U.S. EPA’s ProposedAmendment to the GreenhouseGas Mandatory Reporting Rule(75 FR 18652, April 12, 2010)SF6PartnersMeetingMay 13, 2010Subpart DD: Use of Electrical T&D EquipmentSubpart SS: Manufacture of Electrical T&D EquipmentSubpart QQ: Imports and Exports of Equipment Pre-charged with Fluorinated GHGsPresentation not a substitute forreading the Proposed Rule•This presentation is intended to assist reportingfacilities/owners in understanding key provisions of theproposed rule. However, it is not intended to be asubstitution for the proposal (75 FR 18652; April 12,2010).•If there are any inconsistencies with material presentedhere and the rule, defer to what’s in the rule.•Asking a question on this presentation is not the sameas submitting public comment. Please see Web pageor preamble for information on how to submitcomments.3Mandatory 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, 20104Key Elements of the October 30, 2009Final Rule•Annual reporting of GHG by:–25 source categories–5 types of suppliers offuel and industrial GHG–Motor vehicle and engine suppliers (except light dutysector)•25,000 metric tons CO2e per year reporting threshold for mostsources; capacity-basedthresholds where feasible•Estimated 10,000 facilities (85% of US emissions coverage)•Direct reporting to EPA electronically, system will be webbased•EPA will conduct verification of the emissions data•Excludes most small businesses and governments•MRR complements state programs; it is not intended toreplace or preclude them5UpstreamSources•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 Coal6Amendment to the MandatoryReporting Rule•Proposal signed March 22, 2010;published in Federal RegisterApril 12, 2010•60 day public comment period ends June 11•Goal is reporting for calendar year 2011 in 2012•Includes three sources or suppliers of SF6––Subpart DD: Use of electric power equipment–Subpart SS: Manufacture of electric power equipment–Subpart QQ: Imports and exports of equipment charged withfluorinated greenhouse gases7Electric Transmission andDistribution Equipment Use~Subpart DD~8Background•First proposed on April 12, 2009 (74 FR 16448)–Received comments from 22 entities–General support for threshold, method, monitoring, etc–Needed clarification ondefinition of “facility”•Supplemental proposal (April 12, 2010, 75 FR18652) to provide additional detail on definition offacility under this source category.•EPA requests comment on definition of facility butis not seeking further comment on other elementsof the initial proposal9Proposed Definition of Facility•EPA proposes to define “facility” for this subpartto mean an “electric power system”.•System: 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 an electric power entityusing the Energy Information Administration(EIA) list of examplesEIA Entities•A company•Electric cooperative•Public electric supply corporation, e.g. TVA•Federal Department, e.g. Bonneville•Bureau of Reclamation or Corp of Engineers•A jointly owned electric supply project, e.g.KeystoneREGGI: Alternate Definition•All assets and equipment used to transmit and distribute electricityfrom an electric generator to theelectrical load of a customer. Itincludes all related assets and equipment located within the serviceterritory of the entity, defined as the service territory of a load-servingentity specified by the applicable state regulatory agency.•EPA seeks comment on whether the RGGI definition includes thespectrum of entities identified inthe EIA list and captures the fulluniverse of SF6-emittingentities in the U.S.[1]Regional Greenhouse Gas Initiative Model Rule, 2008.Who Would Report?•Proposed threshold for reporting is 17,820 lbs. ofutility-wide SF6nameplate capacity•Proposed EPS source category includes thefollowing SF6or PFC containing equipment(transmission and distribution):–gas-insulated substations–circuit breakers and other switchgear–gas-insulated lines–power transformers–Plus: cylinders, gas carts,Proposal forCalculating Emissions•Emissions would be calculated for the entire utilityusing the following mass balance formula:3⁄4Emissions = (decrease in SF6inventory) + (acquisitions ofSF6) – (disbursements of SF6) – (Net Increase in TotalNameplate Capacity of Equipment Operated)•Same methodology as Partnership•PFC emissions calculation would also be requiredusing same equationMonitoring and QA/QC Requirements•Proposed QA/QC:–Review inputs to emission calculation to ensure allinputs/outputs included–Ensure all additions including SF6purchased from OEMsand SF6returned from off-site recycling are accounted foramong the additions to inventory.–Do not enter negative inputs, confirm no negativeemissions–Ensure beginning-of-year inventory matches end-of-yearinventory from previous yearMonitoring and QA/QC RequirementsContinued•Proposed QA/QC methods throughout the year:–Weigh all cylinders sent off-site•using scales certified to be accurate and precise to within 1%of the true weight and recalibrated per manufacturer specs.–Track and weigh all cylinders as they leave and enter storage•using scales within 1% of the true weight and recalibrated atleast annually or minimumfrequency per manufacturerspecs.–Ensure all substations have provided information tomanager compiling the emissions report (if not alreadyhandled through an electronic inventory system)Proposed Data Reporting Requirements•Nameplate capacity of all equipment at beginning of year, newequipment purchased and equipment retired during the year•Transmission miles (>34.5 kV)•SF6and PFCs sales and purchases•SF6and PFCs sent off-site (destruction, recycling, or return tosuppliers)•SF6and PFCs returned from off-site after recycling•SF6and PFCs stored in containersat the beginning and end of year•SF6and PFCs with or inside new equipment purchased in the year orsold equipment•If required, missing data could bereplaced by data from similarequipment with similar nameplate capacity17Electrical Equipment Manufactureor Refurbishment~Subpart SS~18Proposed Definition of SourceCategory and ReportingThreshold•Electrical equipment manufacturers and refurbishers ofSF6or 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 ofSF6and PFC exceed 23,000 lbs.3⁄4Equivalent to an emissions-based threshold of 25,000 MTCO2Eq.19Proposed Monitoring Methods•Mass-balance approach similar to the 2006 IPCCGuidelines Tier 3 methods3⁄4Emissions of SF6and 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 equation20Installation•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 installation?3⁄4How to capture the overcharge inuser emissions (subpart DD)?21Imports and Exports ofFluorinated GHG Inside PreCharged Equipment and ClosedCell Foams~Subpart QQ~Imports and Exports of Precharged Equipment Containing FGHGs•Includes all SF6-containing equipment•Threshold: imports or exports at the corporatelevel contained a total of 25,000 metric tons ofcarbon dioxide equivalent (mtCO2e) or more offluorinated GHGs•Why? Source estimated to be 10% of fluorinatedGHG supply23For 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.Discussion Items•Definition of facility–Good fit?•Installation of equipment–Scenarios of ownership transfer•Perfluorocarbon (PFC) transformers–PFCs used as substitute for CFCs–Anybody have any?