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 CommProvided? Did they also submit to Dock

6/24/08 Phone Correspondence 

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

Phil Bolin Mitsubishi 724-778-5235 724-493-2921 

1. We have assumed that the only equipment that 

would be imported or exported with a nominal charge of SF6 would be high-voltage 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, circuit breakers between 72 and 345 kV would represent most of the gas insulated equipment being imported and exported. 345 is borderline. We are shipping some 345 kV assembled and with a nominal charge, but this size would not be exported because this equipment is too large. GIS is also being imported but not exported since it isn’t produced in the U.S. All GIS being used in the states is imported. There is bus gear for GIS that is made within the United States, but this accounts for relatively little SF6 use. The gas-insulated lines produced by some companies would not contain a nominal charge of SF6. They are shipped with dry nitrogen. 

2. How many circuit breakers between 72 to 345 

kV do you think are imported every year? Does 10,000 sound correct? What percent of them have a nominal charge of SF6? No, it is definitely not 10,000. I would estimate that about 1,000 GIS and CBs are imported 

N/A 
annually. About 2/3 of this number is CBs and 

about 1/3 is GIS. About 30% of the CBs would have a nominal charge, and about 20% of the GIS would have a nominal charge. 

3. 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? More CBs are exported than imported. About 1,000 breakers exported with nominal charge. I would say that is a reasonable number. GIS isn’t exported because it isn’t produced here. 

4. Would it be accurate to estimate the nominal 

charge at 20% of nameplate capacity? Yes, I stand by 20% of nameplate capacity. People who say less might not be considering the distinction between gauge and atmospheric pressure. 

5. 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? It depends on the situation. Much of it has to do with habit. There tends to be a higher percentage of exported breakers shipped with cylinders than imported breakers shipped with cylinders. The reason is that much of our exports go to the developing world, where it is hard to obtain SF6 gas. Although we have shipped SF6 alongside breakers to England. 

6. From our previous conversation, we 

understand that most gas-insulated electrical equipment produced in the United States is manufactured by five companies. What percent of all the SF6 used by OEMs in the U.S. is used by these 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 company is exporting a lot of gas-insulated transmission lines, would they be responsible for a higher share of exports than would be expected from their total domestic production of gas-insulated electrical equipment relative to the big five manufacturers? 70% sounds correct. I would expect that domestic market share is roughly correlated to import and export levels.