EPA SF6: Proposed EPA Changes to SF6 Regulation and Subpart DD
SF6 is the greenhouse gas sulfur hexafluoride; it is 25,000 times more damaging to the environment than carbon dioxide (CO2). For a long time, smaller companies did not have an obligation to report on SF6 based on estimated leak rates if the nameplate capacity was under 17,820 pounds. However, a recent change to reporting triggers is reducing the threshold by 90%. This shift in EPA SF6 regulations makes many more companies liable for reporting.
What is EPA SF6?
Chemists Henri Moissan and Paul LeBeau create sulfur hexafluoride gas for the first time in Paris, France in 1901. The potential of the gas is explored in 1937 when GE starts experimenting with SF6 as an arc-quenching medium. The gas would later be massed produced, first by Allied Chemical Corp, and becomes popular in high-voltage switchgear in the 1960s. This gas is used in a variety of applications since its inception, including ocular surgery, Nike Air Shoes, sound-deadening windowpanes, shock absorbers, as well as many more applications.
SF6 has high atmospheric stability and ability to trap infrared radiation, which means it is far more potent at warming the earth’s atmosphere than CO2 over longer periods of time. In fact, it is estimated that, over a 100-year period, SF 6 is 23,500 times more effective at trapping infrared radiation than CO2, meaning that 1 kg of SF 6 has the same impact as 23,500 kg of CO2. Once in the atmosphere, it has an atmospheric lifetime of 3,200 years, which means it can accumulate without degrading for millennia to come.
SF6 has become popular due to our ability to use it in applications like renewable sources of energy; such as wind turbines, electric vehicles, and solar energy. This gas is colorless, odorless, and heavier than air (part of the reason leaks are harder to track). It is also non-flammable, which becomes helpful in industrial applications. Industrial uses include preventing fires in high-voltage electrical equipment and circuit breakers.
This type of electrical insulator — also known as switchgear — becomes more important as we install more renewable electric power systems. And as our focus shifts towards renewable energy, we are using an ever-increasing amount of this gas. A recent study done in the UK finds that worldwide we are expecting to use 75% more of this gas by 2030.
In order to reduce the continued use of SF6 and the potential damage this potent greenhouse gas can have on our planet, government agencies and companies are taking a proactive approach to nudging companies in the right direction.
The EPA SF6 regulatory environment
Climate change is putting significant pressure on government agencies and companies to be responsible for the chemicals that are being used in industrial processes and the effect they have on global warming. ]
EPA SF6 regulations are shifting in these ways:
- The EPA is now suggesting a new approach that asks companies to have a total understanding of their emissions from sources including generators, natural gas, SF6, and other energy sources.
- If that number of total emissions is 25,000 tons combined, they have to produce records that validate their emissions.
- With these changes, it is now up to the individual company to determine what their greenhouse gas emissions are for all sources.
- And if all of their emissions combined are greater than 25,000 metric tons, they must themselves make a determination if they are required to report.
EPA SF6 regulations and Subpart DD
In the past, electric utilities simply looked at their installed nameplate of SF6, and if the capacity was under 17,820 pounds then they would know instantly they did not have to report.
Now, the EPA is proposing that every company must run an emissions calculation (DD-3) to determine their actual emissions from SF6 and other PFC’s. If their emissions are equal to 25,000 mtCO2e or greater, then they must report. If you don’t have a system tracking the variables in the DD-3 equation, it is impossible to prove to the EPA that you either do or do not have to report under 40 CRF Part 98.
This means that companies that have SF6 containing assets must now work on actively tracking and calculating emissions from all on site emissions sources. In order for them to prove that their gross emissions are under 25,000 mtCO2e; and therefore prove that they do not need to report under 40 CRF Part 98.
This validates the stance Trakref has had since the beginning: track everything. The pattern of legislation around greenhouse gasses indicates that the requirements will only become increasingly granular from here on.
Changes for Non-Electric Utilities
Traditionally, users of SF6 that are not electric power systems (non-utilities) did not have to worry about tracking SF6 if their emissions are under the 17,820 pound threshold based on installed nameplate capacity. Now, the EPA is proposing that these users of SF6 (Data Centers, Large Manufacturers, etc) must do the following:
- Calculate emissions from SF6 containing assets;
- Calculate emissions from stationary fuel combustion units, miscellaneous uses of carbonate, and all other applicable source categories that are listed in Table A–3 and Table A–4;
- Determine if the gross emissions from all of the above sources is greater then 25,000 mtCO2e;
- If the gross combined emissions is greater then 25,000 mtCO2e, then the company would be required to report under 40 CRF Part 98 (even if their installed nameplate capacity is less then 17,820 pounds).
In short, you have to prove your work, and keep clear records; whether or not you have to report.
Companies must track everything.
What can you do to manage these EPA SF6 changes?
Proper SF6 management includes:
- Improving accountability and documentation
- Training of field personnel to ensure zero loss during any gas handling event
- Traceability of events including Emergent Loss events, leaking GIE, Repair/Replacement of leaking GIE
- Equipment upgrades to recovery equipment which allows for zero emission practices
- Scale calibration and Mass Flow Meter implementation
- Installing self sealing fittings that are zero emission
- Improving leak detection processes
- Cylinder accountability
- MFG improvements of GIE with <1% annual leakage rate
- Improving Maintenance Programs
How Trakref can help with new EPA SF6 regulations
History shows that the pattern of increasing reporting requirements will continue. There is currently a huge emphasis by international organizations to develop consistency in the way these gases are handled and to increase the effectiveness of climate programs. Donning blindfolds is no longer an option. We must assess the risk, find alternatives to toxic gases, and be responsible for our use of materials in production.
How we operationalize compliance
If you are looking for a partner in refrigerant tracking, with experience with government regulations management, turn to Trakref. We have been in the regulatory compliance software and environmental compliance calendar software space for years. As a refrigerant rules engine and environmental company, we make sure our refrigerant capabilities will help you in your journey towards sustainability, including with SF6 gas and the recent proposed regulation changes.
Trakref can help with EPA SF6 regulations too
- Track cylinder history & use
- Provide push-button access to Subpart DD reports
- Measure installed gas capacity
- Incorporate wide leak rates
- Cylinder rental/history/use/locator
- Service event transaction report
Schedule a demo now to see how you can speed reports, streamline work, and bring an end to useless inaccurate spreadsheets with Trakref.
We are refrigerant geeks with proven techniques to manage leaks in our HVAC/R and refrigerant management software.