Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions Subpart W

Meeting Documentation: Canadian Energy Partnership for Environmental Innovation (CEPEI) 4/22/10

Date Staff Contact 

Information (Name, 

email, phone #)

Name of 

Organization 

(Attach list of all 

attendees names 

and emails if 

possible) 

Summary of Discussion (e.g., applicability, 

reporting requirements, etc.)

Written 

Comments 

Provided?

Did they

also submit 

to Docket?

Date sent to

EPA- CCD

4/22/10

Roger Fernandez

Akachi Imegwu

Sandy Seastream, ICF

Peter Mussio 

Union Gas Limited

Christine Cinnamon 

TransCanada 

PipeLines

Alain Leroux 

Gaz Metro Limited

Glenn England

ENVIRON 

International 

Corporation

Liz Siarkowski

TransCanada 

PipeLines

Lynn Ross

Lynn Ross 

Consulting

Wayne Alexander

ATCO Gas

Ronnie Deol

Terasen Gas

Jennifer Robertson

Terasen Gas

See following pages No written 

comments 

were submitted 

prior to the 

meeting. 
Darren Ribar 

AltaGas Utilities

Artur Janz

ATCO Pipelines

Curtis Clark

ATCO Pipelines

Jasmine Urisk

CEPEI

Marline Smith

TransCanada 

Pipelines

Brian Sloof

TransCanada 

PipeLines

Tom McGrath 

Innovative 

Environmental 

Solutions
CEPEI / EPA Meeting

USEPA OAR Offices, 1310 L Street, Washington DC

Via Teleconference

April 22, 2010 2:30 pm EDT

List of Issues Discussed

1. EPA explains that transmission compressor stations are in the rule, but not transmission pipelines.

2. EPA should define large compressors in transmission.

3. EPA should define for transmission compressors, the duration a compressors is required to be in a mode to 

necessitate emission measurements.

4. EPA should clarify if in distribution residential meters are reportable.

5. EPA explains that LDC’s are required to report under both subpart W and subpart C.

6. EPA should clarify for distribution if gate stations are reportable.

7. EPA should provide an applicability tool for both transmission and LDC reporters.

8. EPA’s cost for subpart W is too low.

April 16, 2010

Prepared fori: CEPEI April 2010 meeting discussion of EPA draft reporting rule

Sub Part W Questions 

Transmission 

 Can we confirm our understanding that the only transmission facilities included under the GHG MRR are compressor stations and that 

the 25 kt CO2e reporting threshold applies to the sum of stationary combustion + vented+fugitive +flared emissions?

 Preamble p. 60 refers to the need for direct 

measurement on “large reciprocating compressor units”, yet the rule only appears to refer to “compressors”. Is there a definition of 

“large” in the rule somewhere so that smaller compressor units need not be measured?
 I’ll defer to someone with on site 

measurement experience, but it seems to me that the requirement to perform yearly measurements while units are (a) pressurized and 

running, (b) pressurized and not running, and (c)depressurized will in itself create incremental GHG emissions as well as some 

operational /logistical challenges. I think we could anticipate the need for multiple site visits to take measurements to meet this 

requirement. Has EPA considered how this requirement can be implemented in practice?

Distribution

 The rule and preamble have varying 

references to “M&R stations”, “regulators”, “metering”, “meter regulators”, etc., but I can’t seem to locate how/if these are defined. 

For example, residential meter sets have regulators and perform metering, but a requirement to perform the “leak detection and leaker 

emission factor” calculation method on an annual basis on all residential meter stations would be very costly. Can we assume that EPA 

did not intend the rule to capture the smaller above ground stations in this requirement? My suggestion would be to revise the rule to 

just require leak detection at gate stations and move the balance of the stations to the “equipment count and population emission 

factor” category. And even in regard to gate station leak detection, I think there might reasonable grounds to extend the survey 

frequency to more than annually. 

 I could not find any mention in the preamble 

as to how EPA intends to review and amend the rule’s requirements in future - for example, the possible adjustment of the required 

monitoring frequency in light of reported leak data, or updating leaker and population emission factors in light of new research.

 Can we confirm our understanding that 

LDC’s are required to report under both SubPart W and SubPart C (general stationary combustion)? This appears to be the case yet the 

preamble (pp 93-94) notes “For other facilities (e.g., LDCs), the only emissions of GHGs are process emissions”.

 Table W-7 in the reporting rule (p. 213):

o Are the leaker emission factors for “above 

grade M&R stations” supposed to apply to gate stations? What, if any, other above ground stations are they to be applied to?

o The population emission factor for 

distribution mains is missing an appropriate multiplier. I’m guessing it should be “scf/h-mile” but can this be confirmed?
o Have the buried pipe factors (particularly the 

cast iron factor) been adjusted for soil oxidation of CH4?

General

 For both transmission compressor and LDC 

reporters, there is still an onus on facilities that are under the threshold to determine that they do not report. This exercise can be 

almost as costly and onerous as complying with the rules where you do trigger the reporting threshold. Particularly in the case of LDC’s 

where only about 10% of LDC’s will trigger reporting (calculated based on Preamble p. 52 data), in the interests of cost containment and 

efficiency, will EPA provide additional guidance to exempt LDC’s below some “easy to check” threshold?

 In my opinion the costs per tonne to 

implement this rule are underestimated. For example, for LDC’s the estimate is $0.07/tonne for the first year dropping to $0.04/tonne 

in subsequent years (Preamble, p.89). If we take a Canadian company example, one LDC operation has “distribution” emissions of about 

70 kt CO2e, so presumably $4900 to cover annual inventory costs (using $0.07/tonne). This LDC company has about 200 gate stations, 

so allocating the full costs to gate station measurement alone works out to about $25 per location, and this is just one recurring cost 

item. Will EPA consider extending the leak detection frequency to help manage monitoring costs?

 

i

Prepared by Lynn Ross, lynnross@telus.net, 250-338-4117*