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 state 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 required 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 requested, 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 response to your questions, I can answer the 

following at this time: 

1) Section 98.232(i)(1) states that emissions would be reported under the natural gas 

distribution industry segment. Specifically, the proposed rule covers all above 

ground meter regulators and gate station fugitive emission from connectors, block 

valves, control valves, pressure relief valves, orifice meters, other meters, 

regulators, and open ended lines. 

 Stated differently, emissions from connectors, 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 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. 

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, obligations, responsibilities, expectations, or benefits in 

regard to any person. Facility owners or operators and suppliers are responsible for determining 

how they would be affected by the requirements of the rule.