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 ^cah4< f A * 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. 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EPA Form No. 5900-410 Template last updated: 9 December 2021 Page 1 ------- 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 Page 2 ------- 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 Page 3 ------- 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 Page 4 ------- 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 Page 5 ------- |