U.S. EPA’s Propose

Amendment to the 

Greenhouse Gas 

Mandatory Reporting R

(75 FR 18652, April 12, 201

NEMA Ad-Hoc Task Group on SF

May 7, 2010

Subpart SS: Manufacture of Electrical T&Subpart DD: Use of Electrical T&D EquipSubpart QQ: Imports and Exports of Equ

charged with Fluorinated G
Mandatory Reporting Rule: Status 

• Required by FY08 Appropriations Act – Dec. 26, 2007

– All greenhouse gases – Report on Upstream and Downstream source– Collect accurate and timely data to inform pub

• Final rule signed September 22, 2009; pu

Federal Register on October 30, 2009

– Requires reporting of 2010 data in 2011

• New/additional source categories propos

2010; published in Federal Register April 
Key Elements of the Final Rul

• Annual reporting of GHG by:

– 25 source categories– 5 types of suppliers of fuel and industr– Motor vehicle and engine suppliers (ex

duty sector)

• 25,000 metric tons CO2 e per year reportin

threshold for most sources; capacity-basethresholds where feasible

• Estimated 10,000 facilities (85% of US em

coverage)

• Direct reporting to EPA electronically, sys

web-based

• EPA will conduct verification of the emiss
Upstream Sources

• Suppliers of Coal-based Liquid Fuels• Suppliers of Petroleum Products• Suppliers of Natural Gas and Natural Gas Liquids• Suppliers of Industrial GHGs• Suppliers of Carbon Dioxide (CO2)

Downstream Sources

• General Stationary Fuel 

Combustion Sources

• Electricity Generation• Adipic Acid Production• Aluminum Production• Ammonia Manufacturing• Cement Production• Ferroalloy Production• Glass Production• HCFC-22 Production 

and HFC-23 Destruction

• Hydrogen Production• Iron and Steel Production• Lead Production

Mobile Sources •Vehicles and engines outside of the light-duty sector (light-duty in NP

Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Fuel Ec

Source Categories in the Final Rul

• Lime Manufacturing• Miscellaneous Uses of Ca• Nitric Acid Production• Petrochemical Production• Petroleum Refineries• Phosphoric Acid Product• Pulp and Paper Manufact• Silicon Carbide Productio• Soda Ash Manufacturing• Titanium Dioxide Produc• Zinc Production• Municipal Solid Waste La• Manure Management

* We delayed inclusion of the following source categories as we consider the comments and Electronics Manufacturing, Ethanol Production, Fluorinated GHG Production, Food ProcesProduction, Oil and Natural Gas Systems, Sulfur Hexafluoride (SF6 ) from Electrical Equipm

Coal Mines, Industrial Landfills, Wastewater Treatment, Suppliers of Coal
MRR Requirements

• Rule applies to:

– Direct emitters of greenhouse gases with emis

equal or greater to 25,000 metric tons/year (ecars’ worth of coal, or average annual energy u

– Suppliers of fossil fuels & industrial chemicals– Manufacturers of motor vehicles and engines

• Covers 85%-90% of total U.S. GHG emissio• Reporting generally at the facility level• Excludes most small businesses and govern• MRR complements state programs; it is no

replace or preclude them
Amendment to the Mandatory Reporting Rule

• Proposal signed March 22, 2010; 

published in Federal Register April 12, 20

• 60 day public comment period - June 11• Goal is reporting for calendar year 2011 in • Includes three sources of SF6 

–

– Subpart SS: Manufacture of electric power eq– Subpart DD: Use of electric power equipment– Subpart QQ: Imports and exports of equipme

fluorinated greenhouse gases
Electrical Equipment Ma

or Refurbishme

~Subpart SS~
Proposed Definition of SourcCategory and Reporting Threshold

• Electrical equipment manufacturers and r

SF6 or PFC-insulated closed-pressure equsealed-pressure equipment including GISand other switchgear, GIL, or power trans

• EPA requests comment on:

3⁄4 Whether transformers using PFCs are manufa3⁄4 Whether PFC emissions associated with the 

manufacture/refurbishment occur at the same 

same processes as SF6 emissions.

• Proposed Reporting Threshold: Total ann

SF6 and PFC exceed 23,000 lbs.

3⁄4 Equivalent to an emissions-based threshold of 
Proposed Monitoring Method

• Mass-balance approach similar to th

Guidelines Tier 3 methods

3⁄4Emissions of SF6 and PFCs would be e

reported separately 

• Mass balance equation: 

3⁄4Emissions = (decrease in SF

6 inventory

of SF

6) – (disbursements of SF

6) 

• PFC emissions calculation would als

using same equation
Determining Disbursemen

• Emissions may occur downstream of the 

equipment that is being filled

3⁄4 To accurately estimate disbursements, these e

estimated separately and subtracted from the 

• EPA considered 4 options and proposed 2 

1. Weigh containers before and after gas from co

to fill equipment or cylinders (proposed)

2. Use flow meters to measure the amount of ga

equipment or cylinders (proposed)

3. Assume that mass disbursed to customers in 

to the nameplate capacity of the equipment (onameplate capacity of the equipment times thdensities of the partial charge and the full cha

4. Weigh equipment filled with SF6 or the PFC f

before and after filling. Subtract tare weight ofrom weight of the filled equipment
Proposed Data Reporting Requirements

• SF6 and PFCs 

– sales and purchases. – sent off site for destruction. – sent off site to be recycled. – returned from off site after recycling. – returned by equipment users with or inside equi– stored in containers at the beginning and end of 

– inside equipment delivered to customers. – returned to suppliers. 

• Nameplate capacity of the equipment delivered 

SF6 or PFCs inside, if different from the quantitinside equipment delivered to customers. 

• A description of the engineering methods and c

determine emissions from hoses or other flow lthe container to the equipment that is being fill
Installation

• EPA requests comment on whether an equ

installation mass-balance eqn. is required emissions from equipment installation anperformed by manufacturer at utility loca

3⁄4 Manufacturer responsible for associated emiss

equipment before transferring custody to the u

• EPA requests comment on whether manu

be required to certify to equipment users tSF6 or PFCs charged into equipment at in

3⁄4 How frequently is equipment over-charged at 3⁄4 How to quantify compensating for the overcha

emissions (subpart DD)
Electric Transmissio

Distribution Equipme

~Subpart DD~
Background 

• First proposed on April 12, 2009 (74 F

3⁄4EPA received a number of commen

the definition of “facility” under sub

• Supplemental proposal (April 12, 2010

18652) to provide additional detail on source category.

• EPA requests comment on definition o

category and is not seeking further comother elements of the initial proposal s

selection of the threshold and the propmonitoring methods.
Proposed Definition of SourcCategory

• EPA proposes to define “facility” for 

to mean an electric power system.

• EPA proposes to define an electric p

as the collection of SF6- and PFC-inequipment linked through electric ptransmission or distribution lines anan integrated unit by one electric poseveral entities that have a single ow

• EPA proposed to define and electric 

using the Energy Information Admi(EIA) list of examples
Imports and Export

Fluorinated GHG Insi

Charged Equipment an

Cell Foams

~Subpart QQ~
Proposed Definition of SourcCategory and Reporting Thre

• Importers and exporters of pre-charged equipmen

foams that contain fluorinated GHGs. 

• Pre-charged equipment - any appliance, appliance 

electrical equipment, or electrical equipment coma fluorinated GHG prior to sale or distribution or 

distribution. Includes both equipment that containecessary for operation and equipment that conta“holding” charge of the fluorinated greenhouse ga

3⁄4 Electrical equipment includes (but is not limited to

substations, circuit breakers, other switchgear, gas-power transformers. 

• Proposed Reporting Threshold: total imports or t

equipment, foams, and in bulk, exceeded 25,000 carbon dioxide equivalent per year. 
Proposed Monitoring Method

• Importers and exporters would dete

mass of fluorinated GHG imported otheir equipment as follows: 

3⁄4For each type of pre-charged equipmen

fluorinated GHG, multiply the fluorinaper unit of equipment by the number oequipment imported or exported annu
Proposed Data Reporting Requirements

• Main data reporting requirements in

– Total mass of each fluorinated GHG imp

exported in pre-charged equipment. 

– the identity of the fluorinated GHG used

(including holding charge, if applicable)of pieces of equipment imported or expo

– Dates when the pre-charged equipment 

and exported. 

– Ports of entry through which the pre-ch

passed. 

– Countries from or to which the pre-char

were imported or exported.
For more information

• Visit EPA’s Web site 

(www.epa.gov/climatechange/emissions/

tml) for more information, including the p

preamble and rule and additional informaspecific industries, or go to <www.regulat

access the rulemaking docket (EPA-HQ O

• Written comments should be submitted to 

www.regulations.gov no later than June 1

• For questions that cannot be answered th

site or docket, call 1-877-GHG-1188 or em

ghgmrr@epa.gov.
Presentation not a substitute reading the Proposed Rule

• This presentation is intended to assist reportin

facilities/owners in understanding key provisi

proposed rule. However, it is not intended to bsubstitution for the proposal (75 FR 18652; Ap

• If there are any inconsistencies with material p

and the rule, defer to what’s in the rule.

• Asking a question on this presentation is not t

submitting public comment. Please see Web ppreamble for information on how to submit co