R.15-01-008 CEK/sf3 · R.15-01-008 CEK/sf3 5 of 6 (7) An annual report on measures that will be taken in the following year to reduce gas leaks and emissions to achieve the goals

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ATTACHMENT 3

RULEMAKING (R.) 15-01-008 TO ADOPT RULES AND PROCEDURES GOVERNING COMMISSION REGULATED NATURAL GAS PIPELINES AND FACILITIES TO

REDUCE NATURAL GAS LEAKS CONSISTENT WITH SENATE BILL 1371, LENO.

ANNUAL REPORT TEMPLATE

Lodi Gas Storage, L.L.C.

Natural Gas Leakage Abatement Report

In partial fulfillment of

Rulemaking (R.) 15-01-008 to Adopt Rules and Procedures Governing Commission Regulated Natural Gas Pipelines and Facilities to Reduce

Natural Gas Leaks Consistent with Senate Bill 1371, Leno.

And In Response to Data Requests Lodi Gas Storage, L.L.C. R15-01-008

2017 Annual Report

By:

Date: 6/16/2017

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Introduction

The following data11 have been prepared to comply with Senate Bill 1371 (Leno, 2014),

Section 2, Article 3, Order Instituting Rulemaking (OIR) 15-01-008, and to provide our

responses to Data Requests Lodi Gas Storage, L.L.C. R15-01-008 2017 Annual Report.

Pursuant to SB 1371, Leno - Natural gas: leakage abatement, the California Public

Utilities Commission (CPUC) requests that the following information be transmitted to

the CPUC and the State Air Resources Board (ARB):

(1) A summary of changes to utility leak and emission management practices from

January 1st, 2016 to December 31st, 2016. The report must include a detailed

summary of changes, including the reasoning behind each change and an

explanation of how each change will reduce methane leaks and emissions.

Response:

LGS procedures that address how gas leaks are identified, classified and

repaired are contained within the LGS Operations and Maintenance (O&M)

Manual, as submitted to CPUC as a part of the Safety Plan. The LGS O&M

Manual is reviewed and updated annually in accordance with 49 CFR 192.605(a)

and changes to the O&M Manual are documented in the Record of Revisions

section.

Only one change to leak management practices (i.e., Procedures 5.02, 5.03,

and 9.01 in the O&M Manual) was made during annual updates in 2016.

11 As described in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2016 Annual Report

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Specifically, Procedure 9.01 for Pipeline Repair Procedures was revised to

include language from Public Utilities Code section 955.5 regarding repair

notifications to schools and hospitals. This procedural change is not expected to

reduce methane emissions, but promotes safety and public awareness in the

event of a leak.

(2) A list of new graded and ungraded gas leaks discovered, tracked by geographic

location in a Geographic Information System (GIS) or best equivalent, by grade,

component or equipment, pipe size, schedule and material, pressure, age, date

discovered and annual volume of gas leaked for each, by month, from January

1st, 2016 through December 31st, 2016

Response:

See Appendices

(3) A list of graded and ungraded gas leaks repaired, tracked by geographic location

in a Geographic Information System (GIS) or best equivalent, by month, from

January 1st, 2016 through December 31st, 2016. Include the grade, component or

equipment, pipe size, schedule and material, pressure, age, date discovered, date

of repair, annual volume of gas leaked for each and the number of days from the

time the leak was discovered until the date of repair.

Response:

See Appendices

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(4) A list of ALL open graded and ungraded leaks, regardless of when they were

found, tracked by geographic location in a Geographic Information System (GIS)

or best equivalent that are being monitored, or are scheduled to be repaired, by

month, from January 1st, 2016 through December 31st, 2016. Include the grade,

component or equipment, pipe size, schedule and material, pressure, age, date

discovered, scheduled date of repair, and annual volume of gas leaked for each.

Response:

See Appendices

(5) System-wide gas leak and emission rate data, along with any data and computer

models used in making that calculation, for the 12 months ending December 31st,

of the reporting year.

Response:

See Appendices

(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data

Request Lodi Gas Storage, L.L.C. R15-01-008 2017 Annual Report for the 12

months ending December 31st, 2016.

Response:

See Appendices

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(7) An annual report on measures that will be taken in the following year to reduce

gas leaks and emissions to achieve the goals of SB 1371. The report must include

a detailed summary of changes, including the reasoning behind each change and

an explanation of how each change will reduce methane leaks and emissions.

Response:

As part of its safety, operations and maintenance programs, LGS

prioritizes the identification of methane emissions sources, including leaks and

emissions resulting from normal operations, and keeping them to a minimum.

On an ongoing basis, employees are vigilant in assuring that any leaks are

identified and repaired promptly. Procedures and technology for identifying,

preventing and minimizing emissions are evaluated at least every year as part of

periodic reviews.

To date, this combination of operational awareness and periodic reviews,

coupled with relatively modern facilities, has yielded great success in

minimizing emissions. While this success has made it difficult to identify cost-

effective changes in LGS’s current safety and emissions reductions programs that

will significantly reduce LGS’s already low emissions levels, LGS recognizes that

technology evolves and is open to the adoption of newly developing technology

and operational procedures that will allow for further reductions. In addition to

ongoing efforts to keep apprised of these advancements through participation in

and awareness of industry-led efforts, LGS has actively participated in

workshops related to the implementation of SB 1371.

Any cost-effective changes to the procedures and technology LGS uses to

identify, prevent and repair leaks and otherwise reduce emissions, be they

identified in the SB 1371 implementation process or from other sources, will be

evaluated by LGS based, among other things, on their effectiveness in reducing

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emissions, and impact on operations and safety procedures. In addition to those

changes found to meet these standards, any required changes arising from

ongoing regulatory initiatives to which LGS is subject, will be scheduled for

implementation. Given the pendency of the SB 1371 proceeding and continuing

success of LGS’s existing efforts to keep emissions to a minimum, LGS has no

significant changes planned for the coming year.

(END OF ATTACHMENT 3)


Rulemaking (R.) 15-01-008 to Adopt Rules and Procedures Governing Commission Regulated Natural Gas Pipelines and Facilities to Reduce Natural Gas Leaks Consistent with Senate Bill 1371, Leno.and In Response to Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report

Issued: March 31, 2017Appendix 1 Rev. 3/31/17

Pursuant to SB 1371, Leno - Natural gas: leakage abatement, the California Public Utilities Commission (CPUC) requests that the following information be transmitted to the CPUC and the State Air Resources Board (ARB):Note - Definitions in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report

The following questions in the above mentioned data requests are answered using the spreadsheets in this Appendix (#1):(2) A List of new graded and ungraded gas leaks discovered, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, by grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered and annual volume of gas leaked for each, by month, from January 1st through December 31st of the previous calendar year. (3) List of graded and ungraded gas leaks repaired, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, from January 1st through December 31st of the previous calendar year. Include the grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered, date of repair, annual volume of gas leaked for each and the number of days from the time the leak was discovered until the date of repair.(4) List of ALL open graded and ungraded leaks, regardless of when they were found, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, that are being monitored or are scheduled to be repaired, from January 1st through December 31st of the previous calendar year. Include the grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered, scheduled date of repair, and annual volume of methane leaked for each.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orange.Response:

Transmission Pipeline Leaks:

IDGeographic

LocationPipe

MaterialPipe Size(nominal)

Pipe Age(months)

Pressure(psi)

Leak Grade

Above Ground or Below Ground

Discovery Date(MM/DD/YY)

Repair Date(MM/DD/YY)

ScheduledRepair Date

(MM/DD/YY)

Reason for Not Scheduling a Repair

Numberof

Days Leaking

Emission Factor(Mscf/Day)

Annual Emissions(Mscf)

Explanatory Notes / Comments

Sum total 0





The following questions in the above mentioned data requests are answered using the spreadsheets in this Appendix (#1):(2) A List of new graded and ungraded gas leaks discovered, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, by grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered and annual volume of gas leaked for each, by month, from January 1st through December 31st of the previous calendar year. (3) List of graded and ungraded gas leaks repaired, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, from January 1st through December 31st of the previous calendar year. Include the grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered, date of repair, annual volume of gas leaked for each and the number of days from the time the leak was discovered until the date of repair.(4) List of ALL open graded nd ungraded leaks, regardless of when they were found, tracked by geographic location in a Geographic Information System (GIS) or best equivalent, that are being monitored or are scheduled to be repaired, from January 1st through December 31st of the previous calendar year. Include the grade, component or equipment, pipe size, schedule and material, pressure, age, date discovered, scheduled date of repair, and annual volume of methane leaked for each.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeResponse:

Transmission Pipeline Damage (3rd party dig-ins, natural disasters, etc.):

IDGeographic

LocationDamage

TypePipe

MaterialPipe Size(nominal)

Pipe Age(months)

Pressure(psi)

Leak Grade

Above Ground or Below Ground



Numberof

Days Leaking

Numberof

Days Until Permanent Repair

Emission Factor(Mscf/Day)



Sum total 0





The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#1):(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orange.Response:

Transmission Pipeline Blowdowns:

IDGeographic

Location

Numberof

Blowdown Events



1 95220 18 63 Preventive maintenance on meter runs2 94585 8 1.7 Preventive maintenance on meter runs

Sum total 64.7





The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#1):

(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeThe emissions captured on this tab represent the emissions associated with the operational design and function of the component. Any intential release of natural gas for safety or maintenance purposes should be included in the Blowdowns worksheet.Response:

Transmission Pipeline Component Vented Emissions:

Total Number of Devices

DeviceType

Bleed Rate ManufacturerEmission Factor

(Mscf/day)Annual Emission

(Mscf)Explanatory Notes / Comments

Sum total 0





The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#1):

(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orange

Response:

Transmission Pipeline Component Fugitive Leaks:

IDGeographic

LocationDeviceType

Bleed Rate ManufacturerDiscovery Date(MM/DD/YY)


Numberof

Days Leaking

Emission Factor(Mscf/day)

Annual Emission(Mscf)


Sum total 0

The emissions captured on this tab represent the emissions associated unintentional leaks that if repaired would not leaking. If the component is releasing gas or "bleeding" as a result of its design or function then it is not to be captured in this tab.





The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#1):(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report.Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeResponse:

Transmission Pipeline Odorizers:

IDGeographic

LocationNumber of Units

Emission Factor(Mscf/yr)

Annual Emission(Mscf)


Sum total 0




Rulemaking (R.) 15-01-008 to Adopt Rules and Procedures Governing Commission Regulated Natural Gas Pipelines and Facilities to Reduce Natural Gas Leaks Consistent with Senate Bill 1371, Leno.and In Response to Data Request Lodi Gas Storage, L.L.C. R15-01-008 2016 May Report




Response:

Underground Storage Blowdowns:

IDGeographic

LocationSource

CompressorType

Numberof

Blowdown Events



2000 94585 C R 1 4 Preventive maintenance3000 94585 C R 4 40 Preventive maintenance4000 94585 C R 7 105 Preventive maintenance

Sum total 149




Pursuant to SB 1371, Leno - Natural gas: leakage abatement, the California Public Utilities Commission (CPUC) requests that the following information be transmitted to the CPUC and the State Air Resources Board (ARB):Note - Definitions in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June ReportThe following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#7):(6) Calculable or estimated emissions and non-graded gas leaks, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report.

Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeUse the Population based emission factor if facility is not surveyed. Use Leaker based emission factor if facility is surveyed, and report only the found leaking components.

Response:

Underground Storage Facility Leaks and Emissions:

IDGeographic

LocationSource Number of Sources

Emission Factor(Mscf/yr)



1 95220 P 1 NA 26 gasket weep on flange 20" midland pipeline

Sum total 26






Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeThe emissions captured on this tab represent the emissions associated with the operational design and function of the compressor. Any intentional release of natural gas for safety or maintenance purposes should be included on the Blowdowns worksheet.Response:

Underground Storage Facility Compressor Vented Emissions (see note above):

IDGeographic

LocationCompressor

TypePrimeMover

Numberof

Cylinders in Compressor

Numberof

Seals

SealType

Operating Mode:Pressurized Operating

(hours)

Operating Mode:Pressurized Idle

(hours)

Operating Mode:Depressurized Idle

(hours)

Emission Factor: Pressurized Operating

(scf/hr)

Emission Factor: Pressurized Idle

(scf/hr)

Emission Factor:Depressurized Idle

(scf/hr)



1000 94585 R C 4 4 W 1039 7745 0 19.1 0 0 19.842000 94585 R C 4 4 W 1149 7635 0 19.1 0 0 21.953000 94585 R C 4 4 W 754 8024 6 19.1 0 0 14.404000 94585 R C 6 6 W 2025 6703 56 19.1 0 0 38.68

Sum total 95







Response:

Underground Storage Facility Compressor Fugitive Leaks (See note above):

IDGeographic

LocationCompressor

TypePrimeMover

Numberof

Cylinders in Compressor

Numberof

Seals

SealType

Operating Mode:Pressurized Operating

(hours)

Operating Mode:Pressurized Idle

(hours)

Operating Mode:Depressurized Idle

(hours)

Emission Factor: Pressurized Operating

(scf/hr)

Emission Factor: Pressurized Idle

(scf/hr)

Emission Factor:Depressurized Idle

(scf/hr)



Numberof

Days Leaking



Sum total 0

The emissions captured on this tab represent the emissions associated unintentional leaks that if repaired would not leaking. If the compressor is releasing gas or "bleeding" as a result of its design or function then it is not to be captured in this tab.





Notes:Use a formula-derived value with the formula used in the Annual Emissions column. Do not use a copy and paste-as-value.At the end of Annual Emissions Column, add a summation total in a cell for a column total, and then highlight orangeThe emissions captured on this tab represent the emissions associated with the operational design and function of the component. Any intentional release of natural gas for safety or maintenance purposes should be included on the Blowdowns worksheet.

Response:

Underground Storage Component Vented Emissions (See note above):

IDGeographic

LocationDevice Type Bleed Rate Manufacturer

Pressure(psi)

Survey Date (MM/DD/YY)

Numberof

Days Emitting

Emission Factor, Engineering or

Manufacturer's based Estimate of Emissions

(Mscf/day)



Kirby Hills - connec 94585 C NA varies varies NA NA 0.0876 118.87 No leaks discovered in 2016; estimated emissions based on population counts.Kirby Hills - pressur 94585 PR NA varies varies NA NA 1.489 59.56 No leaks discovered in 2016; estimated emissions based on population counts.Kirby Hills - valves 94585 V NA varies varies NA NA 0.876 537.86 No leaks discovered in 2016; estimated emissions based on population counts.Lodi - connectors 95220 C NA varies varies NA NA 0.0876 86.55 No leaks discovered in 2016; estimated emissions based on population counts.Lodi - pressure reli 95220 PR NA varies varies NA NA 1.489 26.80 No leaks discovered in 2016; estimated emissions based on population counts.Lodi - valves 95220 V NA varies varies NA NA 0.876 310.98 No leaks discovered in 2016; estimated emissions based on population counts.

Sum total 1141






Response:

Underground Storage Component Fugitive Leaks (see note above):

IDGeographic

LocationDevice Type Bleed Rate Manufacturer

Pressure(psi)



Numberof

Days Leaking

Emission Factor or Engineering Estimate

(Mscf/day)



Sum total 0

The emissions captured on this tab represent the emissions associated unintentional leaks that if repaired would not leaking. If the component is releasing gas or "bleeding" as a result of its design or function then it is not to be captured in this tab.






Response:

Underground Storage Dehydrator Vented Emissions:

IDGeographic

LocationNumber of Sources

Emission Factor (Mscf/yr)



Sum total 0


Rulemaking (R.) 15-01-008 to Adopt Rules and Procedures Governing Commission Regulated Natural Gas Pipelines and Facilities to Reduce Natural Gas Leaks and In Response to Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report

3/31/2017Appendix 8 Rev. 3/31/17

Pursuant to SB 1371, Leno - Natural gas: leakage abatement, the California Public Utilities Commission (CPUC) requests that the following information be transmitted to the CPUC and the Sta Note - Definitions in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report

The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#8):(5) System-wide gas leak rate data, Lodi Gas Storage, L.L.C. R15-01-008 2016 May Report along with any data and computer models used in making that calculation, for the 12 months end

Response:

Summary Tables:

System Categories Emission Source CategoriesFugitive or

Vented

Total Annual Volume of Leaks & Emissions

(Mscf)

Total Annual Count of Leak & Emission Items

Pipeline Leaks Fugitive All Damages Fugitive Blowdowns Vented 64.7

Component Emissions Vented

Component Leaks Fugitive Odorizers Vented

Station Leaks & Emissions Fugitive Blowdowns Vented


Component Leaks Fugitive Compressor Emissions Vented

Compressor Leaks Fugitive Blowdowns Vented


Component Leaks Fugitive

Storage Tank Leaks & Emissions Vented

Pipeline Leaks Fugitive All Damages Fugitive Blowdowns Vented


Component Leaks Fugitive Station Leaks & Emissions Fugitive Blowdowns Vented


Component Leaks Fugitive Meter Leaks Fugitive Above Ground MSA Leaks Fugitive Vented Emissions Vented Storage Leaks & Emissions Fugitive 26

Compressor Emissions Vented 95

Compressor Leaks Fugitive Blowdowns Vented 149

Component Emissions Vented 1141

Component Leaks Fugitive Dehydrator Vent Emissions Fugitive

Unusual Large Leaks (Description)

Underground Storage

Transmission Pipelines

Transmission M&R Stations

Transmission Compressor Stations

Distribution Main & Service Pipelines

Distribution M&R Stations

Customer Meters



3/31/2017Appendix 8 Rev. 3/31/17


The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#8):(5) System-wide gas leak rate data, Lodi Gas Storage, L.L.C. R15-01-008 2017 June Report along with any data and computer models used in making that calculation, for the 12 months ending December 31st, of the reporting year.

Response:

System Wide Leak Rate Data1/1/2016 - 12/31/2016

Gas Storage Facilities:

Average Close of the Month Cushion Gas Storage Inventory

(Mscf)

Average Close of the Month Working Gas Storage Inventory

(Mscf)

Total Annual Volume of Injections into

Storage(Mscf)

Total Annual Volume of Withdrawals from Storage

(Mscf)


12260000 22874525 18021519 19219304

Transmission System:

Total Annual Volume of Gas Used by the Gas

Department(Mscf)

Total Annual Volume of Gas Transported to or for Customers* in

State(Mscf)

Total Annual Volume of Gas Transported to or for Customers* out

of State(Mscf)

Total Annual Volume of Gas Transported to utility-

owned or third-party storage fields for injection

into storage(Mscf)


19219304 18021519 Gas flow in transmission pipeline is bi-directional; gas withdrawn from storage is listed under column B and gas injected for storage is listed under column D.

Distribution System:

Total Annual Volume of Gas Used by the Gas

Department(Mscf)

Total Annual Volume of Gas Transported to or for Customers* in

State(Mscf)

Total Annual Volume of Gas Transported to or for Customers* out

of State(Mscf)


*The term customers includes anyone that the utility is transporting gas for, including customers who purchase gas from the utility.Customers can be anyone including residential, businesses, other utilities, gas transportation companies, etc.



3/31/2017Appendix 8 Rev. 3/31/17


The following question in the above mentioned data request is answered using the spreadsheets in this Appendix (#8):(5) The system-wide gas leak rate data, as defined in Data Request Lodi Gas Storage, L.L.C. R15-01-008 2016 May Report along with any data and computer models used in making that calculation, for the 12 months ending December 31st, of the reporting year.

Response:

Summary Tables:

Natural GasProperties

Average Mole Percent


Methane Natural gas meets PG&E specifications

Carbon Dioxide Natural gas meets PG&E specifications

Ethane Natural gas meets PG&E specifications

C3+ Natural gas meets PG&E specifications

C6+ Natural gas meets PG&E specifications

Oxygen Natural gas meets PG&E specifications

Hydrogen Natural gas meets PG&E specifications

Sulfur Natural gas meets PG&E specifications

Water Natural gas meets PG&E specifications

Carbon Monoxide Natural gas meets PG&E specifications

Particulate Matter Natural gas meets PG&E specifications

Inert Gas Natural gas meets PG&E specifications

Odorant Natural gas meets PG&E specifications

Documents

R.15-01-008 CEK/sf3 · R.15-01-008 CEK/sf3 5 of 6 (7) An annual report on measures that will be taken in the following year to reduce gas leaks and emissions to achieve the goals