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 $2,500AGA 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 

### 2per 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 “connecto rs” 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.