From: Roger Fernandez/DC/USEPA/US

To: placey@aga.org

Date: 06/10/2010 10:59 AM Subject: Follow up to June 3 Email

Pam,

I am writing in regard to the email that I sent to you (see below) on June 3 and our discussions in early May at your office. Does AGA have a response in regard to the following questions that I sent?

I have a request as well. Per our meeting at AGA, you and your members stated that there are extensive existing federal and state regulations that require leak detection and record keeping. Could you provide link to state regulation that mandates leak detection at, for example gate stations and other sources that are covered in the proposed rule? Leak detection and emissions tracking for the Mandatory Reporting Rule is very different from leak detection that prescribes such techniques as ambient gas concentration detection using for example a lower explosive limit (LEL) detector.

We are interested in existing regulations that require actual leak detection on components and ideally a requirement of a record of leaks found. The rules that we have found to date, both federal and state, only concern general safety and cover, for example, the ambient gas concentration in an area without identifying any specific components that may be leaking.

Per our meeting at AGA in early May, the presentation that you gave on May 13 in New Orleans, LA (http://www.aga.org/NR/rdonlyres/928947BE-2282-4063-A440- 2BC306643AF1/0/1005LACEY_GHG.pdf) see page 11, AGA members and you stated that there are extensive existing federal and st ate regulations that require leak detection and record keeping. As noted above and at our meeting at your offices, EPA has requested further information in regard to said Federal and state regulations that mandate fugitive leak detection at, for example gate stations and other sources that are covered in the proposed rule. As of today, we have not heard from AGA. EPA has also put forward substantial effort to find said regulations on our own as well and we have not

been able to locate them.

As I noted in my June 3 email, fugitive leak detection and emissions tracking for the Mandatory Reporting Rule is very different from leak detection that prescribes such techniques as ambient gas concentration detection using for example a lower explosive limit (LEL) detector. As EPA has stated, we are interested in and very willing to review and consider existing regulations that require fugitive leak detection on components and ideally a requirement of a record of all such leaks found. The rules that we have found to date, both federal and state, concern safety and cover, for example, only the ambient gas concentration in an area.

It is our goal to both collect data as is r equired by the Mandatory Reporting Rule but on the other hand, keep the burden to the minimum extent possible while maintaining basic data quality. We look forward to reviewing the various rules to which you and AGA have previously referred. As we've reques ted, any help you can render in regard to locating them is much appreciated.Also, I have not heard from you in regard to a contact at DOT with whom I can discuss existing regulations. I have reached out to several people at DOT but to no avail. Your help in this regard is much appreciated as well.

I look forward to hearing from you.

Roger

Roger Fernandez U.S. Natural Gas STAR Program Methane to Markets Partnership

Phone: +1-202-343-9386

Fax: +1-202-343-2202 Website: epa.gov/gasstar

Visiting and Private Mail Carrier (DHL/FedEx etc) Address 1310 L St., NW (846) Washington, DC 20005
USA

Postal Address 1200 Pennsylvania Ave., NW (6207J) Washington DC 20460
USA ----- Forwarded by Roger Fernandez/DC/USEPA/US on 06/09/2010 04:24 PM -----

From: Roger Fernandez/DC/USEPA/US

To: placey@aga.org

Date: 06/03/2010 03:19 PM Subject: Responses to Questions and a Request



### Pam,

I hope this email finds you well. In re sponse to your questions, I can answer the following at this time:

1) Section 98.232(i)(1) states that emissi ons would be reported under the natural gas distribution industry segment. Specifically, the proposed rule covers all above ground meter regulators and gate station f ugitive emission from connectors, block valves, control valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines.

Stated differently, emissions from c onnectors, block valves, control valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines at above ground meter regulators and gate stations are covered in this proposed rule.

### 2) Open ended lines are defined in on page 56389 of Subpart A of the Mandatory Reporting Rule published in September 2009. Connectors are defined on page

56385.

I have a request as well. Per our meeti ng at AGA, you and your members stated that there are extensive existing federal and state regulations that require leak detection and record keeping. Could you provide link to st ate regulation that ma ndates leak detection at, for example gate stations and other source s that are covered in the proposed rule? Leak detection and emissions tracking for the Mandatory Reporting Rule is very different from leak detection that prescribes such techniques as ambient gas concentration detection using for example a lower explosive limit (LEL) detector.

We are interested in existing regulations that require actual leak detection on components and ideally a requirement of a record of l eaks found. The rules that we have found to date, both federal and state, only concern ge neral safety and cover, for example, the ambient gas concentration in an area without id entifying any specific components that may be leaking.

I look forward to hearing from you.

With best regards, Roger

Roger Fernandez U.S. Natural Gas STAR Program Methane to Markets Partnership

Phone: +1-202-343-9386

Fax: +1-202-343-2202 Website: epa.gov/gasstar

Visiting and Private Mail Carrier (DHL/FedEx etc) Address 1310 L St., NW (846) Washington, DC 20005
USA

Postal Address 1200 Pennsylvania Ave., NW (6207J) Washington DC 20460
USA

Any communication on the mandatory GHG reporting rule is intended to provide general and
administrative information about the Rule. This communication does not provide legal advice, and responses to questions received do not have legally binding effect or expressly or implicitly create, expand, or limit any legal rights, obligatio ns, responsibilities, expectations, or benefits in regard to any person. Facility owners or operat ors and suppliers are responsible for determining how they would be affected by the requirements of the rule.