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, 

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 

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Postal Address 

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Washington DC 20460 

USA 

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.