Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions Subpart W 

Meeting Documentation: American Gas Association (AGA) 5/6/10 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 CommeProvideDid they also subto Dock

5/6/10 

Roger Fernandez Akachi Imegwu Kate Cardamone Sandy Seastream, ICF 

Gregory Jones AGL Resources Danny Smith Alabama Gas Corporation Iqbal Javed Alliant Energy Corporation Dick Coty Ameren Gene Eagle Ameren Bill Burnett Ameren Pam Lacey American Gas Association Victoria Plotkin American Gas Association Stuart Schulz Atmos Energy Rob Bennett 

See following pages No writte

commentwere submprior to thmeeting, below 
Atmos Energy 

Robert Giese Baltimore Gas & Electric Joe Jenkins Black Hills Corp. Glenn Miller CenterPoint Energy Dave Westman Con Edison Amy Kapuga Consumers Energy Lisa Moerner Dominion Amanda Tornabene Dominion David Jacobson DTE Energy Gregory Ryan DTE Energy Darrell Grassmyer DTE Energy Leon T Hinson Entergy New Orleans, Inc Keith Faretra Faretra Kristine Cruz Gas Technology 
Institute 

Jim McCarthy IES Inc Juan Santiago Integrys Lisa Schmidt Integrys Energy Group Roger McCambridge Integrys Energy Group Rick Kottemann Laclede Gas Company Steve Donatiello Laclede Gas Company Michael Ricciardi Madison Gas and Electric Co. Lindsay Lyle Minnesota Energy Resources Alan Hobbs Mobile Gas Service Abbie Krebsbach Montana-Dakota Utilities Co. Charles Burke National Fuel 
Robert Leone 

National Fuel Kenneth Gossel National Fuel Gas Distribution Corporation Sandy Taft National Grid Curtis Winner New Mexico Gas Company Marcelle Fiedler New Mexico Gas Company Somali Tomczak Nicor Gas Ghani Baig NiSource Tracy Gionfriddo Northeast Utilities Jeff Payson NW Natural Loretta Earnest ONEOK, Inc. Linus Farias Pacific Gas & Electric Mike Jones Philadelphia Gas Works 
Michael DePalma 

Piedmont Natural Gas Elisabeth Barr Semco Energy Gas Company John Fooks Sempra Energy Utilities Darrell Johnson Sempra Energy Utilities Hayden Truscott SourceGas Charles Wait Southern Union Bill Schrand Southwest Gas Brianne MetzgerDoran Spectra Energy Terri Shires URS Corporation Matthew Harrison URS Corporation Elizabeth Beck Vectren Lisa Messinger Vectren David Hodges 
Vectren 

Alex Izadpanah Washington Gas Donna Danihel We Energies Paul Kharouf We Energies Michael Miller Xcel Energy Judith H Herman Xcel Energy 
AGA Meeting with EPA

Part 98 Subpart W

GHG Reporting Proposed Ru

May 6 May

6
Overview

Pam Lacey - AGA

• Build on AGA’s excellent relationship and experience g

EPA Natural Gas STAR program

• But caution – experience from individual Gas STAR pr

necessarily representative – lots of variation out there 

• Short timeline for the rule and difficulties involved i

surveying thousands of facilities with scarce optical devices will create problems for both industry and tagency:

– cannot ensure reasonable assurance of compliance – EPA will not be able to meet the criteria for “practica

enforcement” 

• We would l k l ’ l d d 

ld like to explore EPA’s real needs and see i

help suggest practical ways to achieve the agency’s 
I. Why Exclude Transmission ...

... But Not Distribution Pipes?

• Logic for Excluding Transmission Lines also Applies to 

Distribution and Storage 

– Processes and procedures in place to address leaks expe– Dispersed facilities – also true of many LDC facilities– Transmission lines are under high pressure and therefor

more obvious and would be addressed quickly. 

• L k lik l t b dd d Lea

k

s lik

ely t

o b

e

addressed more qui kl i di t ib ti ickl

y i

n di

s

t

rib

uti

– LDCs have extensive leak management programs to avo

and address leaks quickly - DOT PHMSA & PUCs regulat

require more for LDCs than for pipelines

– Odorization – The nose knows – 65 million customers – 

call right away

– LNG and underground storage – just like transmission li

under high pressure and the operator quickly becomes aa leak appears. Plus, often in odorized
II. AGA Survey Results – Victoria Plotkin 

• LDCs have, on average, roughly 19,000 M&R stations • Wide variety among companies• Confusion about the definition of M&R• Does it include industrial, commercial and/or residenti

meters?

• M&R stations per company 

– survey results vary from 

500,000 – depending on what one includes 

• LDCs operate, on average, 60 city gate stations per co• Some companies operate their own city gates

• Others say all city gate stations operated by the inters

transmission company

• Some LDCs operate over 270 city gate stations • Most keep inventories of installed components such as 

regulators and meters, but not the other components in the 

p p ro

posed rule 
III. Emission Factors

Jim McCarthy (IES)

Emission factors are outdated• Brief history of GRI emission factors • AGA’s Guidelines for carbon footprint for LDCs• Status and timeline of field testing and work to develo

updated emission factors – AGA, EPA, GTI OTD 
IV. Annual Leak Detection – Bill Schrand (S

• Proposed Annual Leak Detection at M&R Stations 

O

p pp tical Gas Scanners and Application of Emission 

for “Leakers” 

– Inaccurate, Costly, Burdensome and Duplicative 

• LDCs already conduct annual leak surveys as required 

PHMSA 

• Outline PHMSA requirements
Existing Leak Management

• Customers

– Most distribution systems are located within populated a– Odor added to natural gas is easily recognized– Customers notice gas odor and call to report - provides 

monitoring

– Lower pressures associated with most distribution pipe m

gas loss
Existing Leak Management

• Emergency Plan required by DOT

– Must be kept up to date– Report status of significant leaks to DOT required within 

leak notification 

– Most leaks repaired within 2 hours of being reported– Southwest Gas averages one hour response time
Existing Leak Management

• Leak Survey Procedures required by DOT 

– Must meet DOT and PUC requirements – Procedures and records audited annually by PUCs – Federal standards for inspection frequency– States may have more stringent requirements, based on 

of leaks found

– S i d i ll d l k Sensor equipment use

d systematically to 

detect lea

k

s

– Leaks graded according to hazard level and repaired wit

specified timeframe
Existing Leak Management

• Distribution Integrity Management Plans (DIMP)

– To be fully implemented in August 2011– Intended to further reduce hazards associated with leak– Evaluation based, in part, on leak history and leak rate– Repairs based on risk determinations
Optical Scanning vs. Current Leak Detec

• EPA’s proposal exceeds even the most extensive GHG 

inventories performed by LDCs to date – SW Gas exam

• Cheaper methods (soap solution and wand) are more 

and accurate than optical scanners, which are sensitivand weather conditions and often miss leaks that are the low tech method

• There are not enough optical scanners or people train

them – regardless of whether the LDC purchases the eor hires outside consultants

• There are many thousands of above ground M&R stati

especially if EPA intends to include not just city gates district M&R but also industrial and commercial custom

(basically customer meters) – EPA incorrectly assumethere are only a few to be surveyed each year

• It takes lon

g p er to use an o

ptical scanner than EPA ass
T bl F F iti V t d

Fugitive Vented Source

Due Date: August 19, 2005

District/Office Name

C &

Table F - Fugitive Vented

Information Request 

Reporting Year 2004

Contact Name & Phone number

Direct Emissions - Fugitives

Source ID

District/ Plant/ Facility/ 

Business Unit Equipment Type (Examples Provided below)

Length of 

Pipeline (km)

Number of 

Stations 

F-1 Customer MetersF-2 Distribution Main Pipeline Length (Cast Iron)

F-3 Distribution Main Pipeline Length (Plastic)F-4 Distribution Main Pipeline Length (Protected Steel)F-5 Distribution Main Pipeline Length (Unprotected Steel)F-6 Distribution Services Length (Copper)F-7 Distribution Services Length (Plastic)F-8 Distribution Services Length (Protected Steel)F-9 Distribution Services Length (Unprotected Steel)

F 10 - Di t ib ti Ri Distribution Risers

F-11 Distribution Reg StationF-12 Transmission Pipeline Length (Cast Iron)F-13 Transmission Pipeline Length (Plastic)F-14 Transmission Pipeline Length (Protected Steel)F-15 Transmission Pipeline Length (Unprotected Steel)F-16 Compressor Stations

F-17 Other Equipment??? (separators holding tanks etc ) Other Equipment??? (separators, holding tanks, etc.)F-18F-19F-20

Emissions Summary

T t l CO

Source Type

To

t

al CO2e

(percent of total)

Stationary & Indirect Stationary

& Indirect 1.5%

Mobile Equipment 8.5%Fugitive & Vented 90%

Regulator stations 32%

Residential and 

commercial meters 17%

Distribution mains 30

%

Dig Ins 8%

Blow Downs 3%

Grand Total 100.00%
Emissions by Customer T

Based on Distributed Ga

Type of Customer Number of

Customers

Gas

Delivered

Percentage 

(Decatherms)

Custom. Ther

Residential 1,727,790 70,498,626 95.586% 32.26Small Commercial 77,633 31,455,475 4.295% 14.39Compressed Gas 166 370,899 0.009% 0.17I i ti rr gation 379 1 323 894 1,323,894 0 021% . 0 60

. 

Large Commercial 896 10,817,354 0.050% 4.95S a dust y m

all Indust

r

y

2

54 4, 8,353 118,353

00 % . 14

% 1.88

Essential Agriculture 82 713,821 0.005% 0.32Procurement Sales 20 4,937,975 0.001% 2.26Transported 365 94,274,100 0.020% 43.14

Total 1,807,585 218,510,497
Subpart NN - Suppliers of Natural 

2008 N t l G D li i t C t 2008 Natural Gas Deliveries to Customer

<25,000 mt

< 4,600,000 Therms

Report NG Deliveries

>25,0

> 4,600,0

p Self Re

Customer Class Therms Customers Therms Residential 704,986,220 1,727,790 0 Commercial 422,728,290 78,529 0 Industrial 41,183,510 254 0 Compressed Natural Gas 3, , 708 990 166 0 Irrigation/Water Pumping 13,238,930 379 0 Essential Agriculture 7,138,210 82 0 P tG S l Procurement Gas Sales 154 309 154,309 0 49 016 621 49,016,621 Other Gas Sales 208,820 13 0 Transportation 170,550,000 337 772,191,000 

Total 1,363,897,279 1,807,550 821,207,621 

This information has already been provided to:

Clark Co., NV; Henderson, NV; Maricopa Co., AZ; San Bernardino Co., CA
Total Emissions 

from SWG Activities

Source Tons

SWG Operations SWG Operations 1 694 971 1,694,971 Customers

<25,000 tons 25,000 tons 7,978,799 7,978,799 

Customers >25,000 tons 4,804,065 

Total 14,477,834
Direct Measurement

M&R Stations


Field test observations:

• Extremely difficult to detect small leaks

• R lt l i f ti l Results were only in

ferenti

al

• Use of wands were more effective• Quantification b

y g hi

gh-volume samplers

• Excessive cost for little technical value
Examples of M&R and City Gates –

Wide Variety
SGTC City Gate

Laughlin, NV

Inlet MAOP 1008 psigOutlet pressure 730 psig
Gasline Road City Gate

Victorville, CA

Inlet MAOP 936 psig Inlet MAOP 936 psigOutlet pressure 240 psig
City Gate

Willow Valley, NV 

Inlet MAOP 100 psigOutlet pressure 60 psig
Gypsum Plant M&R

Las Vegas, NV
Convention Center M&R

Las Vegas, NV
APEX Industrial M&R Station

Las Vegas, NV
Small Commercial M&R Station

• Photos of components
Couplings
Couplings
Plug Valve
Small Commercial M&R

Fast Food Restaurant
Commercial M&R

Big Box Store
Commercial M&R

Medium Box Store
Commercial M&R

Another Medium Box Store
Large Commercial M&R
Large Commercial M&R
Commercial M&R

Office Building Back Up Generation 
Commercial M&R

Large Office Building
Cost of Leak Detection & Optical Scann

• Not clear what type of optical gas scanning eq

would be required

• Could affect the cost significantly

– FLIR camera/ Optical Imaging Device? Cost around $

$100,000 each to purchase – around $2,500 per wee

– Mobile or Remote Methane Leak Detector (RMLD)? C

around $30,000

– Vehicle

-Mounted Methane Leak Detector? Cost arou

$16,000-18,000 each 

– Remote hand-held optical methane detectors? Cost 

$8,000 each.
Experience with FLIR

Peter Ford (New Mexico Gas)

• FLIR camera cannot scan hundreds of source types 

contrary to EPA’s assertion in Subpart W proposal

• The FLIR did not find any leaks we could not find al

just looking for dirty pipe or using soap solution

• And it missed the smaller leaks that we found using 

methods
Cost Considerations - M&R Surveys

• Around $40 per ton of CO2e just to estimate (not redu

emissions at M&R stations under the proposal

• AGA survey results indicate each company would need 

several thousand M&R stations

• Company that recently did a test run found they could 

and perform the scan at <10 M&R stations per day pe

• Each company would need over 100 scanners and trai

operators to perform annual survey within a two mont

at the average 19 000 M&R stations per company at the average 19,000 M&R stations per company 

• A substantial portion of the expected costs would be a

M&R stations were removed from the rule – or at leas

term were defined to clearly exclude industrial commterm were defined to clearly exclude industrial, commresidential customer metering 
Big Picture – Danny Smith (Alagasco

• What are your goals?• Are EPA’s goals already served by existing regul• Is your goal to generate methane emissions data to a

calculating the lifecycle GHG emissions for using naturother energy sources? 

• AGA supp g y y g 

orts usin

g lifec

ycle anal

ysis for calculatin

g en

efficiency and GHG emissions

• Better way to achieve that goal--

– LDCs already report mileage of mains and services to DO– EPA creates the annual GHG Inventory applying availabl

factors for bare steel, plastic and cast iron pipe to that m

– Subpart W would just duplicate that effort for mains and 

• Wh j h ii Od d hy not 

just use t

he existing D

OT 

data an

d EPA 

Greenhouse Gas Inventory? 

• And use updated emission factors when availabl
Additional Concerns

• Request clarification – distribution vs. transmiss

PGE 

– The proposal does not specify where to draw the line be

distribution and transmission operations 

– Many members operate both distribution and transmissi

and will need additional clarifications to determine what operations are proposed to be included.

• Need definition of “connector”• Does EPA really need the count for such small fit
Questions & Comments

• AGA member company representatives on the phone 

webinar link may pose questions to EPA or make addicomments

• “Raise Your Hand” in Chat Area – and post short note 

area regarding your topic

• When Pam Lacey calls on you, press *6 to un-mute yo

and ask your question

• When you are done, press When you are done, press 6 to mute your phone ag

* 6 to mute your phone ag
Conclusion

• Postpone Subpart W applicability to Distribution until u

emission factors, then see what makes sense

• In alternative, use existing y 

 GHG Inventory for distribu

and phase in requirements for M&R and city gates

– Use existing best practices in 2012– Phase in additional requirements in 2015– Reduce number of components– Define M&R to exclude industrial, commercial and reside

customer metering and regulating

• D i t f i f d d ll 

Drop requirement for infrared cameras and allow use leak surveys as required by PHMSA and utility commis

– or at least define what types of equipment you have in m

allow the use of alternative methods in use no – such as solution and wands

• Do what makes sense and will allow for compliance as
THANK YOU FOR YOUR TIME

Pamela Lacey

Senior Managing Counsel, Environment

placey@aga.org