## American Gas Association Summary of Current Leak Survey Requirements May 12, 2010 Federal Leak Survey Regulations U.S. Department of Transportation (DOT) Pipeline & Hazardous Substances Safety Administration (PHMSA) 49 C.F.R. Part 192 Pipeline Safety Regulations for Natural Gas Transmission & Distribution See attached chart for all applicable DOT regulations. In brief, DOT requires utilities to conduct leak surveys of gas distribution systems: 1. Once per year in business districts annually and 2. Once every 5 years outside business districts. See 49 C.F.R. §192.723. State Utility Commission Leak Survey Regulations

Some state PUCs adopt the federal DOT rules. Connecticut and Nevada are examples.

Others impose more stringent than federal requirements for surveying and grading leaks. Survey intervals in these states range from once every 3 years to every year . Example of more stringent state rules: California PUC Rule Section 143.1 Leak Surveys must be conducted “at intervals not exceeding 15 months, but at least once each calendar year.” California PUC Rule Section 143.2 Valve maintenance similarly provides: “Each valve, the use of which may be necessary for the safe operation of a distribution system, must be inspected, serviced, lubricated (where required) and partially operated at intervals not exceeding 15 months, but at least once each calendar year .” List of Components to be inspected under DOT and state PUC leak survey rules: The DOT regulations do not list specific components to be inspected. There is no requirement to maintain “counts” of specific types of components. Some of our member companies have developed such counts for purposes of voluntary greenhouse gas inventories, such as CCAR or the Climate Registry, however these companies have not developed component counts for all the components listed in proposed Subpart W. DOT Rules provide in 49 C.F.R. §192.723 -- “The type and scope of the leakage control program must be determined by the nature of the operations and the local conditions.”2State PUC Rules may be more specific. But there is no state requirement to count the number of valves or other types of components. Leak Detection Methods: DOT rules require the use of “leak detector equipment.” See 49 C.F.R. §192.723. This includes the full range of options, such as soap solution, wands, optical scanning. State PUC Rules may be more specific

. For example, Maryland PUC Rules require the following: “A. Procedures and Methods. Each utility or gas master meter operator shall establish procedures for making periodic gas leakage surveys as specified in these regulations. For residential customers with meters located outdoors, leakage surveys shall be performed up to the building entry. The leakage surveys shall be conducted by one or more of the following methods: (1) Flame ionization; (2) Combustible gas indicator and bar hole; (3) Optical methane detector; or (4) Other method approved by the Commission. AGA GPTC Leak Survey Guidelines and Company Leak Survey Plans AGA’s Gas Pipe Technology Committee (GPTC) has developed guidelines for conducting leak surveys based on DOT PHMSA requirements. Member companies have developed their leak survey plans based on the GPTC Guidelines, adding any more stringent requirements imposed by the applicable state PUC. The AGA GTPC Guidelines are available for purchase for a small fee at www.aga.org . AGA can provide EPA with some sample excerpts from the GPTC Guidelines. In addition, we will provide some sample member company leak survey plans. How Utilities Must Respond and Report: Immediate Reports to DOT and State for Serious Leaks: In the case of an emergency level leak, called an “incident,” the operator must respond and address the leak immediately. The operator also must report the incident to DOT and state regulators within two hours. Annual Leak Report to DOT: The incidents and other leaks discovered during the year must also be reported to DOT on the operator’s annual report.