Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions Subpart W

Meeting Documentation:  Canadian Energy Partnership for Environmental
Innovation (CEPEI)   4/22/10

Date	Staff Contact Information (Name, email, phone #)	Name of
Organization (Attach list of all attendees names and emails if possible)
	Summary of Discussion (e.g., applicability, reporting requirements,
etc.)	Written Comments Provided?

Did they also submit to Docket?	Date sent to EPA- CCD



4/22/10

	

Roger Fernandez

Akachi Imegwu

Sandy Seastream, ICF 

	Peter Mussio 

Union Gas Limited

Christine Cinnamon  TransCanada PipeLines

Alain Leroux 

Gaz Metro Limited

Glenn England

ENVIRON International Corporation

Liz Siarkowski

TransCanada PipeLines

Lynn Ross

Lynn Ross Consulting

Wayne Alexander

ATCO Gas

Ronnie Deol

Terasen Gas

Jennifer Robertson

Terasen Gas

Darren Ribar AltaGas Utilities

Artur Janz

ATCO Pipelines

Curtis Clark

ATCO Pipelines

Jasmine Urisk

CEPEI

Marline Smith

TransCanada Pipelines

Brian Sloof

TransCanada PipeLines

Tom McGrath Innovative Environmental Solutions

	See following pages    	No written comments were submitted prior to the
meeting.  



	



CEPEI / EPA Meeting

USEPA OAR Offices, 1310 L Street, Washington DC

Via Teleconference

April 22, 2010 2:30 pm EDT

List of Issues Discussed

EPA explains that transmission compressor stations are in the rule, but
not transmission pipelines. 

EPA should define large compressors in transmission. 

EPA should define for transmission compressors, the duration a
compressors is required to be in a mode to necessitate emission
measurements.

EPA should clarify if in distribution residential meters are reportable.

EPA explains that LDC’s are required to report under both subpart W
and subpart C. 

EPA should clarify for distribution if gate stations are reportable.

EPA should provide an applicability tool for both transmission and LDC
reporters. 

EPA’s cost for subpart W is too low. 

April 16, 2010

Prepared for: CEPEI April 2010 meeting discussion of EPA draft reporting
rule

Sub Part W Questions 

Transmission 

Can we confirm our understanding that the only transmission facilities
included under the GHG MRR are compressor stations and that the 25 kt
CO2e reporting threshold applies to the sum of stationary combustion +
vented+fugitive +flared emissions?

Preamble p. 60 refers to the need for direct measurement on “large
reciprocating compressor units”, yet the rule only appears to refer to
“compressors”.  Is there a definition of “large” in the rule
somewhere so that smaller compressor units need not be measured?

I’ll defer to someone with on site measurement experience, but it
seems to me that the requirement to perform yearly  measurements while
units are (a)  pressurized and running, (b) pressurized and not running,
and (c)depressurized will in itself create incremental GHG emissions as
well as some operational /logistical challenges.  I think we could
anticipate the need for multiple site visits to take measurements to
meet this requirement. Has EPA considered how this requirement can be
implemented in practice?

Distribution

The rule and preamble have varying references to “M&R stations”,
“regulators”, “metering”, “meter regulators”, etc., but I
can’t seem to locate how/if these are defined.  For example,
residential meter sets have regulators and perform metering, but a
requirement to perform the “leak detection and leaker emission
factor” calculation method on an annual basis on all residential meter
stations  would be very costly.  Can we assume that EPA did not intend
the rule to capture the smaller above ground stations in this
requirement?  My suggestion would be to revise the rule to just require
leak detection at gate stations and move the balance of the stations to
the “equipment count and population emission factor” category.  And
even in regard to gate station leak detection, I think there might
reasonable grounds to extend the survey frequency to more than annually.


I could not find any mention in the preamble as to how EPA intends to
review and amend the rule’s requirements in future - for example, the
possible adjustment  of the required monitoring frequency in light of
reported leak data, or updating leaker and population emission factors
in light of  new research.

Can we confirm our understanding that LDC’s are required to report
under both SubPart W and SubPart C (general stationary combustion)? 
This appears to be the case yet the preamble (pp 93-94) notes “For
other facilities (e.g., LDCs), the only emissions of GHGs are process
emissions”.

Table W-7 in the reporting rule (p. 213):

Are the leaker emission factors for “above grade M&R stations”
supposed to apply to gate stations?  What, if any, other above ground
stations are they to be applied to?

The population emission factor for distribution mains is missing an
appropriate multiplier.  I’m guessing it should be “scf/h-mile”
but can this be confirmed?

Have the buried pipe factors (particularly the cast iron factor) been
adjusted for soil oxidation of CH4?

General

For both transmission compressor and LDC reporters, there is still an
onus on facilities that are under the threshold to determine that they
do not report.  This exercise can be almost as costly and onerous as
complying with the rules where you do trigger the reporting threshold. 
Particularly in the case of LDC’s where only about 10% of LDC’s will
trigger reporting  (calculated based on Preamble p. 52 data), in the
interests of cost containment and efficiency, will EPA provide
additional guidance to exempt  LDC’s below some “easy to check”
threshold?

In my opinion the costs per tonne to implement this rule are
underestimated.  For example, for LDC’s the estimate is $0.07/tonne
for the first year dropping to $0.04/tonne in subsequent years
(Preamble, p.89).  If we take a Canadian company example, one LDC
operation has “distribution” emissions of about 70 kt CO2e, so
presumably $4900 to cover annual inventory costs (using $0.07/tonne). 
This LDC company has about 200 gate stations, so allocating the full
costs to gate station measurement alone works out to about $25 per
location, and this is just one recurring cost item.  Will EPA consider
extending the leak detection frequency to help manage monitoring costs?

 Prepared by Lynn Ross,  HYPERLINK "mailto:lynnross@telus.net"
lynnross@telus.net , 250-338-4117*

