Proposed Rule: Mandatory Reporting of Greenhouse Gas EmissionsMeeting DocumentationDateStaffContactInformation(Name, email,phone #)Name ofOrganization(Attach list ofall attendeesnames andemails ifpossible)Summary of Discussion (e.g., applicability, reportingrequirements, etc.)Written CommentsProvided?Did they alsosubmit to Docket?Date sent to EPACCD6/24/08PhoneCorrespondencePaul Stewart, ICFInternational,pstewart@icfi.com202-862-1135on behalf of EPAunder ContractEP-W-07-068,Task Order 23Phil BolinMitsubishi724-778-5235724-493-29211.We have assumed that the only equipment thatwould be imported or exported with a nominalcharge of SF6 would be high-voltage circuitbreakers between 72 and 345 kV. Is this anaccurate assumption?What equipment wouldwe not be capturing with this assumption andhow much would this remaining equipmentrepresent?Yes, circuit breakers between 72 and 345 kVwould represent most of the gas insulatedequipment being imported and exported. 345 isborderline. We are shipping some 345 kVassembled and with a nominal charge, but thissize would not be exported because thisequipment is too large. GIS is also beingimported but not exported since it isn’t producedin the U.S.All GIS being used in the states is imported.There is bus gear for GIS that is made within theUnited States, but this accounts for relativelylittle SF6 use.The gas-insulated lines produced by somecompanies would not contain a nominal charge ofSF6. They are shipped with dry nitrogen.2.How many circuit breakers between 72 to 345kV do you think are imported every year?Does 10,000 sound correct? What percent ofthem have a nominal charge of SF6?No, it is definitely not 10,000. I would estimatethat about 1,000 GIS and CBs are importedN/AN/Aannually. About 2/3 of this number is CBs andabout 1/3 is GIS.About 30% of the CBs would have a nominalcharge, and about 20% of the GIS would have anominal charge.3.How many circuit breakers between 72 and 345kV do you think are exported every year?What percent of them have a nominal chargeof SF6?More CBs are exported than imported. About1,000 breakers exported with nominal charge. Iwould say that is a reasonable number. GIS isn’texported because it isn’t produced here.4.Would it be accurate toestimate the nominalcharge at 20% of nameplate capacity?Yes, I stand by 20% of nameplate capacity.People who say less might not be considering thedistinction between gauge and atmosphericpressure.5.When equipment is imported and exported, is itever shipped with SF6 alongside of it incylinders? Would the amount shipped incylinders be equal to the breaker’s nameplatecapacity? What percentof breakers shippedwould have SF6 alongside of it?It depends on the situation. Much of it has to dowith habit. There tends to be a higher percentageof exported breakers shipped with cylinders thanimported breakers shipped with cylinders. Thereason is that much of our exports go to thedeveloping world, where it is hard to obtain SF6gas. Although we have shipped SF6 alongsidebreakers to England.6.From our previous conversation, weunderstand that most gas-insulated electricalequipment produced in the United States ismanufactured by fivecompanies. Whatpercent of all the SF6 used by OEMs in theU.S. is used by these five (would you say70%)? Do you think they are also responsiblefor (x percent) of exports, or does size ofmarket share in the U.S. not correlate wellwith share of exports?For example, if acompany is exporting a lot of gas-insulatedtransmission lines, would they be responsiblefor a higher share of exports than would beexpected from their total domestic productionof gas-insulated electrical equipment relativeto the big five manufacturers?70% sounds correct. I would expect that domesticmarket share is roughlycorrelated to import andexport levels.