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.) 

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Email & telephone correspondence from 6/4/10 – 6/22/10 

 Mollie Averyt, ICF International, 202-862-1569 

maveryt@icfi.com

on behalf of EPA under Contract EPW-07-068, Task Order 68 

Lukas Rothlisberger, Dilo 727-232-0050 lukasr@dilo.com

Topic: Under Subpart SS, there is a concern regarding the disbursement input of the mass balance approach. Typically manufacturers would enter the quantity of gas that was disbursed from the cylinder and into the breaker. However, if there was an emission during the transfer of the gas, it would be counted as a disbursement rather than an emission – thereby underestimating emissions. EPA is examining a variety of ways to accurately determine the amount of SF6 (or PFC) filled into new equipment 

before that equipment is shipped out to customers including either engineering methods on the transfer of the gas or very precise measurement of the equipment’s nameplate capacity. Response: 

- The actual loss, if they’re using the proper fittings, should not be 

zero 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 a good seal is established. More of an issue of a best practice in the industry, i.e., that OEMs should be using these types of hoses. 

- Self sealing hoses are used quite often, about 80 to 90% of 

industry is using them. 

- Residual gas in the hoses a lot of times may not be recovered if 

the operation is more manual 

- Several facilities leave the hoses pressurized at the end of a 

day/shift and then start over again. And, correct – this would not result in a loss 

- Different sets ups in the factories; many facilities will not fill one 

breaker at a time. There could be as many as 20 different stations. 

- Option of using a flow meter to measure the amount of gas going 

into the breaker, if you put it really close to the breaker – yes, you would have a very good estimate. Currently flow meters are not 

No 
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.) 

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in the factories given their price and that these devices would not eliminate the need for the scales and therefore there lacks a business justification to add flow meters to their practices. 

- Dilo Germany estimated emission losses when uncoupling a 

hose. Dilo calculated for two standard fitting sizes—an 8 MM (DN8) and 20 MM (DN20) under normal breaker pressure (72.5 PSI), The results were as follows: 

At 20 degrees Celsius – Loss on 8 MM valve during uncoupling – no more than 10 grams Loss on 20 MM valve during uncoupling – no more than 50 grams At higher temps – losses will be less At lower pressures will be less  Internal volume and guts of the fittings known.  Results determined based on a calculation; Dilo’s valves estimated to be used by 80% of electrical equipment manufacturers. 

- On bagging techniques: might be too advanced for such a 

deminimis amount. And other considerations get raised such as user/operator error, possibility of the bag getting damaged; practicality (i.e., you would have to run the test without the valve being hooked up to the equipment.) 

- On precisely determining the shipping charge of the equipment or 

its nameplate capacity to accurately determine disbursement, noted that one can fill with a liquid or fluid and calculate internal volume correctly and subsequently the nameplate capacity. Noted that the vendor of parts might change the component and then there is a need to test again – and there are lots of parts with this equipment.