Electric Transmission and Distribution

Equipment Use

SEPA

Subpart DD, Greenhouse Gas Reporting Program

United States
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Under Subpart DD, owners and operators of electric power system facilities with a total nameplate
capacity that exceeds 17,820 lbs (7,838 kg) of sulfur hexafluoride (SF6) and/or perfluorocarbons (PFCs)
must report emissions of SFe and/or PFCs from the use of electrical transmission and distribution
equipment. Owners and operators are required to collect emissions data, calculate GHG emissions, and
follow the specified procedures for quality assurance, missing data, recordkeeping, and reporting per the
requirements of 40 CFR Part 98 Subpart DD - Electric Transmission and Distribution Equipment Use.

How Is This Source Category Defined?

The electrical transmission and distribution equipment use source category consists of all electric
transmission and distribution equipment and servicing inventory insulated with or containing SF6 or PFCs
used within an electric power system. This equipment includes but is not limited to gas-insulated
substations; circuit breakers; switchgear, including closed-pressure and hermetically sealed-pressure
switchgear; gas-insulated lines containing SF6 or PFCs; gas containers such as pressurized cylinders; gas
carts; electric power transformers; and other containers of SF6 or PFC.

For the purposes of this subpart, facility is defined as the electric power system, comprising all electric
transmission and distribution equipment insulated with or containing SF6 or PFCs that is linked through
electric power transmission or distribution lines and functions as an integrated unit, that is owned,
serviced, or maintained by a single electric power transmission or distribution entity (or multiple entities
with a common owner), and that is located between (1) the point(s) at which electric energy is obtained
by the facility from an electricity generating unit or a different electric power transmission or distribution
entity that does not have a common owner, and (2) the point(s) at which the customer or another electric
power transmission or distribution entity that does not have a common owner receives the electric energy.
The facility also includes servicing inventory for such equipment that contains SF6 or PFCs.

What Greenhouse Gases Must Be Reported?

The rule requires that each electric power system facility must report total SF6 and PFC emissions
(including emissions from equipment leaks, installation, servicing, decommissioning, and disposal, and
from storage cylinders) from the following types of equipment:

•	Gas-insulated substations;

•	Circuit breakers;

•	Switchgear, including closed-pressure and hermetically sealed-pressure switchgear;

•	Gas-insulated lines containing SF6 or PFCs;

•	Gas containers such as pressurized cylinders;

•	Gas carts;

•	Electric power transformers; and

•	Other containers of SF6 or PFC

How Must Greenhouse Gas Emissions Be Calculated?

Under this rule, electric power system facilities must calculate SF6 and PFC emissions using a mass-
balance approach that takes into account the following:

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•	Decrease in SF6 Inventory. The SF6 stored in containers (but not in energized equipment) at the
beginning of the year minus the SF6 stored in containers (but not in energized equipment) at the
end of the year. These quantities must be measured using a scale that is accurate to within +/- 2
pounds of true weight, and the scale must be recalibrated periodically per manufacturer
specifications.

•	Acquisitions of SF6. The sum of the following:

o The amount of SF6 purchased from chemical producers or distributors in bulk,
o SF6 purchased from equipment manufacturers or distributors inside or alongside equipment

(including hermetically sealed-pressure equipment), and
o SF6 returned to the facility after off-site recycling.

•	Disbursements of SF6. The sum of the amount of SF6 in bulk and contained in equipment that is
sold to other entities, returned to suppliers, and sent off-site for recycling or destruction. Facilities
returning cylinders to storage or to the supplier must either weigh the cylinders themselves or
have the supplier weigh the cylinders, obtaining a detailed monthly account from the supplier.
The scale used to weigh these quantities (regardless of whether weighing is performed by the
electric power system facility or the supplier) must be accurate to within +/- 2 pounds of true
weight, and the scale must be recalibrated periodically per manufacturer specifications.

•	Net Increase in Total Nameplate Capacity of Equipment. The nameplate capacity of new
equipment (including hermetically sealed-pressure equipment) minus the nameplate capacity of
retiring equipment (including hermetically sealed-pressure equipment). Nameplate capacity refers
to the full and proper charge of gas within equipment as specified by the equipment manufacturer
rather than the actual charge, which may reflect leakage.

Using the parameters above, the electric power system facility must calculate emissions (in pounds) using
the following mass-balance equation:

Emissions =

Decrease in SF6 Inventory + Acquisitions of SF6 - Disbursements of SF6- Net Increase
in the Nameplate Capacity of Equipment

PFC emissions (e.g., from transformers that formerly used CFC-113) must be calculated in the same way,
substituting the PFC for SF6 in the equation above.

A checklist for data that must be monitored is available at: https://www.epa.gov/ghgreporting/electronic-
transmission-and-distribution-checklist

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each electric power
system must report the following information:

•	Nameplate capacity of equipment (pounds) containing SF6 and PFCs existing at the beginning of
the year (excluding hermetically sealed-pressure equipment).

•	Nameplate capacity of new hermetically sealed-pressure equipment (pounds) purchased during
the year and hermetically sealed-pressure equipment retired during the year.

•	Nameplate capacity of new equipment other than hermetically sealed-pressure equipment
(pounds) purchased during the year and equipment other than hermetically sealed-pressure
equipment retired during the year.

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•	The number of SF6- or PFC-containing pieces of equipment in each of the following equipment
categories: (1) New hermetically sealed-pressure switchgear during the year; (2) New equipment
other than hermetically sealed-pressure switchgear during the year; (3) Retired hermetically
sealed-pressure switchgear during the year; (4) Retired equipment other than hermetically sealed-
pressure switchgear during the year.

•	Transmission miles (length of lines carrying voltages above 35 kilovolt [kV]).

•	Distribution miles (length of lines carrying voltages at or below 35 kilovolt [kV]).

•	States and territories in which the facility lies.

•	SF6 and PFC stored in containers, but not in energized equipment, at the beginning of the year
(pounds).

•	SF6 and PFC stored in containers, but not in energized equipment, at the end of the year (pounds).

•	SF6 and PFC purchased in bulk from chemical producers or distributors (pounds).

•	SF6 and PFC purchased from equipment manufacturers or distributors with or inside equipment,
including hermetically sealed-pressure switchgear (pounds).

•	SF6 and PFC returned to facility after off-site recycling (pounds).

•	SF6 and PFC in bulk and contained in equipment sold to other entities (pounds).

•	SF6 and PFC returned to suppliers (pounds).

•	SF6 and PFC sent off-site for recycling (pounds).

•	SF6 and PFC sent off-site for destruction (pounds).

•	For any missing data, the parameters for which the data were missing, the substitute parameters
used to estimate emissions in their absence, and the quantity of emissions thereby estimated.

When and How Must Reports Be Submitted?

Annual reports must be submitted by March 31 of each year, unless the 31st is a Saturday, Sunday, or
federal holiday, in which case the reports are due on the next business day. Annual reports must be
submitted electronically using the electronic Greenhouse Gas Reporting Tool (e-GGRT). the GHGRP's
online reporting system. Additional information on setting up user accounts, registering a facility and
submitting annual reports is available at https://ccdsupport.com/confluence/.

When Can a Facility Stop Reporting?

There are several scenarios under which a facility may discontinue reporting. These scenarios are
summarized in the Subpart A Information Sheet as well as in an FAQ.

For More Information

For additional information on Subpart DD, visit the Subpart DP Resources webpage. For additional
information on the Greenhouse Gas Reporting Program, visit the Greenhouse Gas Reporting Program
Website, which includes information sheets on other rule subparts, data previously reported to the
Greenhouse Gas Reporting Program, training materials, and links to frequently asked questions.

This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the Greenhouse Gas
Reporting Program.

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