 14 - Formal Job Classifications

PART 1: OVERVIEW

a) Best Practice: 14 b) Status: Exemption Requested

Create new formal job classifications for apprentices, journeyman, specialists, etc., where needed to address new methane emissions minimization and leak abatement best practices, and filed as part of the Compliance Plan filing, to be approved by the CPUC, in consultation with CARB.


a) Historic work: GRS staffing consists of less than 10 operators and maintenance personnel that man the storage facility 24 hours per day, 365 days per year. With this limited size of workforce, job descriptions must have considerable flexibility to cover the full range of operations and maintenance required for a facility of this size and scope. As such, GRS does not have job classifications for apprentices, journeyman, etc. In the Commission’s order adopting the Best Practices, the unique situation with the ISPs regarding staffing levels was addressed:

“The ISPs generally utilize small workforces with staff levels set as necessary to safely and reliably operate their facilities. It could be burdensome to require the ISPs to implement some personnel practices better suited to large distribution facilities.”

b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests exemption from this BP because it is overly burdensome and not applicable to the nature of the operations at the Facility. Alternatively, all GRS personnel will be trained in the requirements of the Best Practices without creating new job classifications. In addition, this BP would require separate reporting of results in future biennial compliance plan filings, further increasing the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? NA e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None


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i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: NA – Exemption requested


a) Technology: None



d) Other: None


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4.1.15 BP 15 - Gas Distribution Leak Surveys

PART 1: OVERVIEW


Utilities should conduct leak surveys of the gas distribution system every 3 years, not to exceed 39 months, in areas where G.O. 112-F, or its successors, requires surveying every 5 years. In lieu of a system-wide three-year leak survey cycle, utilities may propose and justify in their Compliance Plan filings, subject to Commission approval, a risk-assessment based, more cost-effective methodology for conducting gas distribution pipeline leak surveys at a less frequent interval. However, utilities shall always meet the minimum requirements of G.O. 112-F, and its successors.


a) Historic work: No work related to this BP has been completed. The Gill Ranch Facility does not contain any gas distribution systems. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests exemption from this BP because it does not operate any gas distribution facilities at the Gill Ranch Facility. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? NA e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known:


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NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: None


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4.1.16 BP 16 – Special Leak Surveys

PART 1: OVERVIEW


Utilities shall conduct special leak surveys, possibly at a more frequent interval than required by G.O. 112-F (or its successors) or BP 15, for specific areas of their transmission and distribution pipeline systems with known risks for natural gas leakage. Special leak surveys may focus on specific pipeline materials known to be susceptible to leaks or other known pipeline integrity risks, such as geological conditions. Special leak surveys shall be coordinated with transmission and distribution integrity management programs (TIMP/DIMP) and other utility safety programs. Utilities shall file in their Compliance Plan proposed special leak surveys for known risks and proposed methodologies for identifying additional special leak surveys based on risk assessments (including predictive and/or historical trends analysis). As surveys are conducted over time, utilities shall report as part of their Compliance Plans, details about leakage trends. Predictive analysis may be defined differently for differing companies based on company size and trends.


a) Historic work: GRS conducts leakage surveys over all transmission pipelines at least annually in accordance with both PHMSA and CPUC regulations (see 2.d below). To date no leaks on any transmission pipelines have been detected and GRS has not identified any specific areas with known risks for leakage. Additionally, in 2016 GRS conducted an inline inspection (ILI) of the 30” transmission pipeline in accordance with DOT 49 CFR Part 192, Subpart O requirements. Results of that inspection were compiled in a report that was filed with the CPUC. The ILI process is considered effective for assessment of this pipeline. The pipeline is scheduled for its next reassessment in seven (7) years to be completed by April 27th, 2022. Several direct assessment digs were completed after completing the ILI and validation digs. Blistering of the Power J joint coating appears to have been caused by poor surface preparation prior to applying the coating. Further inspection indicates that the underground pipeline is not at threat of experiencing external corrosion. The Gill Ranch Facility does not include any distribution pipelines. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests an exemption from this BP as it is being unwarranted due to the age and condition of the Gill Ranch Facility transmission pipelines. There are no “known risks for natural gas leakage” or “specific pipeline materials known to be susceptible to leaks or other known pipeline integrity risks, such as geological conditions.” All of the Gill Ranch Facility transmission pipelines were constructed in 2010. They consist of:

26 miles of 30” mainline transmission, connecting to PG&E Line 401

4.1 miles of 10“ transmission pipeline connecting the compressor station to wells

1.9 miles of 16“ transmission pipeline connecting the compressor station to wells

In addition, this BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports.


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DOT 49 CFR Part 192 – incremental requirements for surveys due to special conditions that do not exist for the Gill Ranch transmission pipelines

CPUC General Order 112-F, Section 143.1(b)Leakage Surveys and Procedures 192 – incremental requirements for surveys due to special conditions that do not exist for the Gill Ranch transmission pipelines

e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None




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a) Technology: None



d) Other: None


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4.1.17 BP 17 – Enhanced Methane Detection

PART 1: OVERVIEW


Utilities shall utilize enhanced methane detection practices (e.g. mobile methane detection and/or aerial leak detection) including gas speciation technologies.


a) Historic work: GRS routinely surveys the gas storage field and associated equipment for leaks in accordance with existing regulations. This includes the following:

Daily visual and leakage inspections of all well pads

Quarterly visual patrol of all transmission pipelines

Annual leakage inspection of all transmission pipelines

Quarterly leakage inspection of all High Consequence Areas (HCA’s and those Class 2 areas that GRS operationally inspects as a Class 3 areas to enhance pipeline safety

Continuous monitoring of operating parameters by a SCADA system

Quarterly sampling for surface gas pursuant to the Gas Monitoring Plan (GMP), provided as Appendix G to the Gill Ranch Storage Project Final Initial Study/Mitigated Negative Declaration, as revised by GRS and approved by the California Public Utilities Commission (CPUC) on September 17, 2010 (GRS, 2010).


c) Proposed Plan: GRS requests exemption from this BP as it is overly burdensome considering the degree of monitoring and inspection currently in place for the Gill Ranch Facility. The footprint of the facilities does not warrant a mobile methane detector. As described in the Executive Summary, GRS will be installing a permanent ambient air monitoring system during 2018 which should provide for better detection than periodic aerial leak detection surveys. GRS proposes to continue with the existing monitoring and inspection programs and the continuous ambient air monitoring system once installed later in 2018. In addition, this BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? (1) Overlap with California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate

Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. These regulations require continuous ambient air monitoring systems to be installed for all storage fields, but not mobile methane detection equipment.

(2) Overlap with the Gas Monitoring Plan (GMP), provided as Appendix G to the Gill Ranch Storage Project Final Initial Study/Mitigated Negative Declaration, as revised by GRS and approved by the California Public Utilities Commission (CPUC) on September 17, 2010 (GRS, 2010).

e) What technology is required to implement the best practice and why?


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NA – Exemption requested f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other:

Gill Ranch Gas Monitoring Plan - Appendix G to the Gill Ranch Storage Project Final Initial Study/Mitigated Negative Declaration, as revised by GRS and approved by the California Public Utilities Commission – September 2010

Gill Ranch Underground Gas Storage Monitoring Plan – December 2017


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4.1.18 BP 18 – Stationary Methane Detectors

PART 1: OVERVIEW


Utilities shall utilize Stationary Methane Detectors for early detection of leaks. Locations include: Compressor Stations, Terminals, Gas Storage Facilities, City Gates, and Metering & Regulating (M&R) Stations (M&R above ground and pressures above 300 psig only). Methane detector technology should be capable of transferring leak data to a central database, if appropriate for location.


a) Historic work: As described in the Executive Summary, GRS has designed an ambient air monitoring system and filed a plan with ARB for its review and approval. That system will continuously monitor the ambient air at two locations in the gas storage field and compare levels of detected methane to baseline data to determine if there is a source of leakage. If so, the source of any potential leak can be investigated and repaired as soon as practicable. If the plan is approved as submitted, this system is expected to be installed before yearend 2018. Each reciprocating compressor has a permanent gas detector above it and the compressor building is equipped with a long range gas detector that can detect gas across all five compressor units. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests exemption from this BP as being redundant of existing ARB regulations requiring the installation of a permanent ambient air monitoring system and overly burdensome in that it will require separate reporting of results in future biennial compliance plan filings. GRS has very limited staff for preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? Overlap with California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. These regulations require continuous ambient air monitoring systems to be installed for all storage fields, immediate reporting of alarm conditions (detected methane exceeds baseline data) and annual reporting of results. e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None


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a) Technology: None



d) Other: Gill Ranch Underground Gas Storage Monitoring Plan – December 2017


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4.1.19 BP 19 – Above Ground Leak Surveys

PART 1: OVERVIEW


Utilities shall conduct frequent leak surveys and data collection at above ground transmission and high pressure distribution (above 60 psig) facilities including Compressor Stations, Gas Storage Facilities, City Gates, and Metering & Regulating (M&R) Stations (M&R above ground and pressures above 300 psig only). At a minimum, above ground leak surveys and data collection must be conducted on an annual basis for compressor stations and gas storage facilities.


a) Historic work: GRS conducts leakage surveys over all transmission pipelines at least annually in accordance with both PHMSA and CPUC regulations (see 2.d below). During March 2018 the GRS staff will complete a leakage survey of all aboveground components within the storage facility in accordance with existing ARB regulations (see 2 d below). This inspection is required quarterly with results reported to ARB annually. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: The existing ARB regulations regarding aboveground leak surveys for underground storage facilities are considerably more stringent than this BP. GRS requests an exemption to avoid the redundant and overly burdensome task, and redundant reporting requirements. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? (1) Overlap with California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate

Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. There are no incremental requirements of this BP.

(2) Overlap with the Transmission Lines: Leakage Surveys (49 CFR 192.706 and G.O. 112 F (143). There are no incremental requirements of this BP.

e) What technology is required to implement the best practice and why? NA – Exemption requested f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones):


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NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: None


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4.1.20 BP 20a – Quantification & Geographic Tracking

PART 1: OVERVIEW

a) Best Practice: 20a b) Status: Exemption Requested

Utilities shall develop methodologies for improved quantification and geographic evaluation and tracking of leaks from the gas systems. Utilities shall file in their Compliance Plan how they propose to address quantification. Utilities shall work together, with CPUC and ARB staff, to come to agreement on a similar methodology to improve emissions quantification of leaks to assist demonstration of actual emissions reductions.


a) Historic work: GRS has developed a set of volume calculation templates to aid in determining the quantity of gas emitted from various equipment and pipeline segments within the Gill Ranch Facility. These templates are based on the physical attributes of the various elements and utilize the measured pressure in the equipment to determine the standard cubic feet of natural gas emitted. The volume of methane emitted can then be determined based on the analysis of gas within the storage reservoirs which is done continuously by an onsite chromatograph and annually by an independent laboratory.. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests exemption from this BP as it is overly burdensome for a storage operator of its size. The leak quantification methodology is well established for the Gill Ranch Facility. The geographic evaluation and tracking of leaks cannot be justified for a facility such as Gill Ranch with a very limited footprint and minimal leak history. In addition, this BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? Overlap with California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. There are no incremental requirements of this BP. e) What technology is required to implement the best practice and why? NA – Exemption requested f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested


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h) What are the new procedures to develop or existing procedures to modify? Please provide details. None – Exemption Requested i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: None


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BP 20b – Geographic Tracking

PART 1: OVERVIEW

a) Best Practice: 20b b) Status: Exemption Requested

Utilities shall develop methodologies for improved geographic tracking and evaluation of leaks from the gas systems. Utilities shall work together, with CPUC and ARB staff, to come to agreement on a similar methodology to improve geographic evaluation and tracking of leaks to assist demonstrations of actual emissions reductions. Leak detection technology should be capable of transferring leak data to a central database in order to provide data for leak maps. Geographic leak maps shall be publicly available with leaks displayed by zip code or census tract.


a) Historic work: GRS conducts leakage surveys over all transmission pipelines at least annually in accordance with both PHMSA and CPUC regulations (see 2.d below).


c) Proposed Plan: GRS requests emption from this BP due to the extremely limited footprint of its transmission pipeline facilities, the leakage surveys GRS already conducts and the overly burdensome task of creating and maintaining a geographical tracking system. In addition, this BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

DOT 49 CFR Part 192 – incremental requirements for surveys due to special conditions that do not exist for the Gill Ranch transmission pipelines. The geographic tracking and transferring leak data to a central database are incremental to these regulations.

CPUC General Order 112-F, Section 143.1(b) Leakage Surveys and Procedures 192 – incremental requirements for surveys due to special conditions that do not exist for the Gill Ranch transmission pipelines.

The geographic tracking and transferring leak data to a central database are incremental to these regulations.

e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested


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h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: None


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4.1.21 BP 21 – Find It / Fix It

PART 1: OVERVIEW


Utilities shall repair leaks as soon as reasonably possible after discovery, but in no event, more than three (3) years after discovery. Utilities may make reasonable exceptions for leaks that are costly to repair relative to the estimated size of the leak.


a) Historic work: GRS typically repairs leaks as soon as practicable, given any operational constraints. It is highly unusual for leaks to remain unrepaired for more than a few weeks. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests an exemption from this BP due to the historical small number of leaks detected and the requirement to comply with the more restrictive ARB regulations for gas storage fields regarding specific repair timelines based on the size of the leak (see 2 d). This BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities.

Specific repair timelines currently range from 5 to 14 days, depending on the detected ppm level of the leak. This reduces to 2 to 14 days in 2020. There are no incremental requirements of this BP. e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested


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j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: NA – Exemption Requested


a) Technology: None



d) Other: None


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4.1.22 BP 22 – Pipe Fitting Specifications

PART 1: OVERVIEW


Companies shall review and revise pipe fitting specifications, as necessary, to ensure tighter tolerance/better quality pipe threads. Utilities are required to review any available data on its threaded fittings, and if necessary, propose a fitting replacement program for threaded connections with significant leaks or comprehensive procedures for leak repairs and meter set assembly installations and repairs as part of their Compliance Plans. A fitting replacement program should consider components such as pressure control fittings, service tees, and valves metrics, among other things.


a) Historic work: As described in the Executive Summary, the Gill Ranch Facility is a modern facility

designed, constructed and operated based on current standards. The Facility was designed with high strength materials and a limited number of threaded fittings. Pressure control valves and isolation valves have flanged or welded fittings. There are no service tees. Aboveground facilities are surveyed quarterly for leakage in accordance with ARB regulations. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests an exemption from this BP because no action is required - the Gill Ranch Facility has no “threaded connections with significant leaks” to provide a basis for such a plan. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

DOT 49 CFR Part 192

CPUC General Order 112-F

California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities.

e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None i) Timeline for implementation (Milestones): NA – Exemption requested


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j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: Revisions to procedures and practices may result in an emission reduction benefit (no estimate at this time). 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: None


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4.1.23 BP 23 – Minimize Emissions from Operations, Maintenance and Other Activities

PART 1: OVERVIEW


Utilities shall minimize emissions from operations, maintenance and other activities, such as new construction or replacement, in the gas distribution and transmission systems and storage facilities. Utilities shall replace high-bleed pneumatic devices with technology that does not vent gas (i.e. no-bleed) or vents significantly less natural gas (i.e. low-bleed) devices. Utilities shall also reduce emissions from blowdowns, as much as operationally feasible.


a) Historic work: As described in the Executive Summary, the Gill Ranch Facility is a modern facility

designed, constructed and operated based on current standards. The facility was designed with a minimum number of continuous bleed devices and all of those are considered “low bleed” based on ARB’s definition of less than 6.0 SCFH. Blowdowns are the largest source of emissions at the Gill Ranch Facility. The full implementation of policies M-001, Methane Leakage Abatement, and V-001,

Methane Evacuation & Venting and the development of related procedures (described below) will aid in the future reduction of emissions from operations and maintenance. To reduce blowdown emission volumes, GRS’ practice has been to lower the pressure within equipment and pipelines to the greatest extent possible by equalizing the higher pressure sections to connected lower pressure equipment prior to venting to atmosphere.

b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: With the recent adoption of policies M-001, Methane Leakage Abatement, and V-

001, Methane Evacuation & Venting, GRS will embark on an evaluation of existing O&M procedures to determine appropriate revisions and possible new procedures necessary to ensure compliance with the policies.

1) Identify specific procedures that will require modification to be consistent with this policy 2) Revise procedures accordingly 3) Train personnel d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities

Pending DOGGR regulations “California Code of Regulations, Title 14 Chapter 4. Development, Regulation and Conservation of Oil and Gas Resources, Subchapter 1. Onshore Well Regulations

The extent of overlap and incremental requirements of this BP will be determined in the review process. e) What technology is required to implement the best practice and why? TBD f) Will work require additional personnel and/or contract support? If so, please provide details.


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Contract personnel will be required to review current O&M procedures, revise as necessary, develop new procedures and train personnel g) What changes to existing operations are required? How will those changes be implemented? Undetermined as yet. h) What are the new procedures to develop or existing procedures to modify? Please provide details. To be determined based on the review of all O&M procedures. i) Timeline for implementation (Milestones):

July 1, 2018 – Review and identify procedures requiring revision September 1, 2018 – Revise procedures December 31, 2018 – Train GRS operators and maintenance personnel j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? Not known at this time m) Anticipated Emissions Reductions from this BP: None – The new policies will not directly reduce emissions, but will likely lead to the revision of procedures and practices which may have an emission reduction benefit. 2015 Baseline Emissions affected, where known: Unknown n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None





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4.1.24 BP 24 – Dig-Ins / Public Education Program

PART 1: OVERVIEW


Dig-Ins – Expand existing public education program to alert the public and third-party excavation contractors to the Call Before You Dig – 811 program. In addition, utilities must provide procedures for excavation contractors to follow when excavating to prevent damaging or rupturing a gas line


a) Historic work: The Gill Ranch Facility is a participant in the CA One-Call system and receives notification when excavations are planned in the vicinity of any of its underground facilities. As part of its active Public Awareness Program, GRS routinely communicates with local stakeholders in the following ways:

Safety information brochures are sent to every resident in close proximity to the pipelines

GRS hosts an information event for all property owners in the pipeline Class 3 locations

GRS participates in a backpack give-away program in Mendota where safety brochures are distributed.

To date there have been no dig-ins on any the Gill Ranch Facility pipelines. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: : GRS requests emption from this BP due to the existing programs already in place to educate the public regarding third party excavations near the Gill Ranch Facility transmission pipelines and the excellent safety record of no excavation damage in the 7 plus year operating history of the Facility. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

DOT 49 CFR Part 192 – incremental requirements to expand the current damage prevention and public education programs and to develop procedures for evacuation contractors

CPUC General Order 112-F, Section 143.1(b)Leakage Surveys and Procedures 192 – incremental requirements to expand the current public education program and develop procedures for evacuation contractors

e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details.


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None i) Timeline for implementation (Milestones): NA – Exemption requested j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA – Exemption requested k) Identify any cost benefits from this BP, when cost estimates are known: NA – Exemption requested l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? NA – Exemption requested m) Anticipated Emissions Reductions from this BP: None 2015 Baseline Emissions affected, where known: NA n) Calculation Methodology: NA o) Additional Comments: None



a) Technology: None



d) Other: Gill Ranch Storage Public Awareness Program Gill Ranch Storage Safety Information Brochure


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4.1.25 BP 25 – Dig-Ins / Company Standby Monitors

PART 1: OVERVIEW


Dig-Ins – Utilities must provide company monitors to witness all excavations near gas transmission lines to ensure that contractors are following utility procedures to properly excavate and backfill around transmission lines.


a) Historic work: The Gill Ranch Facility is a participant in the CA One-Call system and receives notification when excavations are planned in the vicinity of any of its underground facilities. When a notification is received, GRS personnel determine where the planned excavation is located relative to the underground pipeline. It excavation will occur within 25 feet of the centerline of the pipeline, then a qualified GRS operator will standby at the site, coordinate with the excavator and monitor all excavation activity. b) Alternative Proposal to BP or exemption? None

c) Proposed Plan: The current GRS practice of standing by during excavation activity in the vicinity of the transmission pipelines has not been documented in a written procedure. GRS will develop a written procedure to address excavation standbys. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations?

DOT 49 CFR 192.935(a)(4). Operators with pipelines in High Consequence Areas are currently required to monitor excavations. e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. Contract personnel will be required to develop the new excavation procedures and train personnel. g) What changes to existing operations are required? How will those changes be implemented? None anticipated h) What are the new procedures to develop or existing procedures to modify? Please provide details. Develop a new procedure for monitoring/standby for excavation near transmission pipelines. i) Timeline for implementation (Milestones): Procedure to be developed by July 1, 2018. j) Identify the range of factors or considerations used to determine cost-effectiveness of this measure, when costs estimates have been determined: NA


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k) Identify any cost benefits from this BP, when cost estimates are known: NA l) Do any incremental costs, if known, or benefits overlap with other BPs? If so, to which BP do they overlap, what are they, and how do they overlap? m) Anticipated Emissions Reductions from this BP: None, the practice is already established. The procedure will simply document what is already being performed. 2015 Baseline Emissions affected, where known: None n) Calculation Methodology: NA o) Additional Comments: None

p) Overlap with Safety: None


a) Technology: None





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4.1.26 BP 26 – Dig-Ins / Repeat Offenders

PART 1: OVERVIEW


Utilities shall document procedures to address Repeat Offenders such as providing post-damage safe excavation training and on-site spot visits. Utilities shall keep track and report multiple incidents, within a 5-year period, of dig-ins from the same party in their Annual Emissions Inventory Reports. These incidents and leaks shall be recorded as required in the recordkeeping best practice. In addition, the utility should report egregious offenders to appropriate enforcement agencies including the California Contractor’s State License Board. The Board has the authority to investigate and punish dishonest or negligent contractors. Punishment can include suspension of their contractor’s license.


a) Historic work: The Gill Ranch Facility is a participant in the CA One-Call system and receives notification when excavations are planned in the vicinity of any of its underground facilities. As part of its active Public Awareness Program, GRS routinely communicates with local stakeholders regarding excavation practices near the pipelines and general safety information. There has never been a dig-in in any of the Gill Ranch Facility pipelines, and therefore no repeat offenders. b) Alternative Proposal to BP or exemption? Exemption Requested

c) Proposed Plan: GRS requests exemption from this BP because its pipelines are in a very limited footprint with limited exposure from excavations and there have been no recorded dig-ins to date. In addition, this BP would require separate reporting of results in future biennial compliance plan filings adding to the regulatory burden on the very limited GRS staff which is tasked with the preparation of these reports. d) Overlap with other regulations? What portion of the BP is incremental beyond those regulations? California Government Code 4216.19(e)(3), beginning on July 1, 2020, requires the board to consider the operator’s or excavator’s history of violations when considering the issuance of citations and assessment of penalties. The referenced California Government Code overlaps with this BP in that they both address the investigation and punishment of repeat offenders. e) What technology is required to implement the best practice and why? None f) Will work require additional personnel and/or contract support? If so, please provide details. No – Exemption requested g) What changes to existing operations are required? How will those changes be implemented? None – Exemption requested h) What are the new procedures to develop or existing procedures to modify? Please provide details. None


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a) Technology: None





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SUPPLEMENTAL DOCUMENTS

1) GRS Policy M-001 – Methane Leakage Abatement Policy

2) GRS Policy V-001 – Methane Evacuation & Venting

3) GRS Emergency Response Plan

4) Gill Ranch Gas Monitoring Plan - Appendix G to the Gill Ranch Storage Project Final Initial Study/Mitigated Negative Declaration, as revised by GRS and approved by the California Public Utilities Commission – September 2010

5) Gill Ranch Underground Gas Storage Monitoring Plan – December 2017

6) Gill Ranch Storage Public Awareness Program

7) Gill Ranch Storage Safety Information Brochure

Date post:	18-Jun-2020
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Biennial Methane Leak Abatement Compliance Plan · 2018-04-06 · Gill Ranch Gas Storage Facility...

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