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

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

Date: 06/03/2010 03:22 PM Subject: RE: Responses to Questions and a Request

Thank you Roger - I will check with our pipeline safety group to get answers to your questions. - Pam

-----Original Message----- From: Fernandez.Roger@epamail.epa.gov [mailto:Fernandez.Roger@epamail.epa.gov] Sent: Thursday, June 03, 2010 3:19 PM

To: Lacey, Pam Subject: Responses to Questions and a Request

Pam,

I hope this email finds you well. In response to your questions, I can answer the following at this time:

1) Section 98.232(i)(1) states that emissions would be reported

under the natural gas distribution industry segment. Specifically, the proposed rule covers all above ground meter regulators and gate station fugitive emission from connectors, block valves, control valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines.

Stated differently, emissions from connectors, block valves, control valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines at above ground meter regulators and gate stations are covered in this proposed rule.

2) Open ended lines are defined in on page 56389 of Subpart A of

the Mandatory Reporting Rule published in September 2009. Connectors are defined on page 56385.

I have a request as well. Per our meeting at AGA, you and your members stated that there are extensive existing federal and state regulations that require leak detection and record keeping. Could you provide link to state regulation that mandates leak detection at, for example gate stations and other sources that are covered in the proposed rule? Leak detection and emissions tracking for the Mandatory Reporting Rule is very different from leak detection that prescribes such techniques as ambient gas concentration detection using for example a lower explosive
limit (LEL) detector.

We are interested in existing regulations that require actual leak detection on components and ideally a requirement of a record of leaks
found. The rules that we have found to date, both federal and state, only concern general safety and cover, for example, the ambient gas concentration in an area without identifying any specific components that may be leaking.

I look forward to hearing from you.

With best regards,

RogerRoger 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

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Any communication on the mandatory GHG reporting rule is intended to provide general and administrative information about the Rule. This communication does not provide legal advice, and responses to questions received do not have legally binding effect or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits in regard to any person. Facility owners or operators and suppliers are responsible for determining how they would be affected by the requirements of the rule.