Proposed Rule: Mandatory Reporting of Greenhouse Gas EmissionsMeeting DocumentationDateStaffContactInformation(Name, email,phone #)Name of Organization(Attach list of allattendees names andemails if possible)Summary of Discussion (e.g., applicability, reportingrequirements, etc.)WrittenCommentsProvided?Did they alsosubmit to Docket?Date sent toEPA- CCD6/24/08EmailCorrespondencePaul Stewart, ICFInternational,pstewart@icfi.com202-862-1135on behalf of EPAunder ContractEP-W-07-068,Task Order 23Rich YorkABBrich.york@us.abb.com1.We have assumed thatthe only equipmentthat would be imported or exported witha nominal charge of SF6 would be highvoltage circuit breakers between 72 and345 kV. Is this an accurate assumption?What equipment would we not becapturing with this assumption and howmuch would this remaining equipmentrepresent?Yes, it would be safe to say that circuitbreakers between 72 and 345 kV representall gas-insulated equipment that would beimported or exported with a nominal chargeof SF6 since breakers above 345 are nevershipped with SF6 and breakers below are 72usually do not contain SF6.However, any given breaker within the 72to 345 range might or might not be shippedwith a nominal charge. Breakers are onlyshipped with SF6 when they are fullyassembled. Sometimes exported equipmentis broken down into pieces so the equipmentfits better into containers. This is often thelogical thing to do because shippers chargeby volume rather than weight, and a largeportion of the circuit breakers volume is air.By disassembling the equipment into pieces,the exporter can reduce shipping costs. Theonly time equipment is shipped with anominal charge is when the contractspecifically states thatthe equipment needsto be delivered in a ready-to-use conditionN/AN/Awhere you just need toplug in the wires.2.We have heard that some companiesexport a large amount of their gasinsulated transmission lines. Would theselines be shipped with a nominal charge?I have no idea.3.How many circuit breakers between 72 to345 kV do you think are imported everyyear? What percent of them have anominal charge of SF6?I have no idea. We actually do not importanything. We construct all of our electricalequipment here in the United States.4.We have heard that about 10,000 breakersbetween 72 and 345 kV are importedevery year. Does this sound correct?That sounds ridiculously high. I wouldguess that fewer than 1,000 breakersbetween 72 and 345 kV are imported everyyear, and a fraction of those would actuallycontain a nominal charge of SF6.5.How many circuit breakers between 72and 345 kV do you think are exportedevery year? What percent of them have anominal 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 anestimate for the industry as a whole, andour current estimate is 40,000, does thissound correct.40,000 sounds outrageously high. Thatdoesn’t even sound close. I would estimatethat the total worldwide production ofbreakers is 40,000.7.When you say breakers, do you meanbreakers in between 72 and 345 kV?Yes, I know ABB’s production and I knowour market share and that leads me tobelieve that global production would beabout 40,000.8.Would it be accurate to estimate thenominal charge at 20% of nameplatecapacity?No, shipping pressure is limited to 5 PSI,which would be less than 5% of nameplatecapacity. These shipping charges are thesame for domestic and internationalshipping. In a 72 breaker, 5 PSI might be 5-10% of nameplate capacity, but for a 345kV breakers it would be below 5%.9.When equipment is imported andexported, is it ever shipped with SF6alongsideof it in cylinders? Would the amountshipped in cylinders be equal to thebreaker’s nameplate capacity? Whatpercent of breakers shipped would haveSF6 alongside of it?Depends on the contract with the customer.I wouldn’t think that bulk SF6 is shippedalongside equipment very often ininternational shipping situations becauseshipping restrictions on pressurized gasmake it burdensome.10.From our previous conversation, weunderstand that most gas-insulatedelectrical equipment produced in theUnited States is manufactured by 5 largeOEMs. What percent of all the SF6 usedby OEMs in the U.S. is used by these bigfive (would you say 70%)? Do you thinkthey are also responsible for (x percent)of exports, or does size of market share inthe U.S. not correlate well with share ofexports? For example, if a particularcompany is exporting a lot of gasinsulated transmission lines, would theybe responsible for a higher share ofexports than would be expected fromtheir total domesticproduction of gasinsulated electrical equipment relative tothe big five manufacturers?I am not sure. If you are asking about theshare of SF6 consumed by the largest fiveOEMs compared to the SF6 consumed byall OEMs, 70% generally sounds right. Itdoesn’t sound unreasonable to me. 90%would be too high, and if you said 30% Iwould say that something is wrong with thenumber. I have no idea about how muchother OEMs export.