Reducing Costly Phantom SF6 Emissions Through Tracking Ted Atwood (President & Owner), Polar Technology LLC

Current EPA Regulations Mandatory reporting of emissions for any company with installed SF6 inventory > 17,820 lbs. Mass-balance approach that incorporates the following: Change in inventory Acquisitions Disbursements Change in Nameplate capacity First report for 2011 Emissions is due September 28th, 2012

Emission Sources Leaky Equipment Emissions from normal operation of equipment Solution: Leak detecting camera or other device, repair or replace equipment

Emission Sources Improper Recovery/Loading: Emissions while recovering SF6 or loading SF6 into equipment Solution: Proper training on recovering / loading technique, monthly leak and functionality equipment testing.

Emission Sources Phantom Emissions Emissions that did not actually occur, but using EPA’s mass balance approach appear because of bad source data Solution: Implement an effective tracking program to eliminate bad data and accurately track true emissions

Phantom Emission Source 1: Virgin Gas Inaccuracies Problem 1: Amount of gas provided by bulk gas provider in bottle is inaccurate (overstated): Virgin gas provider states gross weight of cylinder as 230 lbs and assumes tare weight is 115lbs meaning there is 115lbs of gas in cylinder. Actually tare weight is 123 lbs reducing actual gas weight on bottle by 8 lbs. You are instantly hit with an 8 lb emission before you touch the bottle! EXAMPLES of 20 Random Tare Weights:

Phantom Emission Source 1: Virgin Gas Inaccuracies Problem 2: Vendor includes cap in Gross Weight of SF6 bottle Each cylinder cap weighs lbs. Cap Weight is not included in Tare Weight If gross weight is reported with cap on bottle, customer instantly faces emission equal to weight of cap Gross Weight With CapTare WeightApparent SF6 Weight Correct Gross Without CapTare WeightActual SF6 Weight lb “Phantom” Emission/ bottle

Phantom Emission Source 1: Virgin Gas Inaccuracies Assume you purchase 100 bottles of SF6 / year. It is thought you received 11,500 lbs of SF6 out of those bottles. Because of Tare Weight issues, improper filling, or Gross Weight mistakes you only actually receive 10,900 lbs of SF6. Instantly tagged with 600 lbs. of Phantom Emission that never occurred. 600lbs of emitted SF6 equates to 6900 tons of CO2 in terms of Global Warming potential or the CO2 released by 1352 cars in a year! Charged for $3000-$5000 of SF6 that was never received

Phantom Emission Source 1: Virgin Gas Inaccuracies Solution: Require all Virgin deliveries to be accompanied by spreadsheets certifying: S#, Gross Weights, Tare Weights, SF6 Weight, and purity of each bottle. Always request and verify vendors filling and weighing procedures Request scale certification certificates quarterly Independently verify 10% of data Always log delivery certificate in a spreadsheet or tracking software along with supporting documents for eventual EPA audit

Phantom Emission Source 2: Cylinder Heels Problem: Field Technician believes bottle is empty and returns to gas provider. Technician believes bottle is empty because of two reasons: Cannot get any more liquid out of bottle or bottle pressure equalizes with equipment that is being worked on Bottle does no allow pump out below a specified pressure Bottle likely has 6-10 lbs of SF6 “heel” remaining in it If unaccounted for, 6-10 lb SF6 “heel” becomes instant SF6 emission Most utilities log their own heels but: If possession of heels isn't taken by re-claimer or whomever you send bottles to, heels are still responsibility of utility company.

Phantom Emission Source 2: Cylinder Heels Solution: Require all parties who take back your SF6 cylinders to produce and log heel reports. Reports must include: S#, Tare Weight, Gross Weight, and SF6 purity. Heel reports need to be supported by certificate of ownership stating that ownership of SF6 was transferred. Example heel report: Cylinder SNGWTWSF

Phantom Emission Source 2: Cylinder Heels Require certificate of recycling or transfer of ownership for returned gas and cylinders Example: “ To Whom it concerns, On this date {SF6 Company} took possession of 40lbs of SF6 from 4 bottles from XYZ Utility Company. The cylinders came from the Main Street service station of XYZ Utility Company. Please see attached heel report for total gas verification. Signed, Dated, {SF6 Company Name}, EPA ID” Cylinder SNGWTWSF

Phantom Emission Source 3: Lost Cylinders Problem: Bottles that contain gas are lost in the field because: Bottle is too heavy for a single technician to move Bottle is attached to installed equipment Technician is not responsible for bottle tracking Lost bottles typically contain 1000’s of pounds of SF6 Bottles are viewed as a normal material: Once checked out of warehouse tracking is not required Solution: Implement a digital or paper based tracking program to assure bottle location and SF6 gas is always tracked.

What must be tracked? Exact amount of virgin gas acquired Source of all acquired gas Gas sent off to SF6 processing companies as heels or contaminated Locations of all SF6 assets (bottles and equipment) Nameplate capacity of all equipment Transfers of SF6 gas between bottles and equipment

Tracking Methods Excel forms completed whenever any SF6 movement occurs. Forms should be managed at each location with every transaction. Digital web based solutions that track: SF6 Inventory SF6 assets Disbursements Acquisitions

Questions?