## Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions Subpart W

Meeting Documentation : Canadian Energy Partnership for Environmental Innovation ( CEPEI ) 4/2 2 /10 Date Staff Contact In formation (Name, email, phone #) Name of Organization (Attach l ist 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

4/2 2/10 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 A lexander AT CO Gas Ronnie Deol Terasen Gas Jennifer Robertson Terasen Gas See following pages No w ritten comments were submitted prior to the meeting.Darren Ribar AltaGas Utilities Artur Janz AT CO Pipelines Curtis Clark AT CO 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 2 2 , 20 10 2 : 30 pm EDT L ist 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 i s required to be in a mode to necessitate emission measurements. 4. EPA should clarify if in distribution residential meter s are reportable. 5. EPA explains that LDC’s are required to report under both s ubp art W and s ub p art C

. 6. EPA should clarify for distributio n 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 for i 

## : 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+fugit ive +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 defin ition of “large” in the rule somewhere so that smaller compres sor 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) pressuri zed and running, (b) pressurized and not running, and (c)depres surized 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 me et this requirement. Has EPA considered how this requiremen t 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 ha ve 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 assum e 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 emis sion factor” catego ry. 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 require ments 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 rese arch.

 Can we confirm our understanding that LDC’s are requ ired 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 repo rting 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 a n 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 reporter s, 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 c as e 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 con tainment 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 sta tions, 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
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