AGA filed comments on June 21, 2013 urging EPA to delete inappropriate and misleading references to natural gas transmission line leaks in a guidance document intended for analyzing potential “vapor intrusion” from underground plumes of chemicals from subsurface contamination into buildings. EPA dropped this inappropriate reference in guidance for “Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Sources to Indoor Air” (“SVI Guidance”), which EPA issued in tandem with a second guidance for “Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tanks” (“PVI Guidance”) (Docket ID No. EPA-HQ-RCRA-2002-0033). AGA’s comments described the robust program of pipeline safety regulations administered by DOT PHMSA for leak detection and remediation, and noted that this is the appropriate regulatory scheme for addressing pipeline safety, not an EPA site remediation guidance.
AGA also joined in detailed comments of the Utility Solid Waste Activities Group (USWAG) filed on June 24, 2013 on other issues in the two guidance documents that could affect underground storage tanks (UST), site clean-ups and manufactured gas plants (MGPs). The USWAG comments supported AGA’s request to delete references to pipeline leaks or at least clarify that such methane leaks are not the sort of “vapor intrusion” intended to be covered by the guidance. AGA is a member of USWAG.
Click to view AGA's comments and to view USWAG's comments.