EPA Releases FAQs Addressing Subpart DD Issues

On March 20, 2012, EPA posted 10 new frequently asked questions (FAQs) that provide answers to common questions regarding Subpart DD (Electrical Transmission and Distribution Equipment Use) reporting including:

  • Q641. Our utility owns power plants that are subject to Part 98 subpart D and 100-150 substations. Do we report SF6 and PFC emissions under subpart DD as a separate facility or together?
  • Q642. Our facility owns SF6- or PFC-containing equipment, but we are not an electric power transmission or distribution entity as defined in 98.308. Are we required to report emissions under subpart DD?
  • Q643. Our power plant is subject to Part 98 subpart D and has a substation located on site. Do we report SF6 and PFC emissions from the substation under subpart DD? If so, would the SF6 and PFC emissions be reported under the same report as the subpart D emissions or as a separate report?
  • Q644. At what point during the year does the reporting threshold apply for subpart DD?
  • Q645. Does equipment that has been sent out for reconditioning (not on-site) count toward the subpart DD threshold?
  • Q646. Our facility has SF6 gas cylinders. Do we include those in reporting under subpart DD?
  • Q647. Is BAMM available for a facility that is subject to subpart DD and began data collection in 2011?
  • Q648. Is BAMM available for a facility that first became subject to subpart DD and began data collection in reporting year 2012?
  • Q649. Hermetic seals should not leak. Do we include the quantity of SF6contained in hermetically sealed equipment when determining applicability under subpart DD?
  • Q650. We are a registered Subpart D facility that reported for reporting year 2010. For reporting year 2011, we also are subject to Subpart DD because we exceed the reporting threshold. Are we allowed to report our Subpart D GHG emissions now and then report the Subpart DD GHG emissions when the reporting tool becomes available?

To view these and other FAQs, please visit the Greenhouse Gas Reporting Program FAQ site at: http://www.ccdsupport.com/confluence/display/faq.

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