Page 12 - ETRN 2019 Interim CSR Report test
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include those that can be reduced by either a       permits. Requirements to control methane
              change in operational practice or equipment         are typically a co-benefit to VOC control
              design. “Controllable” emissions do not             and are not explicitly stated. As of the
              include those that result from events such as       printing of this report, the only exception
              emergency situations, pipeline failures, or acts    to this is the general permit to be issued
              of God, etc. Generally, if an event is a one-time   by the Pennsylvania Department of
              occurrence and cannot be fully predicted, it is     Environmental Protection for compressor
              not considered to be controllable.                  stations. The most recent version of the
                                                                  GP-5, as it is commonly referred to, has
              Current Regulatory Requirements –                   explicit methane control requirements.
              Federal and/or State
                                                                  Monitoring and Reporting
              Control
                                                                  The EPA’s GHG reporting rules in 40 CFR
              Based on federal requirements, the only
                                                                  98 Subpart W – Petroleum and Natural
              methane regulation that currently affects a
                                                                  Gas Systems are contained in 40 CFR 98 –
              portion of our assets is 40 CFR 60 Subpart
                                                                  Mandatory Greenhouse Gas Reporting.
              OOOOa (Quad Oa). Quad Oa was announced
                                                                  The rule requires a facility having emissions
              on June 3, 2016 and was the first regulation
                                                                  of 25,000 metric tons or more of CO2e per
              that explicitly stated its purpose was to limit
                                                                  year to submit an annual report of GHGs to
              greenhouse gases. Previously, Environmental
                                                                  the EPA.
              Protection Agency (EPA) regulations
              that were intended to regulate methane
                                                                  Additionally, methane emissions must be
              emissions did so by regulating volatile
                                                                  reported to the state regulatory agencies
              organic compounds (VOCs), which are also
                                                                  within ETRN’s operating areas, as applicable.
              a component of natural gas. In this case, the
                                                                  In some cases, Subpart W methodologies are
              EPA stated that methane reduction was a
                                                                  used to calculate emissions for the state;
              “co-benefit” to controlling VOCs.
                                                                  however, in certain cases, methodologies
                                                                  based on engineering and process
              Assets potentially affected by Quad Oa,
                                                                  knowledge or vendor guarantees may be used.
              depending on their date of construction,
              reconstruction, or modification are:
                                                                  Methane Intensity Rate (as of year-end 2018)
              •  Reciprocating compressors
                                                                  In 2018, ETRN reported total methane
              •  Pneumatic controllers                            emissions of 4,850.5 tons. Our midstream
              •  Storage vessels                                  operations, which include gathering,
                                                                  transmission, and compressor station facilities,
              •  Fugitive emission components at
                                                                  had a methane intensity of 1.3 mtons/Tbtu.
               compressor stations
                                                                  ETRN’s assets included 101 compressor
                                                                  stations/dehydration facilities; 950 miles of
              At the state level, current environmental
                                                                  transmission lines; and 2,130 miles of high-
              agency requirements regarding control of
                                                                  and low-pressure gathering lines.
              methane emissions are established in air



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