Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation Date Staff Contact 

Information (Name, email, phone #) 

Name of Organization (Attach list of all attendees names and emails if possible) 

Summary of Discussion (e.g., applicability, reporting requirements, etc.) 

Written Comments Provided? Did they alssubmit to D

6/24/08 Email Correspondence 

Paul Stewart, ICF International, pstewart@icfi.com 202-862-1135 on behalf of EPA under Contract EP-W-07-068, Task Order 23 

Rich York ABB rich.york@us.abb.com 

1. We have assumed that the only equipment 

that would be imported or exported with a nominal charge of SF6 would be highvoltage circuit breakers between 72 and 345 kV. Is this an accurate assumption? What equipment would we not be capturing with this assumption and how much would this remaining equipment represent? Yes, it would be safe to say that circuit breakers between 72 and 345 kV represent all gas-insulated equipment that would be imported or exported with a nominal charge of SF6 since breakers above 345 are never shipped with SF6 and breakers below are 72 usually do not contain SF6. However, any given breaker within the 72 to 345 range might or might not be shipped with a nominal charge. Breakers are only shipped with SF6 when they are fully assembled. Sometimes exported equipment is broken down into pieces so the equipment fits better into containers. This is often the logical thing to do because shippers charge by volume rather than weight, and a large portion of the circuit breakers volume is air. By disassembling the equipment into pieces, the exporter can reduce shipping costs. The only time equipment is shipped with a nominal charge is when the contract specifically states that the equipment needs to be delivered in a ready-to-use condition 

N/A 
where you just need to plug in the wires. 

2. We have heard that some companies 

export a large amount of their gasinsulated transmission lines. Would these lines be shipped with a nominal charge? I have no idea. 

3. How many circuit breakers between 72 to 

345 kV do you think are imported every year? What percent of them have a nominal charge of SF6? I have no idea. We actually do not import anything. We construct all of our electrical equipment here in the United States. 

4. We have heard that about 10,000 breakers 

between 72 and 345 kV are imported every year. Does this sound correct? That sounds ridiculously high. I would guess that fewer than 1,000 breakers between 72 and 345 kV are imported every year, and a fraction of those would actually contain a nominal charge of SF6. 

5. How many circuit breakers between 72 

and 345 kV do you think are exported every year? What percent of them have a nominal charge of SF6? I don’t know. I know how much we export, but that is proprietary. 

6. That’s fine, but we need to make an 

estimate for the industry as a whole, and our current estimate is 40,000, does this sound correct. 40,000 sounds outrageously high. That doesn’t even sound close. I would estimate that the total worldwide production of breakers is 40,000. 

7. When you say breakers, do you mean 

breakers in between 72 and 345 kV? Yes, I know ABB’s production and I know our market share and that leads me to believe that global production would be 
about 40,000. 

8. Would it be accurate to estimate the 

nominal charge at 20% of nameplate capacity? No, shipping pressure is limited to 5 PSI, which would be less than 5% of nameplate capacity. These shipping charges are the same for domestic and international shipping. In a 72 breaker, 5 PSI might be 5-10% of nameplate capacity, but for a 345 kV breakers it would be below 5%. 

9. When equipment is imported and 

exported, is it ever shipped with SF6 alongside of it in cylinders? Would the amount shipped in cylinders be equal to the breaker’s nameplate capacity? What percent of breakers shipped would have SF6 alongside of it? Depends on the contract with the customer. I wouldn’t think that bulk SF6 is shipped alongside equipment very often in international shipping situations because shipping restrictions on pressurized gas make it burdensome. 

10. From our previous conversation, we 

understand that most gas-insulated electrical equipment produced in the United States is manufactured by 5 large OEMs. What percent of all the SF6 used by OEMs in the U.S. is used by these big five (would you say 70%)? Do you think they are also responsible for (x percent) of exports, or does size of market share in the U.S. not correlate well with share of exports? For example, if a particular company is exporting a lot of gasinsulated transmission lines, would they be responsible for a higher share of exports than would be expected from 
their total domestic production of gasinsulated electrical equipment relative to 

the big five manufacturers? I am not sure. If you are asking about the share of SF6 consumed by the largest five OEMs compared to the SF6 consumed by all OEMs, 70% generally sounds right. It doesn’t sound unreasonable to me. 90% would be too high, and if you said 30% I would say that something is wrong with the number. I have no idea about how much other OEMs export.