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 specific 
equipment 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 Email 
Roger, 

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)