U.S. EPA’s Proposed 

Amendment to the Greenho

Gas Mandatory Reporting 

(75 FR 18652, April 12, 201

SF6 Partners Meeting

May 13, 2010

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

charged with Fluorinated G
Presentation not a subst

reading the Proposed 

• This presentation is intended to assist rep

facilities/owners in understanding key provproposed rule. However, it is not intended substitution for the proposal (75 FR 186522010). 

• If there are any inconsistencies with mater

here and the rule, defer to what’s in the ru

• Asking a question on this presentation is n

as submitting public comment. Please see or preamble for information on how to subcomments.
Mandatory Reporting Rule: Status 

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

– All greenhouse gases – Report on “Upstream” and “Downstream” sou– 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 October 3Final Rule

• Annual reporting of GHG by:

– 25 source categories– 5 types of suppliers of fuel and industrial G– Motor vehicle and engine suppliers (except 

sector)

• 25,000 metric tons CO2 e per year reporting th

sources; capacity-based thresholds where feas

• Estimated 10,000 facilities (85% of US emissio• Direct reporting to EPA electronically, system 

based

• EPA will conduct verification of the emissions • Excludes most small businesses and governme• MRR complements state programs; it is not in

replace or preclude them
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
Amendment to the Mandatory Reporting Rule

• Proposal signed March 22, 2010; 

published in Federal Register April 12, 

• 60 day public comment period ends Ju• Goal is reporting for calendar year 2011 • Includes three sources or suppliers of S

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

fluorinated greenhouse gases
Electric Transmissio

Distribution Equipme

~Subpart DD~
Background 

• First proposed on April 12, 2009 (74 FR 

– Received comments from 22 entities – General support for threshold, method, moni– Needed clarification on definition of “facility”

• Supplemental proposal (April 12, 2010, 

18652) to provide additional detail on dfacility under this source category.

• EPA requests comment on definition of 

is not seeking further comment on otheof the initial proposal 
Proposed Definition of Facilit

• EPA proposes to define “facility” for 

to mean an “electric power system”.

• System: the collection of SF6- and P

equipment linked through electric ptransmission or distribution lines anan integrated unit by one electric poseveral entities that have a single ow

• EPA proposed to define an electric p

using the Energy Information Admi(EIA) list of examples
EIA Entities

• A company• Electric cooperative• Public electric supply corporation, e• Federal Department, e.g. Bonneville• Bureau of Reclamation or Corp of E• A jointly owned electric supply proje

Keystone
REGGI: Alternate Definitio

• All assets and equipment used to transmit and dis

from an electric generator to the electrical load of includes all related assets and equipment located territory of the entity, defined as the service territentity specified by the applicable state regulatory 

• EPA seeks comment on whether the RGGI definit

spectrum of entities identified in the EIA list and universe of SF6-emitting entities in the U.S. [1] Regional Greenhouse Gas Initiative Model Rul
Who Would Report?

• Proposed threshold for reporting is 17,

utility-wide SF6 nameplate capacity

• Proposed EPS source category includes 

following SF6 or PFC containing equip

(transmission and distribution): 

– gas-insulated substations– circuit breakers and other switchgear– gas-insulated lines – power transformers– Plus: cylinders, gas carts, 
Proposal for 

Calculating Emissions

• Emissions would be calculated for the e

using the following mass balance formu

3⁄4 Emissions = (decrease in SF6 inventory) + (

SF6) – (disbursements of SF6) – (Net Increa

Nameplate Capacity of Equipment Operated

• Same methodology as Partnership• PFC emissions calculation would also be 

using same equation
Monitoring and QA/QC Requirem

• Proposed QA/QC:

– Review inputs to emission calculation to e

inputs/outputs included

– Ensure all additions including SF6 purcha

and SF6 returned from off-site recycling a

among the additions to inventory.

– Do not enter negative inputs, confirm no n

emissions

– Ensure beginning-of-year inventory match

inventory from previous year
Monitoring and QA/QC Requirem

Continued

• Proposed QA/QC methods throughout t

– Weigh all cylinders sent off-site

• using scales certified to be accurate and pre

of the true weight and recalibrated per man

– Track and weigh all cylinders as they leave a

• using scales within 1% of the true weight an

least annually or minimum frequency per mspecs.

– Ensure all substations have provided inform

manager compiling the emissions report (if nhandled through an electronic inventory syst
Proposed Data Reporting Require

• Nameplate capacity of all equipment at beginning o

equipment purchased and equipment retired durin

• Transmission miles (>34.5 kV)• SF6 and PFCs sales and purchases

• SF6 and PFCs sent off-site (destruction, recycling, o

suppliers)

• SF6 and PFCs returned from off-site after recycling

• SF6 and PFCs stored in containers at the beginning 

• SF6 and PFCs with or inside new equipment purch

sold equipment 

• If required, missing data could be replaced by data 

equipment with similar nameplate capacity
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 equ

sealed-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 SF

6 and PFCs would be es

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
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 capture the overcharge in user emissio
Imports and Export

Fluorinated GHG Insi

Charged Equipment an

Cell Foams

~Subpart QQ~
Imports and Exports of Precharged Equipment Containin

GHGs

• Includes all SF6-containing equipm• Threshold: imports or exports at the 

level contained a total of 25,000 mecarbon dioxide equivalent (mtCO2e) fluorinated GHGs 

• Why? Source estimated to be 10% o

GHG supply
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.
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?