Proposed Rule: Mandatory Reporting of Greenhouse Gas EmissionsMeeting DocumentationDateStaff ContactInformation (Name,email, phone #)Name ofOrganization(Attach list of allattendees namesand emails ifpossible)Summary of Discussion (e.g., applicability, reporting requirements,etc.)WrittenCommentsProvided?Did theyalso submitto Docket?Date sent toEPA- CCDEmail &telephonecorrespondencefrom6/4/10 –6/22/10Mollie Averyt, ICFInternational, 202-862-1569maveryt@icfi.comon behalf of EPAunder Contract EPW-07-068, TaskOrder 68LukasRothlisberger,Dilo727-232-0050lukasr@dilo.comTopic: Under Subpart SS, there is a concern regarding thedisbursement input of the mass balance approach. Typicallymanufacturers would enter the quantity of gas that was disbursedfrom the cylinder and into the breaker. However, if there was anemission during the transfer of the gas, it would be counted as adisbursement rather than an emission – thereby underestimatingemissions. EPA is examining a variety of ways to accuratelydetermine the amount of SF6(or PFC) filled into new equipmentbefore that equipment is shipped out to customers including eitherengineering methods on the transfer of the gas or very precisemeasurement of the equipment’s nameplate capacity.Response:-The actual loss, if they’re using the proper fittings, should not bezero but too small to detect.-Connection to the self sealing hoses not a problem, no operator/user error. The self sealer in the valve will not open up until agood seal is established. More of an issue of a best practice inthe industry, i.e., that OEMs should be using these types of hoses.-Self sealing hoses are used quiteoften, about 80 to 90% ofindustry is using them.-Residual gas in the hoses a lot of times may not be recovered ifthe operation is more manual-Several facilities leave the hoses pressurized at the end of aday/shift and then start over again. And, correct – this would notresult in a loss-Different sets ups in the factories; many facilities will not fill onebreaker at a time. There could be as many as 20 different stations.-Option of using a flow meter to measure the amount of gas goinginto the breaker, if you put it really close to the breaker – yes, youwould have a very good estimate. Currently flow meters are notNoN/A12Date Staff ContactInformation (Name,email, phone #)Name ofOrganization(Attach list of allattendees namesand emails ifpossible)Summary of Discussion (e.g., applicability, reporting requirements,etc.)WrittenCommentsProvided?Did theyalso submitto Docket?Date sent toEPA- CCDin the factories given their priceand that these devices would noteliminate the need for the scales and therefore there lacks abusiness justification to add flow meters to their practices.-Dilo Germany estimated emission losses when uncoupling ahose. Dilo calculated for two standard fitting sizes—an 8 MM(DN8) and 20 MM (DN20) under normal breaker pressure (72.5PSI), The results were as follows:At 20 degrees Celsius –Loss on 8 MM valve during uncoupling – no more than 10 gramsLoss on 20 MM valve during uncoupling – no more than 50 gramsAt higher temps – losses will be lessAt lower pressures will be lessInternal volume and guts of the fittings known.Results determined based on a calculation;Dilo’s valves estimated to be used by 80% of electrical equipmentmanufacturers.-On bagging techniques: might be too advanced for such ademinimis amount. And other considerations get raised such asuser/operator error, possibility of the bag getting damaged;practicality (i.e., you would have to run the test without the valvebeing hooked up to the equipment.)-On precisely determining the shipping charge of the equipment orits nameplate capacity to accurately determine disbursement,noted that one can fill with a liquid or fluid and calculate internalvolume correctly and subsequently the nameplate capacity.Noted that the vendor of parts might change the component andthen there is a need to test again– and there are lots of parts withthis equipment.