Monitoring, Reporting, and Reducing SF6 Emissions from the U. S Monitoring, Reporting, and Reducing SF6 Emissions from the U.S. Electric Transmission and Distribution Sector: A Look at EPA Regulations and Voluntary Initiatives Past and Present November 15, 2016 Presented at 2016 Dilo’s SF6 Gas Management Seminar Mollie Averyt, ICF

Voluntary Emissions Reduction Program Kapiteleinführung

Public-Private Partnership SF6 Emission Reduction Partnership for Electric Power Systems Sulfur Hexafluoride Dielectric, effective insulator and/or arc quenching medium The most potent fluorinated greenhouse gas 22,800 times more potent than CO2 Extremely long atmospheric lifetime of 3,200 years Public-Private Partnership Formed in 1999 between EPA and 48 Charter Partners Designed to cost-effectively reduce SF6 emissions from electrical transmission operations Partners set emission reduction goals and annually report progress (emissions). Partners are encouraged to implement practices that are economically and technically feasible Currently 90 Partner utilities representing approximately 46-48% of total U.S. grid Kapiteleinführung

Benefits to joining the Partnership Create a record of voluntary reductions & establish and improve SF6 gas inventory tracking methods Be recognized by EPA as an environmental leader among your peers Build network with industry peers and draw upon others’ experiences and successes in reducing SF6 emissions Experience improved system reliability Save money and increase operational efficiency Earn customer confidence & trust Kapiteleinführung

2017 Workshop on SF6 Emission Reduction Strategies Kapiteleinführung

Common Methods Partners are Implementing to Reduce SF6 Emissions Systematic operations and inventory tracking Cylinder management SF6 gas recycling cart use Equipment leak detection and repair Equipment upgrades and replacement of old equipment Training employees in best management practices to handle, manage, and monitor SF6 Learning new strategies from the experiences of other Partners! Kapiteleinführung

Estimating Emissions using the Mass-Balance Method Change in Storage Inventory Purchases/Acquisitions Sales/Disbursements Change in Nameplate capacity Tracking gas flows using the mass balance method will account for potential emission sources: Poor gas handling practices Leakage from SF6-containing equipment describe principle of mass-balance approach: account for all additions, subtractions, and uses of gas; what's left is emissions. Kapiteleinführung

Partnership Accomplishments 75 percent decrease in SF6 emissions of Partners since 1999 Cumulative reductions of 6.1 million pounds of SF6 (compared to holding 1999 levels constant) Equivalent to removing 13.2 million passenger cars of the roads for one year 85 percent decrease in emissions rate (emissions/nameplate capacity) since inception Summary of Absolute Partnership SF6 Emission Reductions   1999 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Total Partner-Reported SF6 Emission (lbs) 775,868 496,434 413,300 348,633 305,273 318,505 293,742 235,633 207,181 205,200 214,648 196,194 Total Partner-Reported SF6 Emission (MMTCO2e) 8.02 5.13 4.27 3.61 3.16 3.29 3.04 2.44 2.14 2.12 2.22 2.03 Reduction from 1999 (lbs) 279,433 362,568 427,235 470,595 457,363 482,126 540,235 568,687 570,668 561,219 579,674 Reduction from 1999 (MMTCO2e) 2.89 3.75 4.42 4.87 4.73 4.99 5.59 5.88 5.90 5.80 5.99 Percent Reduction from 1999 36% 47% 55% 61% 59% 62% 70% 73% 74% 72% 75% Note: Historical estimates have been updated based on the estimation methodology used by EPA and data made available by Partners. Kapiteleinführung

Partner Accomplishments 2015 SF6 Partnership Emission Rate: 1.9%

Federal Reporting Program

The Greenhouse Gas Reporting Program Annual Reporting Program 41 source categories, accounting for about 85-90% of U.S. GHG emissions Reporting Threshold of 25,000 metric tons CO2 equivalent (CO2e) or more per year for most sources Direct reporting to EPA electronically EPA verification of GHG data

Subparts DD and SS of 40 CFR Part 98 Subpart DD Electrical Transmission and Distribution Equipment Use Reporting threshold: system nameplate capacity of 17,820 pounds or greater. Subpart DD facility emissions account for an estimated 67% of national emissions from this source category. Subpart SS Electrical Equipment Manufacture or Refurbishment Reporting threshold: total annual purchases of SF6 and PFCs that exceed 23,000 pounds. Subpart SS facility emissions account for an estimated 66% of national emissions from this source category. (a) You must report GHG emissions from an electric power system if the total nameplate capacity of SF6 and PFC containing equipment (excluding hermetically sealed-pressure equipment) located within the facility, when added to the total nameplate capacity of SF6 and PFC containing equipment (excluding hermetically sealed-pressure equipment) that is not located within the facility but is under common ownership or control, exceeds 17,820 pounds and the facility meets the requirements of §98.2(a)(1).

Calculating GHG Emissions Subpart DD – Eq. DD-1 User Emissions = (Decrease in Storage Inventory) + (Acquisitions) – (Disbursements) – (Net increase in Total Nameplate Capacity of Equipment Operated) The net change of nameplate capacity is determined by taking the nameplate capacity of new equipment and subtracting the nameplate capacity of retiring equipment Subpart SS – Eq. SS-6 Emissions from Equipment Installation = (Total Mass used to Fill Equipment) + (Total Mass used to charge Equipment Prior to Leaving the Manufacturer Facility) – (Total Nameplate Capacity Installed at Electric T&D Facility)

Force Majeure Events Question: Sometimes SF6 is emitted or destroyed due to a lightning strike or fire or there is a major storm that causes catastrophic loss of SF6 gas from substations; should these emissions be reported? Response: Emissions of SF6 that occur from a force majeure event are required to be reported under Subpart DD. The mass-balance monitoring methods required for Subpart DD are designed for a system-wide emissions measurement and are not intended for use in measuring emissions occurring from specific events affecting specific pieces of equipment. The objective of program is to collect emissions data; the regulation does not penalize facilities based on the quantity of their emissions. Nevertheless, systems are free to keep their own records of emissions of SF6 attributable to force majeure events. Only current mechanism for EPA to get details on why emissions increased/decreased dramatically would be through the CT process. EPA might contact facilities if there was a large change increase in emissions for the year. One of these events is recognized as a plausible explanation/response.

Subpart DD Proposed Revisions Report total miles of transmission and distribution lines in each state and total miles for electric power system. When reporting the quantities of equipment installed and retired each year (nameplate capacities and numbers of pieces), distinguish between hermetically sealed equipment and other equipment. FR Notice: 81 FR 2536 January 15, 2016 https://www.gpo.gov/fdsys/pkg/FR-2016-01-15/pdf/2015-32753.pdf COMMENT PERIOD WAS EXTENDED TO 3/15/2016 Goal of first change is to try to understand emissions in each state (EPA often asked about this). Goal of second change is to try to understand emissions from different types of equipment. Rule has not been finalized yet; EPA is considering comments and expects to publish the final rule by the end of the calendar year.

Subpart DD Reported Data at a Glance 2011 2012 2013 2014 2015 Number of Reporters 123 121 118 105 Emissions (MMTCO2e) 3.92 3.22 3.27 3.15 2.73 Annual Emission Changes -17.7% +1.4% -3.7% -13.5% Total Emission Changes -16.6% -19.7% -30.5% Over the five years of the reporting program, there has been a 30.5 percent reduction in emissions The highest emitters* reduced emissions by more than all reporters combined between 2011 and 2015. 3-year opt-out provision 5-year opt-out provision * The highest emitters are defined as the subset of reporters who were the top 10% emitters in 2011. This group was held constant between 2011 and 2015 and their reductions were tracked accordingly.

Subpart SS Reported Data at a Glance 2011 2012 2013 2014 2015 Number of Reporters 6 7 Emissions (MMTCO2e) 0.35 0.18 0.20 0.16 Annual Emission Changes -49.2% +12.9% +1.8% -21.3% Total Emission Changes -42.7% -41.6% -54.1% Over the five years of the reporting program, there has been a 54.1 percent reduction in emissions Almost all of the emission reductions attributed to one reporter between the first and second year of reporting

Comparative Analysis

Early-reported GHGRP Reported Data and Partnership Data Many GHGRP reporters were previously reporting F-GHG emissions voluntarily to the EPA for more than a decade Compare the emission reductions observed over the life of the GHGRP to those observed over the lives of various voluntary emission reduction Partnerships Key Findings: The largest reductions can be attributed to largest emitters. Partners have continued to reduce their emission rate. Non-Partners contribute more to emission reductions than would be expected based on their activity levels and emissions. Partners GHGRP Reporters Analysis completed in late 2014 that investigated the potential reasons for trends observed in GHGRP emissions over three years of reporting (2011 through 2013)

Mollie Averyt Mollie.Avery@icf.com 202.862.1569 Thank you. Helpful links: Partnership homepage: www.epa.gov/f-gas-partnership-programs/electric-power-systems-partnership 2017 Workshop page (and registration page): www.epa.gov/f-gas-partnership-programs/2017-workshop-sf6-emission-reduction-strategies EPA’s GHGRP: https://www.epa.gov/ghgreporting Thank you. Mollie Averyt Mollie.Avery@icf.com 202.862.1569