METHANE REDUCTION COMMITMENT At Kinder Morgan, we recognize that operating thousands of miles of pipelines, 20 natural gas storage facilities and hundreds of terminals across North America is a huge responsibility. Throughout our organization, from the top down, we are committed to maintaining and operating our assets safely and in an environmentally responsible manner. To protect the public, our employees and the environment, we invest hundreds of millions of dollars each year on integrity management, maintenance and environmental programs to meet these goals. We utilize state-of-the-art technology for pipeline and storage well integrity and maintenance. We also employ personnel who constantly monitor pipeline and storage facility operating conditions using computer systems located in control centers. We conduct internal pipeline inspections at prescribed intervals by sending sophisticated computerized equipment called “smart pigs” through most of our pipelines. We use our patented pipeline inspection protocol, the Kinder Morgan Assessment Protocol (KMAP) system, to interpret the data gathered by smart pigs. Additionally, we use cathodic protection, a technology designed to protect pipelines and storage wells from external corrosion through the use of an electrostatic current. At each of our natural gas storage facilities, Kinder Morgan maintains risk management programs and monitoring systems for well and reservoir integrity and deliverability. In 2016, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued rules to establish federal standards for underground natural gas storage facilities. These rules respond to Section 12 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016, which was enacted following the serious natural gas leak at Southern California Gas Company’s Aliso Canyon facility in California in 2015. In 2017 PHMSA and additional subject matter experts conducted facility safety site assessments at a cross-section of natural gas storage operators. We volunteered a facility to participate as the first of the site assessments, and PHMSA assessed our facility with positive results. In addition to our corporate and business segment Environmental, Health and Safety (EHS) leadership teams and departments, our Board of Directors has a standing EHS Committee, whose charter is available on our website at www.kindermorgan.com in the “Corporate Governance” sub-section of the “Media & Investor Relations” page. This committee assists our Board in overseeing management’s establishment and administration of our EHS policies, programs, procedures and initiatives, including those that promote the safety and health of our employees, contractors, customers, the public and the environment. The committee also periodically reviews with management our company’s reputation as a responsible corporate citizen and our efforts to employ sustainable business practices consistent with our company’s business purpose and values. In 2015 and again in 2016, the U.S. Environmental Protection Agency finalized rules to regulate methane emissions from the production, gathering and processing, and transmission and storage sectors of the oil and natural gas industry. We strongly supported the implementation of voluntary methane emission reductions in the final regulatory regime. Currently, we are participating in several industry initiatives to reduce methane emissions. Below are a few examples of how we have been actively engaged with various trade organizations and regulatory entities to share our data and experience with methane monitoring and management, and provide perspective on how methane emission reductions can best be achieved. Page 1 of 11
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METHANE REDUCTION COMMITMENT
At Kinder Morgan, we recognize that operating thousands of miles of pipelines, 20 natural gas storage facilities and hundreds of terminals across North America is a huge responsibility. Throughout our organization, from the top down, we are committed to maintaining and operating our assets safely and in an environmentally responsible manner. To protect the public, our employees and the environment, we invest hundreds of millions of dollars each year on integrity management, maintenance and environmental programs to meet these goals.
We utilize state-of-the-art technology for pipeline and storage well integrity and maintenance. We also employ personnel who constantly monitor pipeline and storage facility operating conditions using computer systems located in control centers. We conduct internal pipeline inspections at prescribed intervals by sending sophisticated computerized equipment called “smart pigs” through most of our pipelines. We use our patented pipeline inspection protocol, the Kinder Morgan Assessment Protocol (KMAP) system, to interpret the data gathered by smart pigs. Additionally, we use cathodic protection, a technology designed to protect pipelines and storage wells from external corrosion through the use of an electrostatic current.
At each of our natural gas storage facilities, Kinder Morgan maintains risk management programs and monitoring systems for well and reservoir integrity and deliverability. In 2016, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued rules to establish federal standards for underground natural gas storage facilities. These rules respond to Section 12 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016, which was enacted following the serious natural gas leak at Southern California Gas Company’s Aliso Canyon facility in California in 2015. In 2017 PHMSA and additional subject matter experts conducted facility safety site assessments at a cross-section of natural gas storage operators. We volunteered a facility to participate as the first of the site assessments, and PHMSA assessed our facility with positive results.
In addition to our corporate and business segment Environmental, Health and Safety (EHS) leadership teams and departments, our Board of Directors has a standing EHS Committee, whose charter is available on our website at www.kindermorgan.com in the “Corporate Governance” sub-section of the “Media & Investor Relations” page. This committee assists our Board in overseeing management’s establishment and administration of our EHS policies, programs, procedures and initiatives, including those that promote the safety and health of our employees, contractors, customers, the public and the environment. The committee also periodically reviews with management our company’s reputation as a responsible corporate citizen and our efforts to employ sustainable business practices consistent with our company’s business purpose and values.
In 2015 and again in 2016, the U.S. Environmental Protection Agency finalized rules to regulate methane emissions from the production, gathering and processing, and transmission and storage sectors of the oil and natural gas industry. We strongly supported the implementation of voluntary methane emission reductions in the final regulatory regime. Currently, we are participating in several industry initiatives to reduce methane emissions.
Below are a few examples of how we have been actively engaged with various trade organizations and regulatory entities to share our data and experience with methane monitoring and management, and provide perspective on how methane emission reductions can best be achieved.
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Over 20 years of voluntary participation in the U.S. Environmental Protection Agency (EPA) Natural Gas STAR program Through voluntary efforts such as EPA’s Natural Gas STAR program, Kinder Morgan has reduced methane emissions by over 94 billion cubic feet since 1993. The reductions contributed to reducing U.S. methane emissions by 15% from 1990 to 2016 while natural gas production has increased 49% over the same period. EPA’s Natural Gas STAR Summary Report for Kinder Morgan’s reported activities from 1993 through 2016 is included in Appendix A.
We are committed to implementing and reporting voluntary methane emission reductions as part of EPA’s Natural Gas STAR Methane Challenge Program, and the Our Nation’s Energy Future (ONE Future) Coalition described below.
Leadership Role in the Interstate Natural Gas Association of America (INGAA) Greenhouse Gas (GHG) Task Force We participate in, and chaired from late 2008 to 2011 and again from 2013 to early 2017, the INGAA GHG Task Force. As part of that leadership role we, along with INGAA, participated in the Quadrennial Energy Review by the U.S. Department of Energy (DOE), which included a joint effort by the industry, the Administration and other stakeholders to understand better the issues confronting the transportation sector and develop mutually beneficial solutions.
Leadership role in collaborating with the EPA and DOE methane emissions reductions We have taken a leadership role in meeting with the EPA to identify the most effective means for reducing methane emissions from natural gas transmission and storage operations. In addition to our ONE Future Emissions Intensity commitment described below, we meet with the EPA routinely to share data and engage in discussions about numerous potential emissions management strategies.
Steve Kean, our President and Chief Executive Officer, has participated in the DOE’s roundtable discussions with government, industry, non-profit, union and environmental leaders to help identify opportunities, share technical solutions and coordinate best practices to reduce methane emissions.
During 2016, we were an industry leader participating in the Joint Industry Task Force on the regulation of natural gas storage facilities. Our employees contributed to industry technical papers presented in joint hearings of the DOE and PHMSA as well as collaborative meetings with various non-governmental organizations developing an understanding of storage facilities, operations, and emissions and safety technologies. This work is ongoing in numerous federal, state and industry venues.
We have also worked closely with the DOE, academic institutions, environmental groups, and consultants on several independent technology evaluations and scientific studies as described further in the sections below.
Founding member of ONE Future We are a founding member of ONE Future, a unique coalition made up of members across the natural gas industry, focused on identifying policy and technical solutions that result in improvements in the management of emissions associated with the production, gathering, processing, transmission, storage, and distribution of natural gas. Members of ONE Future are committed to continuously improving their emissions management to achieve voluntary reductions in emissions and to provide efficient, increased use of natural gas. ONE Future’s goal is to enhance the energy delivery efficiency of natural gas by limiting energy waste and achieving a total methane emission rate of one percent or less of gross natural gas production across the natural gas value chain, the point at which the use of natural gas for any purpose
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provides obvious and immediate greenhouse gas reduction benefits. The ONE Future coalition represents the entire natural gas value chain, with members from some of the largest natural gas production, gathering, processing, transmission, storage, and distribution companies in the United States.
The ONE Future Emissions Intensity Commitment Option has been accepted as part of the Natural Gas Star Methane Challenge Program. The option provides companies a flexible way to reduce methane emissions from their operations. The ONE Future Commitment is intended to drive action to achieve segment-specific intensity targets, established through the ONE Future Coalition. ONE Future’s overall goal is to achieve a methane “leakage rate,” defined as emissions per volume produced or volume of throughput, of 1 percent or less along the natural gas value chain by 2025. We are committed to implementing the ONE Future Emissions Intensity Commitment Option program for the Kinder Morgan transmission and storage sector as part of the Natural Gas STAR Methane Challenge program. The implementation plan submitted to EPA is included in Appendix B. Kinder Morgan’s transmission and storage sector ONE Future emissions intensity target commitment is 0.31% by 2025. The first ONE future status report is scheduled to be issued before the end of 2018 and to include 2017 actual methane emissions intensity compared to the target.
Kinder Morgan’s ONE Future commitment includes expanded leak survey and maintenance at our transmission and storage compressor stations. For calendar year 2017, we performed annual leak surveys using an Optical Gas Imaging (OGI) camera and reported greenhouse gas (GHG) emissions at 47% of our stations under the EPA’s Greenhouse Gas Reporting Program (GHGRP). In 2017, we extended annual leak surveys to include an additional 20% of those stations not already surveyed annually under the EPA’s GHGRP. We have committed to continuing to expand the leak survey and maintenance program by an additional 20% of our stations each year so that by 2021 100% of our transmission and storage stations are scheduled to have annual leak surveys. Leaks which can be quickly addressed are addressed at the time of the survey and confirmed to be fixed. Leaks above 1 ft3/min that cannot be addressed when found are placed on a list to be addressed during the next planned maintenance shutdown.
Participation in DOE’s Advanced Research Projects Agency-Energy (ARPA-E) Project We are a member of the Industry Advisory Board (IAB) advising ARPA-E and Colorado State University on the development of a methane emission test site to represent actual natural gas leaks that might occur at production, gathering, and underground pipelines facilities. This project is part of the ARPA-E Methane Observation Networks with Innovative Technology to Obtain Reductions (MONITOR) program. The MONITOR program’s goal is to develop innovative and cost-effective methane leak detection technologies to more precisely and efficiently locate and measure methane emissions associated with natural gas operations. The next generation leak detection technologies should drive enhanced leak detection and repairs to further reduce methane emissions.
Kinder Morgan is actively engaged in the development of the test site, evaluation of the various leak detection technologies being developed, and providing guidance to the developers on industry expectations and steps for regulatory approval of their technologies.
Collaboration with DOE on Methane Emissions from Gathering Compressor Stations and Underground Natural Gas Storage Facilities We are participating in two DOE-funded studies to develop improved national methane emission estimates and methane emission factors for natural gas gathering compressor stations. The current methane emission factors used for gathering compressor stations are more than twenty years old and based on a limited dataset. The studies are intended to establish improved methane emission factors more representative of the current state of gathering compressor station operations. Kinder Morgan participates
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on the Steering Committee and Technical Review Committee of each study. We also allowed the academic institutions and consultants to perform testing at more than thirty Kinder Morgan natural gas gathering compressor stations.
A third DOE-funded study involves estimation of methane emissions from underground natural gas storage field operations. Kinder Morgan is working with the consultant leading this study and allowing testing at some of our natural gas storage fields.
Collaboration with DOE’s National Energy Technology Laboratory (NETL) We are participating in a methane emissions life cycle analysis (LCA) being performed by NETL with input from ONE Future members representing all sectors of the natural gas industry value chain. This analysis is intended to inform ONE Future members and others interested in the overall methane LCA emissions. The study will also evaluate specific emission reduction opportunities in each sector and the impact on overall methane life cycle emissions.
Collaboration with the Environmental Defense Fund (EDF) on GHG emissions We are one of seven natural gas transmission companies that worked with the EDF to develop a comprehensive GHG emissions inventory for the natural gas transmission and storage sector.
Importantly, the results of the EDF study demonstrated that due to actions taken in the gas transportation sector over the years to address methane emissions, the EPA has been overstating emissions from natural gas transmission and storage facilities. Since the release of this study, the EPA has used the results to improve their GHG emission estimates for natural gas transmission and storage facilities in their National GHG Emission Inventory report.
Strict adherence to existing reporting and compliance regulation Certain of our facilities are subject to the EPA’s GHG Reporting Program (GHGRP) and federal and state leak detection and repair regulations. Leak surveys required by regulatory or voluntary programs are conducted by trained Kinder Morgan or third party technicians. We have extensive emissions monitoring equipment and measurement programs. We report emissions to the EPA and fourteen state or local agencies on an annual basis in accordance with their reporting requirements.
EPA’s GHGRP requires annual leak detection survey’s at subject facilities. EPA’s new source performance standards for natural gas processing plants and oil and gas production, transmission and distribution facilities, and several state specific regulations also require leak detection and repair (LDAR) inspections to identity and fix equipment leaks. For facilities subject to these LDAR inspections, monitoring frequency and methods vary depending on facility type. Frequencies range from monthly, to quarterly or annual surveys. These LDAR inspections are conducted using OGI technology or flame ionizing detectors to identify gas leaks. Once leaks are identified they are repaired and then resurveyed to document the repair addressed the leak.
Detailed information about our environmental, health and safety initiatives and performance, as well as our efforts to maintain pipeline integrity including through the use of our KMAP system, can be found on our website, http://www.kindermorgan.com/pages/responsibility. We publish our environmental, health and safety performance because we are committed to working openly and transparently with our stakeholders.
Updated May 30, 2018
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Appendix A
EPA Natural Gas STAR Summary Report
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3/22/2018 Natural Gas STAR Summary Report
Natural Gas STAR Summary Report (Filtered)Partner(s)
Colorado Interstate Gas Company, El Paso Natural Gas Company, Kinder Morgan, Natural Gas Pipeline Company ofAmerica, Southern Natural Gas Company, Tennessee Gas Pipeline Company
Segment(s) Distribution, Transmission
Year(s) 2016, 2015, 2014, 2013, 2012, 2011, 2010, 2009, 2008, 2007, 2006, 2005, 2004, 2003, 2002, 2001, 2000, 1999, 1998,
1997, 1996, 1995, 1994, 1993, 1992, 1991, 1990
This report summarizes the voluntary methane emissions reductions achieved under the EPA Natural Gas STARProgram.
2016, 2015, 2014, 2013, 2012, 2011, 2010, 2009, 2008, 2007, 2006, 2005, 2004, 2003, 2002, 2001,2000, 1999, 1998, 1997, 1996, 1995, 1994, 1993, 1992, 1991, 1990
Cumulative
New: 57,825,236 Mcf Ongoing: 36,545,210 Mcf
94,370,446Mcf
Mcf
Annual Reductions
New
Ongoing
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
0
2M
4M
6M
8M
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3/22/2018 Natural Gas STAR Summary Report
Methane Emission Reduction Equivalencies as of December 2017 See EPA's Greenhouse Gas Equivalencies Calculator for additional equivalencies and details about the
conversion units.
Cumulative (94,370,446 Mcf)
Tonnes CO2 equivalent 45,297,633 MTCO2e
CO2 emissions from the energy used by this many homes in one year 4,891,753 homes
Carbon sequestered from this many acres of U.S. forests in one year 53,291,332 acres
Value of methane saved (at $3 per Mcf) $283,111,338
* This total includes the identification and rehabilitation of leaky distribution pipe.
Cumulative Reductions: 94,370,446 Mcf
Use pipeline pump-downtechniques to lower gas linepressure: 34.6%
Use pipeline pump-downtechniques to lower gas linepressure: 34.6%
Install vapor recovery units onpipeline liquid/condensate tanks:26.8%
Install vapor recovery units onpipeline liquid/condensate tanks:26.8%
Use of turbines at compressorstations: 9.5%Use of turbines at compressorstations: 9.5%
Directed inspection andmaintenance at compressorstations: 9.4%
Directed inspection andmaintenance at compressorstations: 9.4%
Use composite wrap repair: 7.3%Use composite wrap repair: 7.3%
Other: 12.3%Other: 12.3%
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3/22/2018 Natural Gas STAR Summary Report
Tota
l Ann
ual R
educ
tions
(Mcf
)Top Technologies and Practices
Use pipeline pump-down techniques to lower gas line pressureInstall vapor recovery units on pipeline liquid/condensate tanksUse of turbines at compressor stationsDirected inspection and maintenance at compressor stationsUse composite wrap repairOther (includes all other technologies and practices)
1990 1995 2000 2005 2010 20150
1M
2M
3M
4M
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Appendix B
One Future Coalition Implementation Plan for Natural Gas STAR Methane Challenge Program
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Emission Source Category Start Date
Annual Reporting
Deadline to Methane
Challenge Progress Report
Target Commitment
Achievement Year
Equipment Leaks/Fugitive
Emissions 1/1/2017 30-Jun Annual CY 2025
Pipeline Segment Blowdowns 1/1/2017 30-Jun Annual CY 2025
Other Reduction Technologies
& Work Practices 1/1/2017 30-Jun Annual CY 2025
Prod G&B Proc T&S Trans PL Company LNG
Stor
LNG
I/E
Distr
Kinder Morgan, Inc. yes El Paso Natural Gas Company, L.L.C. 2017
Kinder Morgan, Inc. yes Tennessee Gas Pipeline Company, L.L.C. 2017
Kinder Morgan, Inc. yes Southern Natural Gas Company, L.L.C. 2017
Kinder Morgan, Inc. yes Natural Gas Pipeline Company of America LLC 2017
Kinder Morgan, Inc. yes Colorado Interstate Gas Company, L.L.C. 2017
Kinder Morgan, Inc. yes Cheyenne Plains Gas Pipeline Company, L.L.C. 2017
Kinder Morgan, Inc. yes Ruby Pipeline, L.L.C. 2017
Kinder Morgan, Inc. yes Mojave Pipeline Company, L.L.C. 2017
Kinder Morgan, Inc. yes TransColorado Gas Transmission Company LLC 2017
Kinder Morgan, Inc. yes Midcontinent Express Pipeline, LLC 2017
Kinder Morgan, Inc. yes Wyoming Interstate Company, L.L.C. 2017
Kinder Morgan, Inc. yes Kinder Morgan Louisiana Pipeline LLC 2017
Kinder Morgan, Inc. yes Kinder Morgan Tejas Pipeline LLC 2017
Kinder Morgan, Inc. yes Kinder Morgan Texas Pipeline LLC 2017
Kinder Morgan, Inc. yes Sierrita Gas Pipeline LLC 2017
Participating Company Operation/Assets
Name or ID
Segment*
Calendar Year(s) of
Implementation**
Comments
V. EPA Natural Gas STAR Program Historical Participation and Methane Emission Reductions
Kinder Morgan’s natural gas transmission pipelines have participated in EPA’s Natural Gas STAR Program since 1993. Since 1993, Kinder Morgan’s natural gas transmission pipelines have achieved greater than 85.9 billion cubic feet of natural gas (primarily methane) emissions reductions. These reductions have been achieved through implementation of directed inspection and maintenance programs at
compressor stations and other surface facilities, using existing or temporary compression to reduce pipeline segment blowdowns, replacing reciprocating compressor rod packings, replacing high-bleed pneumatic devices, installing vapor recovery systems on liquid storage tanks, installation of gas turbine and electric motor driven compression, and implementation of other methane reduction technologies
or work practices.
Additional Information/Context (optional)
[Provide other information about historical actions in advance of joining Methane Challenge, or other information on how the Program will be implemented.]
Kinder Morgan will implement the following management practices across its Transmission and Storage operations to achieve the target emissions intensity commitment.
A. Leak Inspection and Maintenance at Compressor Stations
Kinder Morgan will implement leak inspections at its Transmission and Storage compressor stations over a five-year period commencing in 2017. The leak inspections will include compressor stations subject to U.S. Environmental Protection Agency’s greenhouse gas reporting program (GHGRP, 40 CFR Part 98). An incremental 20% of facilities not subject to the GHGRP or other regulatory programs will be
added annually over five years, 2017-2021. As of 2021, all Transmission and Storage compressor stations will be inspected annually. The leak inspections will be conducted using optical gas imaging cameras, or other EPA approved technologies. The methane emission surveys will be conducted with the components operating in the as found condition.
Leaks identified during the inspections will be evaluated and repaired as appropriate. If the repair or replacement is technically infeasible, would require a vent blowdown, a compressor station shutdown, a well shutdown or well shut-in, or would be unsafe to repair during operation of the unit, the repair or replacement will be completed during the next scheduled compressor station shutdown for
maintenance, well shutdown, well shut-in. Delay of repair will be allowed beyond the next scheduled compressor station shutdown for maintenance if (a) replacement parts cannot be acquired before the next scheduled shutdown for maintenance or (b) the delay is attributable to other good cause. The repair or replacement will be performed when parts and crews are available during a scheduled
maintenance shutdown, but no longer than 2 years from discovery unless the shutdown will cause a greater release of natural gas than would be reduced by the repairs.
B. Transmission Pipeline Segment Blowdowns Between Compressor Stations
Kinder Morgan will use maintenance methods not requiring pipeline blowdowns to the degree possible required to maintain pipeline integrity. When blowdowns are required, Kinder Morgan will follow a process to minimize blowdown emissions. As time and conditions permit, existing KM compression, customer delivers and/or temporary compression will be used to reduce pipeline pressures prior to
conducting blowdowns. Pipeline segment blowdowns will be reduced to the extent feasible while maintaining pipeline safety and minimizing adverse customer impacts.
C. Other Methane Emission Reduction Technologies and Work Practices
Kinder Morgan will evaluate and implement other methane emission reduction technologies or work practices on a case-by-case basis. Other specific technologies or work practices that are implemented will be reported to ONE Future and EPA in the annual reports.
Plans (if any) for actions to be evaluated and implemented
[For example, further expansion of Methane Challenge commitments]
Kinder Morgan Inc. (hereinafter referred to as Kinder Morgan) is a charter member of Our Nation’s Energy Future (ONE Future) coalition. ONE Future is focused on demonstrating an innovative, performance-based approach to the management of methane emissions directed toward a concrete goal: to achieve an average rate of methane emissions across the entire natural gas value chain that is one
percent or less of total natural gas gross production. The ONE Future Commitment entails a Partner commitment to segment-specific intensity targets which represent emissions per volume produced or volume of throughput and add up to a 1% or less “leakage rate” along the value chain by 2025. Kinder Morgan’s ONE Future emissions intensity commitment is:
ONE Future Emissions Intensity Commitment Segment: Transmission and Storage
Intensity Target: 0.31% Target Year: 2025
The CY2025 annual report would be submitted by June 30, 2026. The annual progress report will be provided to ONE Future by each participating company and ONE Future will provide a industry-wide progress report summary to EPA's Methane Challenge group.
Methane Challenge commitments and projected timeframe for meeting commitments (as specified in the Partnership Agreement)
[Provide information on steps for achieving commitments such as anticipated rate of progress, key milestones, or other context.]
ONE Future Coalition Implementation Plan for Natural Gas STAR Methane Challenge Program
Comments
The CY2025 annual report would be submitted by June 30, 2026. The annual progress report will be provided to ONE Future by each participating company and ONE Future will provide a industry-wide progress report summary to EPA's Methane Challenge group.
The CY2025 annual report would be submitted by June 30, 2026. The annual progress report will be provided to ONE Future by each participating company and ONE Future will provide a industry-wide progress report summary to EPA's Methane Challenge group.
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Kinder Morgan, Inc. yes Kinder Morgan North Texas Pipeline LLC 2017
Kinder Morgan, Inc. yes Elba Express Company, L.L.C. 2017
Kinder Morgan, Inc. yes Horizon Pipeline Company, L.L.C. 2017
Kinder Morgan, Inc. yes Kinder Morgan Illinois Pipeline LLC 2017
Kinder Morgan, Inc. yes Kinder Morgan Border Pipeline LLC 2017
Kinder Morgan, Inc. yes Bear Creek Storage Company, L.L.C. 2017
Kinder Morgan, Inc. yes Young Gas Storage Company, Ltd. 2017
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