U.S.EPA’sProposedAmendment to theGreenhouse GasMandatory Reporting Rule(75 FR 18652, April 12, 2010)NEMA Ad-Hoc Task Group on SF6MeetingMay 7, 2010Subpart SS: Manufacture of Electrical T&D EquipmentSubpart DD: Use of Electrical T&D EquipmentSubpart QQ: Imports and Exports of Equipment Pre-charged with Fluorinated GHGs2Mandatory Reporting Rule:Status•Required by FY08 Appropriations Act –Dec. 26, 2007–All greenhouse gases–Report on Upstream and Downstream sources–Collect accurate and timely data to inform public policy•Final rule signed September 22, 2009; published inFederal Registeron October 30, 2009–Requires reporting of 2010 data in 2011•New/additional source categories proposed March 22,2010; published in Federal Register April 12, 20103Key Elements of the Final Rule•Annual reporting of GHG by:–25 source categories–5 types of suppliers of fuel and industrial GHG–Motor vehicle and engine suppliers (except lightduty sector)•25,000 metric tons CO2e per year reportingthreshold for most sources; capacity-basedthresholds where feasible•Estimated 10,000 facilities (85% of US emissionscoverage)•Direct reporting to EPA electronically, system will beweb-based•EPA will conduct verification of the emissions data4UpstreamSources•Suppliers of Coal-based Liquid Fuels•Suppliers of Petroleum Products•Suppliers of Natural Gasand Natural Gas Liquids•Suppliers of Industrial GHGs•Suppliers of Carbon Dioxide (CO2)DownstreamSources•General Stationary FuelCombustion Sources•Electricity Generation•Adipic Acid Production•Aluminum Production•Ammonia Manufacturing•Cement Production•Ferroalloy Production•Glass Production•HCFC-22 Productionand HFC-23 Destruction•Hydrogen Production•Iron and Steel Production•Lead ProductionMobile Sources•Vehicles and engines outsideof the light-duty sector(light-duty in NPRM toEstablishLight-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Fuel Economy Standards)Source Categories in the Final Rule*•Lime Manufacturing•Miscellaneous Usesof Carbonates•Nitric Acid Production•Petrochemical Production•Petroleum Refineries•Phosphoric Acid Production•Pulp and Paper Manufacturing•Silicon Carbide Production•Soda Ash Manufacturing•Titanium Dioxide Production•Zinc Production•Municipal Solid Waste Landfills•Manure Management* We delayed inclusion of the following source categories as we consider the comments and options:Electronics Manufacturing, Ethanol Production, Fluorinated GHG Production, Food Processing, MagnesiumProduction, Oil and Natural Gas Systems,Sulfur Hexafluoride (SF6) from Electrical Equipment, UndergroundCoal Mines, Industrial Landfills, Wastewater Treatment, Suppliers of Coal5MRR Requirements•Rule applies to:–Direct emitters of greenhousegases with emissions generallyequal or greater to 25,000 metrictons/year (equivalent to 131 railcars’ worth of coal, or average annual energy use of 2,200 homes)–Suppliers of fossil fuels & industrial chemicals–Manufacturers of motor vehicles and engines•Covers 85%-90% of total U.S. GHG emissions•Reporting generally at the facility level•Excludes most small businesses and governments•MRR complements state programs; it is not intended toreplace or preclude them6Amendment to the MandatoryReporting Rule•Proposal signed March 22, 2010;published in Federal RegisterApril 12, 20010•60 day public comment period - June 11•Goal is reporting for calendar year 2011 in 2012•Includes three sources of SF6––Subpart SS: Manufacture of electric power equipment–Subpart DD: Use of electric power equipment–Subpart QQ: Imports and exports of equipment charged withfluorinated greenhouse gases7Electrical Equipment Manufactureor Refurbishment~Subpart SS~8Proposed Definition of SourceCategory and ReportingThreshold•Electrical equipment manufacturers and refurbishers ofSF6 or PFC-insulated closed-pressure equipment andsealed-pressure equipment including GIS, circuit breakers,and other switchgear, GIL, or power transformers.•EPA requests comment on:3⁄4Whether transformers using PFCs are manufactured in the U.S.3⁄4Whether PFC emissions associated with themanufacture/refurbishment occur atthe same rate and during thesame processes as SF6 emissions.•Proposed Reporting Threshold:Total annual purchases ofSF6 and PFC exceed 23,000 lbs.3⁄4Equivalent to an emissions-based threshold of 25,000 MTCO2Eq.9Proposed Monitoring Methods•Mass-balance approach similar to the 2006 IPCCGuidelines Tier 3 methods3⁄4Emissions of SF6 and PFCs would be estimated andreported separately•Mass balance equation:3⁄4Emissions = (decrease in SF6inventory) + (acquisitionsof SF6) – (disbursements of SF6)•PFC emissions calculation would also be requiredusing same equation10Determining Disbursements•Emissions may occur downstream of the container to theequipment that is being filled3⁄4To accurately estimate disbursements, these emissions should beestimated separately and subtracted from the disbursement total.•EPA considered 4 options and proposed 2 methods1.Weigh containers before and after gas from containers was usedto fill equipment or cylinders (proposed)2.Use flow meters to measure the amount of gas used to fillequipment or cylinders (proposed)3.Assume that mass disbursed to customers in equipment is equalto the nameplate capacity ofthe equipment (or equal to thenameplate capacity of the equipment times the ratio of thedensities of the partial charge and the full charge).4.Weigh equipment filled with SF6or the PFC from the containerbefore and after filling. Subtracttare weight of the equipmentfrom weight of the filled equipment11Proposed Data ReportingRequirements•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 userswith or inside equipment.–stored in containers at thebeginning and end of the year.–inside equipment delivered to customers.–returned to suppliers.•Nameplate capacity of the equipment delivered to customers withSF6 or PFCs inside, if different from the quantity of SF6 and PFCsinside equipment delivered to customers.•A description of the engineering methods and calculations used todetermine emissions from hoses or other flow lines that connectthe container to the equipment that is being filled.12Installation•EPA requests comment on whether an equipmentinstallation mass-balance eqn. is required to measureemissions from equipment installation and commissioningperformed by manufacturer at utility location.3⁄4Manufacturer responsible for associated emissions when fillingequipment before transferring custody to the user•EPA requests comment on whether manufacturer shouldbe required to certify to equipment users the actual qty. ofSF6 or PFCs charged into equipment at installation.3⁄4How frequently is equipment over-charged at installation3⁄4How to quantify compensating for the overcharge in useremissions (subpart DD)13Electric Transmission andDistribution Equipment Use~Subpart DD~14Background•First proposed on April 12, 2009 (74 FR 16448).3⁄4EPA received a number of comments regardingthe definition of “facility” under subpart DD.•Supplemental proposal (April 12, 2010, 75 FR18652) to provide additional detail on definition ofsource category.•EPA requests comment on definition of sourcecategory and is not seeking further comment onother elements of the initial proposal such as theselection of the threshold and the proposedmonitoring methods.15Proposed Definition of SourceCategory•EPA proposes to define “facility” for this subpartto mean an electric power system.•EPA proposes to define an electric power systemas the collection of SF6- and PFC-insulatedequipment linked through electric powertransmission or distribution lines and operated asan integrated unit by one electric power entity orseveral entities that have a single owner.•EPA proposed to define and electric power entityusing the Energy Information Administration(EIA) list of examples16Imports and Exports ofFluorinated GHG Inside PreCharged Equipment and ClosedCell Foams~Subpart QQ~17Proposed Definition of SourceCategory and Reporting Threshold•Importers and exporters of pre-charged equipment and closed-cellfoams that contain fluorinated GHGs.•Pre-charged equipment - any appliance, appliance component,electrical equipment, or electrical equipment component charged witha fluorinated GHG prior to sale ordistribution or offer for sale ordistribution. Includes both equipment that contains the full chargenecessary for operation and equipment that contains a partial“holding” charge of the fluorinated greenhouse gas.3⁄4Electrical equipment includes (butis not limited to) gas-insulatedsubstations, circuit breakers, other switchgear, gas-insulated lines, andpower transformers.•Proposed Reporting Threshold: total imports or total exports, inequipment, foams, and in bulk, exceeded 25,000 metric tons ofcarbon dioxide equivalent per year.18Proposed Monitoring Methods•Importers and exporters would determine the totalmass of fluorinated GHG imported or exported intheir equipment as follows:3⁄4For each type of pre-charged equipment containing afluorinated GHG, multiply the fluorinated GHG chargeper unit of equipment by the number of units ofequipment imported or exported annually.19Proposed Data ReportingRequirements•Main data reporting requirements include:–Total mass of each fluorinated GHG imported orexported in pre-charged equipment.–the identity of the fluorinated GHG used, charge size(including holding charge, ifapplicable), and the numberof pieces of equipment imported or exported.–Dates when the pre-charged equipment were importedand exported.–Ports of entry through which the pre-charged equipmentpassed.–Countries from or to which the pre-charged equipmentwere imported or exported.20For more information•Visit EPA’s Web site(www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more information, including the proposedpreamble and rule and additional information sheets onspecific industries, or go to <www.regulations.gov> toaccess the rulemaking docket (EPA-HQ OAR-2009-0927).•Written comments should be submitted towww.regulations.govno later than June 11•For questions that cannot be answered through the Website or docket, call 1-877-GHG-1188or email:ghgmrr@epa.gov.21Presentation not a substitute forreading the Proposed Rule•This presentation is intended to assist reportingfacilities/owners in understanding key provisions of theproposed rule. However, itis not intended to be asubstitution for the proposal (75FR 18652; April 12, 2010).•If there are any inconsistencies with material presented hereand the rule, defer to what’s in the rule.•Asking a question on this presentation is not the same assubmitting public comment. Please see Web page orpreamble for information on how to submit comments.