May 14, 2010 

TO: Roger Fernandez 

 Program Manager, EPA Natural Gas STAR 

FROM: Pamela Lacey 

 AGA Senior Managing Counsel, Environment 

RE: Information Requested in May 6, 2010 Meeting & 

 AGA’s Request for Clarification of Terms in Subpart W 

 Docket ID No. EPA-HQ-OAR-2009-0923 

EPA Proposed Rule, Mandatory Reporting of Greenhouse Gases: 

Petroleum and Natural Gas Systems, 40 CFR Part 98, 

75 Fed. Reg. 18608 (April 12, 2010) 

 

Information Regarding Federal & State Leak Survey Rules: 

As a follow up to our meeting on May 6, 2010, and as you requested, AGA is 

submitting the attached information summarizing the existing federal and state 

requirements for leak detection at natural gas distribution facilities. 

 

Undefined or Unclear Terms: 

In addition, we discussed in the meeting that there are several terms for which 

AGA needs clarification in order to be able to evaluate and effectively comment on 

the impact of the proposed Subpart W on member operations. As you suggested, 

we are submitting the following list of terms and an explanation of why we need 

clarification before the June 11, 2010 comment deadline. 

1. Metering & Regulating (M&R) Stations 

Natural gas utilities operate many types of metering and regulating equipment, 

ranging from city gates and custody transfer stations, district M&R stations, M&R 

for industrial customers, to much smaller meters and regulators for homes and 

businesses. The impacts and burdens of the proposed rule would be increased 

by many orders of magnitude if you include millions of commercial and residential 

M&R equipment in the requirement to conduct annual surveys using $100,000 

infrared cameras. Do you plan to define M&R to exclude industrial, commercial 

and residential customers? 

2. Optical Gas Imaging Instrument 

Section 98.234 requires the use of an “optical gas imaging instrument” for annual 

leak surveys. This is an undefined term. The equipment that could be included 

potentially could range from about $100,000 each for infrared cameras (or $2,500 
AGA Comments to OMB on EPA Subpart W Proposed Rule 

May 12, 2010 

Page 2 of 6 

400 North Capitol St., NW, Washington, DC 20001 ∎ Telephone 202-824-7000, Fax 202-824-7115 ∎ Web Site 

http://www.aga.org 

2

per week to rent an infrared camera) to about $30,000 for each mobile or vehiclebased remote leak detection (RMLD) unit or about $18,000 each for hand-held 

leak detectors. What equipment does this term encompass? 

3. Connectors 

Proposed 40 C.F.R. §98.232(e), (f), (g), (h) and (i) would require our members to 

report fugitive emissions from “connectors” among other components. 

There is no definition for the term “connectors.” It could encompass a vast 

number of components, and this could exponentially increase the cost of 

performing annual leak surveys of “connectors” using optical gas scanning. What 

does this term include or exclude? 

4. Open –Ended Lines 

Proposed 40 C.F.R. §98.232(e), (f), (g), (h) and (i) also would require our 

members to report fugitive emissions from “open-ended lines.” There is no 

definition of this term, and most of our members have no idea what it means. One 

member company tells us that in California usage, the term refers to blow down 

vents. Is this what you intend? 

We realize that time is growing short to obtain the appropriate internal reviews and 

provide a response before the comment deadline of June 11, 2010, but if it is 

possible, the clarification would assist us in providing informed comments on the 

Subpart W proposal.