OMB Control No. 2060-0722
Approval expires 12/31/2024

Methane Challenge Program
Implementation Plan

Partner Name	Current As Of (Date)

City of Ellensburg Gas Division

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This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq.
(OMB Control No. 2060-0722). Responses to this collection of information are voluntary 42 USC 7403(g). An
agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless
it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this
collection of information is estimated to be 37 hours per response. Send comments on the Agency's need for this
information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent
burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200
Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do
not send the completed form to this address.

EPA Form No. 5900-410

Template last updated: 9 December 2021

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Methane Challenge Program Implementation Plan

Methane Challenge Commitments1 - BMP Commitment Option



Source

Start Date

Achievement Year

Onshore Production

~

Pneumatic Controllers







Equipment Leaks/Fugitive Emissions (commitment not finalized)







Liquids Unloading (commitment not finalized)







Pneumatic Pumps (commitment not finalized)





~

Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks







Continuous Improvement Source (TBD)







Continuous Improvement Source (TBD)





Gathering and Boosting

~

Pneumatic Controllers







Equipment Leaks/Fugitive Emissions (commitment not finalized)







Pneumatic Pumps (commitment not finalized)





~

Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks





~

Reciprocating Compressors - Rod Packing Vent





~

Centrifugal Compressors - Venting







Continuous Improvement Source (TBD)







Continuous Improvement Source (TBD)





Natural Gas (NG) Processing

~

Reciprocating Compressors - Rod Packing Vent





~

Centrifugal Compressors - Venting







Continuous Improvement Source (TBD)







Continuous Improvement Source (TBD)





NG Transmission & Underground Storage

~

Reciprocating Compressors - Rod Packing Vent





~

Centrifugal Compressors - Venting





~

Equipment Leaks (Compressor Blowdown and Isolation Valves)





~

Transmission Pipeline Blowdowns between Compressor Stations

(Commitment Rate: ; must be 50% or greater)





~

Pneumatic Controllers







Continuous Improvement Source (TBD)







Continuous Improvement Source (TBD)





NG Distribution



M&R Stations/City Gates (commitment not finalized)





~

Mains - Cast Iron and Unprotected Steel (Commitment Rate: )





~

Services - Cast Iron and Unprotected Steel





~

Distribution Pipeline Blowdowns (Commitment Rate: ; must be
50% or greater)





B

Excavation Damages

Jan 1, 2022

2027

H

Renewable Natural Gas

Jan 1, 2022

2025



Continuous Improvement Source (TBD)





1 Partners may delete unused rows within the table and may duplicate rows and add relevant details as needed (e.g., a corporate parent
partner that has different commitments for each LDC can duplicate relevant rows to list the commitments for each LDC).

EPA Form No. 5900-410

Template last updated: 9 December 2021

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Methane Challenge Program Implementation Plan

Source

Start Date

Achievement Year



Continuous Improvement Source (TBD)





Methane Challenge Commitments - ONE Future Emissions Intensity Commitment Option

Segment:



Intensity Target:



Target Year:



EPA Form No. 5900-410

Template last updated: 9 December 2021

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Methane Challenge Program Implementation Plan

Milestones/Timeframes for Meeting Commitments

Provide information on steps for achieving commitments such as anticipated rate ofprogress, key milestones, or other
context (e.g., referencing work to be done during the next planned shutdown of a facility).

The City of Ellensburg Gas Division is pleased to partner with the EPA through
this program and implementation plan to work toward reducing methane
emissions. The City Gas Division has committed to pursue a Best Management
Practice (BMP) within the Excavation Damages and Renewable Natural Gas
categories for Natural Gas Distribution.

The City of Ellensburg Gas Division's greatest threat to the integrity of its system
and methane emissions has been identified as excavation damages. The City
has worked hard through its Public Awareness and Damage Prevention Program
to educate contractors and excavators and minimize damages. Joining the
Methane Challenge will encourage and challenge the City Gas Division to
expand our data analysis, regularly evaluate our damage prevention program
and efforts, and come up with additional tracking metrics to evaluate our
progress toward our 2027 goal.

The City of Ellensburg Gas Division will be implementing the following goals for
this BMP:

•	Reduce excavation damage frequency (damages per 1000 tickets) to below
2.0.

•	Send letters to contractors or excavators for any known improper excavation
practices performed.

•	Ensure tnat all new gas lines are traceable.

•	Improve maps and records to facilitate better asset location/identification.

•	Have no mislocates/mismarks annually.

The City of Ellensburg Gas Division is currently working with the City's
Wastewater Treatment Facility to capture the methane being burnea-off and
converting it to pipeline quality gas for use on site and within the Gas Division's
system. Funding for the project has been designated and the project is expected
to be completed within the next few years.

EPA Form No. 5900-410

Template last updated: 9 December 2021

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Methane Challenge Program Implementation Plan

Additional Information/Context (optional)

Use this space, if desired, to provide other information about Program participation, such as plans for expanding Methane
Challenge commitments, how historical actions informed Methane Challenge commitments, or other information on how the
Program will be implemented.

The City of Ellensburg Gas Division has been minimizing system emissions
since it became a utility in 1956. Thanks to a strong City Council and utility team
all pipe in Ellensburg's system is coated and cathodically protected steel or high
density polyethylene. By not introducing cast iron or other materials now being
replaced across the country, the City of Ellensburg Gas Division has shown its
dedication to being a leader in reducing methane emissions associated with
operations while also providing increased pipeline integrity.

In addition to the City's commitment to reduce excavation damages through this
implementation plan, the City Gas Division will continually assess additional
measures, both within this program and outside of it, that could offer meaningful
emission reductions.

Two additional emission reduction activities the City of Ellensburg has
implemented are:

Increased leak survey frequency. Each year a quarter of the system is surveyed
with the entire system surveyed over 4 years. Tnis is an increase from the
regulations that require the system to be surveyed every 5 years.

EFV Installation: All new services have an EFV installed and anytime there is an
opportunity to install an EFV on an existing service, the City of Ellensburg will
install an EFV. With a majority of excavation damages occurring with service
lines, the installation of EFV's has reduced the excess emissions from damages
until the time of gas being shut off.

EPA Form No. 5900-410

Template last updated: 9 December 2021

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