| longname |
|---|
| Wiki Markup |
{longname} Q651. Under Section 98.233(q)(8)(i), a company may elect to conduct leak detection on a multiple year cycle, up to a maximum of five years, with the number of stations monitored "approximately equal across all years in the cycle." The preamble to the final rule says "a minimum of 20%" per year (76 FR 80569). Would a monitoring plan that results in 10% of stations being monitored in each of the first two years, followed by 40% of stations in year 3, 20% in year 4 and 20% in year five, be consistent with the rule language of "approximately equal across all years in the cycle." {longname} |
A651.
...
Yes.
...
According
...
to
...
98.233(q)(8)
...
(i),
...
“Natural gas
...
distribution
...
facilities
...
may
...
choose
...
to
...
conduct
...
leak
...
detection
...
at
...
T-D
...
transfer
...
stations
...
over
...
multiple
...
years,
...
not
...
exceeding
...
a
...
five
...
year
...
period
...
to
...
cover
...
all
...
T-D
...
transfer
...
stations.
...
If
...
the
...
facility
...
chooses
...
to
...
use
...
the
...
multiple
...
year
...
option,
...
then
...
the
...
number
...
of
...
T-D
...
transfer
...
stations
...
monitored
...
in
...
each
...
year
...
should
...
be
...
approximately
...
equal
...
across
...
all
...
years
...
in
...
the
...
cycle
...
without
...
monitoring
...
the
...
same
...
station
...
twice
...
during
...
the
...
multiple
...
year
...
survey.
...
” EPA
...
confirms
...
that
...
an
...
approach
...
of
...
conducting
...
monitoring
...
at
...
10%
...
of
...
the
...
facilities
...
in
...
each
...
of
...
the
...
first
...
two
...
years,
...
followed
...
by
...
40%,
...
20%
...
and
...
20%
...
in
...
years
...
three,
...
four
...
and
...
five
...
would
...
be
...
consistent
...
with
...
the
...
rule
...
language
...
that
...
the
...
number
...
of
...
stations
...
monitored
...
be “approximately equal” over the number of years surveyed.
As noted in the preamble, the purpose of this provision was to reduce burden for reporters, including the option to better align survey frequencies between the Greenhouse Gas Reporting Program and Department of Transportation regulations. The statement in the preamble regarding a “minimum of 20 percent of their total number of stations being leak surveyed annually” was considered for cases where a facility chose a period of less than 5 years. We also recognize that there is a related comment and response in, “Mandatory Greenhouse Gas Reporting Rule: EPA's Response to Public Comments: “2011 Technical Revisions to the Petroleum and Natural Gas Systems Category of the Greenhouse Gas Reporting Rule” (see DCN: EPA-HQ-OAR-2011-0512-0030)
...
where
...
EPA
...
may
...
also
...
appear
...
to
...
reject
...
the
...
10%-10%-40%-20%-20%
...
approach
...
outlined
...
above.
...
However,
...
EPA
...
understood
...
the
...
commenter’s recommendation
...
as
...
to
...
be
...
suggesting
...
measurement
...
of
...
10%
...
of
...
stations
...
per
...
year,
...
over
...
a
...
ten
...
year
...
period.
...
EPA’s objection
...
to
...
the
...
comment
...
to
...
monitor
...
10%
...
of
...
stations
...
per
...
year
...
would
...
have
...
been
...
inconsistent
...
with
...
a
...
five-year
...
cycle.
...
In
...
summary,
...
the
...
rule
...
does
...
not
...
include
...
any
...
minimum
...
threshold
...
and
...
the
...
10%-10%-40%-20%-20%
...
is
...
consistent
...
with
...
the
...
rule
...
requirements
...
and
...
there
...
is
...
no
...
need
...
to
...
request
...
use
...
of
...
BAMM
...
to
...
follow
...
this
...
monitoring
...
approach.
...
Please
...
note
...
that
...
consistent
...
with
...
the
...
preamble
...
to
...
the
...
final
...
rule
...
(76
...
FR
...
80570),
...
you
...
must
...
describe
...
in
...
your
...
monitoring
...
plan
...
how
...
the
...
annual
...
leak
...
detection
...
surveys
...
represent
...
cross
...
sections
...
of
...
the
...
total
...
number
...
of
...
stations.
...
| Wiki Markup |
|---|
{show-to:group=confluence-Users}{center}{_}Footer / References Bar which is Visible to the public{_}{center}{show-to} |
| Panel | |||
|---|---|---|---|
| } Updated onon
|
| Wiki Markup |
|---|
{show-to:group=confluence-Users}
{info}
Source: EPA (Lisa Hanle, 3/20/2012), revised per direction of K. Sibold and A. McKittrick, 10/4/2012 including updated URL provided by K. Sibold 9/27/2012.
Approval / Publishing History: Version 2, Revised to update URLs per direction from K. Sibold, 9/27/2012
Expiration: none
Relevant Subpart: W
{info}{center}{_}History Panel For Internal Use - Not Visible to the Public{_}{center}{show-to} |