From: <roger.little@dot.gov>

To: Roger Fernandez/DC/USEPA/US@ EPA, <mike.israni@dot.gov>

Cc: <jamerson.pender@dot.gov>

Date: 06/10/2010 05:30 PM Subject: RE: Follow up to June 3 Email

Roger,

I am not sure what I can add that you don't already know. The attachment that cites 192.723 do depict what our regulations say on requiring leakage surveys in gas distribution systems. The document also reflects that some states may have more stringent requirements for operators within their state. The document also points out that the

results of the surveys are reported annual as part of each operator's annual report along with any other system leaks by cause found and repaired during the calendar year. There is no way to distinguish leaks reported as part of a survey as opposed to leaks normally found during the course of a year, there is no distinction in that reporting. The annual report form and instructions are found on our Home Page at:

http://www.phmsa.dot.gov/pipeline/library/forms

and the information collected on those forms is available on that

website.

If you want to further discuss you can contact me at 202-366-4569, or Jamerson Pender at (202)366-0218. Jamerson manages the data collection

for the annual reports.

Regards,

Roger Little

-----Original Message----- From: Fernandez.Roger@epamail.epa.gov [mailto:Fernandez.Roger@epamail.epa.gov]

Sent: Thursday, June 10, 2010 5:13 PM To: Israni, Mike (PHMSA); Little, Roger (PHMSA) Subject: RE: Follow up to June 3 Email

Mike and Roger,

I hope this email finds the both of you doing well. Things here at EPA are quite busy with the development of the mandatory greenhouse gas reporting rule for the oil and gas sector. I am writing today to see if I might be able to set up a meeting with one or both of you in the middle or late next week in order for EPA staff to ask questions about current DOT regulations covering the gas distribution system.

Specifically, AGA has been stating to us since April that there are current DOT regs that cover specific fugitive leak detection. We have looked and looked and all that we are finding are regulations that apply to safety. For example, the regs we've located cover leak detection that prescribes such techniques as ambient gas concentration detection using for example a lower explosive limit detector. While perfectly fine from a safety standpoint, this type of leak detection is not applicable to our charge which is to collect greenhouse gas emissions data economy-wide. In the case of LDCs, the proposed rule that is currently out for public comment mandates leak detection at specificequipment sources, the application of a factor if a leak is detected and the reporting of said volumes from these sources - not simply assuring that an area has methane concentration well below the explosive limit.

Again, despite what AGA has been telling us since April, we have found no DOT reg that would give us data at this level of granularity. Concerning Pam Lacey of AGA's email today, from what I can see, she simply reiterated what we already knew about DOT regs. She did note the stringency of the TX State inspection program and says they'll be providing more state references. AGA asks for the ability to do surveys once every 5 years in remote areas and to do them in conjunction with what DOT requires - but again, what we've found in regard to DOT requirements does not meet our needs for actual leak detection and emissions data from specific components. I admit, we may be 100% incorrect though but we have done our best looking for the regs and therefore we'd appreciate a chance to speak with you.

I look forward to hearing from you and thanks for your time.

Sincerely,

Roger

Roger Fernandez U.S. Natural Gas STAR Program Methane to Markets Partnership

Phone: +1-202-343-9386

Fax: +1-202-343-2202 Website: epa.gov/gasstar

Visiting and Private Mail Carrier (DHL/FedEx etc) Address

1310 L St., NW (846) Washington, DC 20005

USA

Postal Address 1200 Pennsylvania Ave., NW (6207J) Washington DC 20460

USA

From: "Lacey, Pam" <PLacey@aga.org>

To: Roger Fernandez/DC/USEPA/US@EPA

Cc: "Israni, Mike" <mike.israni@DOT.GOV>, <roger.little@rspa.dot.gov>

Date: 06/10/2010 01:27 PM

Subject: RE: Follow up to June 3 EmailRoger,

Please forgive the delay. We have been working hard to get you this information while also working on our written comments. I believe you will find the attached description, web links, chart and copies of excerpts from the industry standard GPTC Guide helpful in answering your questions about current federal and state leak survey requirements.

In addition, here are two excellent contacts at DOT PHMSA. We have contacted them and they are expecting your call.

Mike Israni

Senior Technical Advisor

(202)366-4571

mike.israni@dot.gov

Roger Little

Manager, Information Technology and Analysis

(202)366-4569

roger.little@rspa.dot.gov

Both of these contacts will be able to provide a great deal of detail regarding what operators are currently required to do regarding leak surveys, leak management and annual reporting.

Thank you for your patience.

Best regards,

Pam

(See attached file: Existing Regs on Leak Reporting.pdf)(See attached file: Current Leak Inspection Repair Regulations (2).doc)(See attached file: ANSI GPTC Z380 1 - 2009 - Cover and Table of Contents.pdf)(See attached file: Pages from ANSI GPTC Z380 1 - 2009 with Addenda 1-2 (no cover art) pdf - Adobe Acrobat Professional.pdf)