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The Impact of SF6 Regulations
From a Manufacturer‘s Perspective First, thank you to Lukas and Billy for the invitation to speak. It is my pleasure to speak today about the impact of SF6 regulations from a manufacturer's perspective. I know that what happens at a manufacturer can sometimes be “hidden” behind the walls of their facilities. I want to spend the next few minutes sharing what G&W has seen and done since the introduction of the SF6 reporting regulations. November 16, 2017 Karla Trost Senior Global Product Manager G&W Electric Company
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Regulations impacting manufacturers
Summary G&W Overview Regulations impacting manufacturers Direct impacts Indirect impacts Historical & Industry impacts Future impacts I have elected to look at three sets of impacts. Those that manufacturers have already been addressing, those that we are working on now in the industry, and how it may impact the future. As we talk through these impacts, I challenge you to think about what impacts you have seen – especially those that were not expected.
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For those who may not be familiar with G&W, we were founded in 1905 by two Commonwealth Edison engineers (Harry Gear and Paul Williams) who wanted to resolve an issue their crews were having.
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1905 This led to the introduction of the first disconnecting porcelain pothead.
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1966 Our early history was filled with the creation of many medium and high voltage utility products, and to the point of this conference, the introduction of a fully submersible medium voltage SF6 insulated switch in 1966.
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1974 Our first installation was completed in 1974.
Today SF6 insulated switches continue to be a large percentage of our medium voltage product offering.
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Regulations – Direct for G&W
Environmental Protection Agency Greenhouse Gas Reporting Program (GHGRP) Subpart SS (Manufacture of Electric Transmission and Distribution Equipment) California Air Resources Board Global Warming Solutions Act of 2006 SF6 Reductions from Non-Electric and Non-Semiconductor Applications Like many of you we are directly required to report to the EPA Green House Gas Reporting Program. We fall under part SS for the Manufacturer of Electric Transmission and Distribution Equipment. In addition, we also report to CARB for products shipped to California.
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Regulations – Indirect for G&W
Environmental Protection Agency Subpart DD (Use of Electric Transmission and Distribution Equipment) California Air Resources Board Global Warming Solutions Act of 2006 Sulfur Hexafluoride (SF6) Emission Reductions from Gas Insulated Switchgear Massachusetts Department of Environmental Protection Massachusetts Greenhouse Gas Emissions Reporting Program We also support our customers in their reporting to the US EPA, CARB, and Massachusetts Department of Environmental Protection.
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Manufacturer Compliance with Regulations
- Direct Impacts & Process Changes Implementation of a reporting and tracking system The requirement to report had direct impacts on our business with several process changes. In the beginning though, we started with simple weighing. Canisters (arrival and departure) and Tanks pre & post And that met the requirements. But, it added time and costs to the manufacturing processes and was not accurate enough. G&W Reporting for 2011
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Manufacturer Compliance with Regulations
- Direct Impacts & Process Changes Implementation of a reporting and tracking system Inventory mangement Vacuum & Fill Procedures Aftermarket Procedures Customer loan of SF6 Tanks After we calculated our results that 1st year we learned that we needed to seriously evaluate our handling processes. A team was created to look at several key areas – this included: Inventory management of the SF6 Internal Vacuum/Fill procedures Aftermarket Support – both from returned/reworked equipment and field service visits and Customer purchase/loan of SF6 tanks CLICK As you can see here, we saw significant improvements in our second year of reporting . Year Reported G&W Reporting for
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Decrease time to weigh the tanks Eliminate any employee errors
Manufacturer Compliance with Regulations - Next Steps Goals Decrease time to weigh the tanks Eliminate any employee errors Reduce extra costs in the measurement/reporting process While our management was much happier with our results, they challenged us to look into additional ways to improve our processes including any way to eliminate employee error and if possible to reduce the amount of time it was taking to weigh the tanks before and after each switch.
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Manufacturer Compliance with Regulations
- Indirect Impacts – Vacuum & Fill System In 2012 we moved to a new facility. We decided to use the opportunity to implement an automated vacuum and fill system. The new system met two of our goals - remove worker error and eliminate the need to weigh the switch tanks. It also provided us with several additional benefits: automated warnings for time and pressure variances Comparison of the as filled amount to expected quantities.
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Manufacturer Compliance with Regulations - Indirect Impacts
Fill Ports Historically many suppliers used standard Schrader Valves which provided ease of use and consistency across products/manufacturers As we evaluated options for the automated fill system we became aware that in order to see all of the benefits of the investment, we needed to make a change to our product. Many SF6 insulated products use a standard Schrader valve. It is an easy to use device and provides consistency across products and manufacturers. While the valve itself seals using a spring, it is easy to depress the pin and if the cap becomes damaged or improperly installed – the cap itself can depress the pin emitting SF6. CLICK More importantly, the mating filling hose does not seal on the fitting end. So any SF6 that is left in the filling hose can be emitted relatively easily. We started looking for a valve that would be fully self-sealing, would prevent emissions during the filling process, and could withstand the harsh environments to which our switches are subjected. How many of you have had to approve a new product? How did you know that the product would be suitable for the environment and would meet the expected life?
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Manufacturer Compliance with Regulations - Indirect Impacts
As you can imagine, the process and time to approve a switchgear design change is intensive especially when you are talking about a device that has to maintain the tank seal and will be submersed in vaults for extended periods of time. Here you see a switch in a street level vault. Many of our customers tell us that they only drain the vault if it is necessary which means the switch can remained submerged for days, weeks, or even months. And of course, the water in the vault is not 100% clean
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Manufacturer Compliance with Regulations - Indirect Impacts
Fill Ports Implementation of a new valve in order to improve process After the initial rounds of testing we selected a DILO valve. It then took many more months to finalize and to fully test the design.
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Manufacturer Compliance with Regulations - Indirect Impacts
Fill Ports Verification of a new valve in order to improve process How do you prove a design will last for 30+ years in all sorts of environments? We do a combination of tests including: CLICK Thermal aging, submersibility (20’ for 20 G&W and a 6 month test at a customer, Freeze/thaw cycling, Vibration tests and Salt Fog corrosion. WITH AND WITHOUT THE CAP With the creation of the measurement process, the implementation of the automation system and the release of the fill valve design we realized an unexpected impact. A reduction in the amount of time to vacuum and fill the tank – on the largest tanks we saw more than a 60% reduction in the total time. So not only had we eliminated the need and time to weigh the tanks, but we actually had an overall process time improvement. But, it turns out, the biggest impact that the regulation would have on G&W’s use of SF6 – would be the ability to track the as filled value of each switch.
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Manufacturer Compliance with Regulations - Indirect Impacts
Nameplates Historically, nameplates provided a typical value of insulating material This was frequently a volume based calculation Yesterday Jonathan spoke about the use of the nameplate value in the emission calculations and how the historical/typical value can impact the reporting. Why is that? Well, the historical values were often a typical value for a type and size of switch based on an engineering estimate of the volume inside the tank. Any switch design difference such as the tank material (Mild vs stainless), the change of a bushing type (from 600 Amp Apparatus) to 200 Amp Deepwell), CLICK or the addition or subtraction of operating mechanisms would change the actual volume but might not impact the estimate.
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Manufacturer Compliance with Regulations - Indirect Impacts
Nameplates With the new processes and product changes, nameplates can now be made with actual “As Filled” values With all of the changes that we had implemented, we realized we were only one step away from replacing the typical value on the nameplate by that of the actual as filled value. Now, it sounds easier that it was, at least if you ask my IT department. But, by connecting the fill system to our business system we were able to track and record by customer, and by serial number, the actual as filled amount. Paired with our existing ability to fill out nameplates in our factory, we were able to have the nameplates pushed by the business system and made with the as filled value.
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Manufacturer Compliance with Regulations - Unexpected Benefit
Reports Once all of the information was available in our business system, we saw an unexpected additional benefit CLICK the ability to provide reports to our customers showing not only the total amount of SF6 shipped to them each year but also by product. This has become a fairly regular request with some customers receiving reports every week or every month. In this example, there are four and five way switches. Each had some different design characteristics and there are different as filled values for 3 of the units. Among other things, this particular report shows: CLICK Serial number CLICK The Catalog Number CLICK The day of shipment And CLICK The as filled value. You can see these two switches are both four way load break switches but with slightly different maximum voltage levels and some design differences which result in different as filled values. If I were in your shoes, I would be thinking – well this is great for new switches – but what about what I have installed!
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Historical & Industry Impacts - Use of Nameplates
What about installed switchgear? Manufacturers are working with NEMA to create step-by-step processes for users to determine the actual value that should be used as the nameplate value. Each manufacturer will create their own procedure for confirming and approving a request to change the nameplate value. An Example – IF EPA and CARB require OEM approvals We have already talked a little bit about the impact of the nameplates on the reported values and how new factory filled switches can be provided with as filled values. But what about the installed base? As a member of the National Electrical Manufacturer’s Association, we are working closely with the SF6 coalition and utilities to create a process for users to request an adjustment to the nameplate value. CLICK The process isn’t complete, but it could look something like this: User would perform testing per a NEMA process. CLICK The user would then submit their results and a request to the update the nameplate CLICK The manufacturer would review the results and compare to their internal data. CLICK Finally the manufacturer would notify the user if the request was approved. It is important to note that each manufacturer can choose whether or not they will participate in the program and that each manufacturer will create their own procedure for confirming and approving a request to change the nameplate value. User submits results and request to update nameplate Manufacturer reviews results and compares to internal data Manufacturer notifies user if request was approved User performs testing via NEMA Process
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Historical & Industry Impacts - Use of Nameplates
Will there be any requirements for the accuracy of the value on the nameplate? At this time, most of the IEEE standards just call for the type and quantity with no accuracy requirements. Users should consider including accuracy requirements in their specifications. Some of the IEEE Working Groups are including accuracy requirements for the nameplate values, but it will take time before they are released. One of the other questions that comes up is the accuracy of the nameplate value. If users have to be within a certain % of emissions, and the equipment used to measure the SF6 is rated to a certain accuracy – what about the nameplate. CLICK Currently, most of the standards just call for the total weight. This is a portion of the C37.74 standard for loadbreak switches. But, that does not mean that users can’t request an accuracy value. If you would find it valuable, please consider including a requirement in your specification. Some IEEE working groups are working on including accuracy requirements in their current drafts. These need to be balloted and approved by a combination of users, manufacturers, and interested parties. It will take time before they are released and more time before the requirements are implemented in all standards. Nameplate specification IEEE C
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Impact on the Future Introduction of new media and/or growth of alternate insulating media Solid dielectric New gases Combinations of existing / new As customers and manufacturers address the impacts of regulations on SF6, there is work being done on new insulating materials. Some already exist, like Solid Dielectric. CLICK If you are not familiar with Solid Dielectric, it is typically an epoxy type material which is molded over a vacuum bottle switching device. This has become very popular in the recloser market and has been expanding into Pad-mounted and vault switchgear. In addition, several manufacturers are investigating new insulating gases and gas mixtures. Finally, work is being done to combine various media such as solid dielectric in a pressurized inert gas. Regardless of which direction each manufacturer chooses to go – there are still a lot of questions to be answered.
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Impact on the Future Questions for the industry
Ensure expected life of the equipment Environmental impacts Evaluate needed processes and equipment Product approval process Consistency across the industry FOR EXAMPLE CLICK how to test to prove long term life of a switch. How long and how do we test a new product to ensure a 30 year, 40 year, or longer life? What are the environmental impacts of the new product and how to how to dispose of the product at the end of life? We certainly didn’t expect to come to a point where we were discussing the end of SF6 in electrical products. CLICK What new processes and equipment become necessary? CLICK How are new products approved? Most are not covered in the standards. Even Solid Dielectric which has been in use for almost 20 years in medium voltage applications is not specifically called out in most standards. 5) CLICK And if each manufacturer goes their own way, how do we have some level of consistency across the industry? What of these matters the most to you and how can we as manufacturers help?
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Regulations impacting manufacturers
Review Regulations impacting manufacturers Direct impacts Indirect impacts Historical & Industry impacts Future impacts I don’t think anyone expected that a reporting program meant to help our environment would have so many impacts on the users and manufacturers. Creating processes to report Changing numerous existing processes and safety protocols to eliminate emissions and errors Changing products to better work with those processes Looking at how to update product in the field Revision to Specifications and Standards And Creation of new types of products and insulating media I believe that the work we have gone through since 2011 has made us a better manufacturer, it has helped us to improve our products and processes, and we better understand the impacts of these regulations and changes on our users. I hope that what I have shared today will help you, our users, understand the impacts these regulations and changes have had on manufacturers. Now, I would like to know what questions that you have….
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The Impact of SF6 Regulations
From a Manufacturer‘s Perspective Presentation By: Karla Trost Presented On: November 16, 2017 G&W Electric Company Address: 305 W. Crossroads Pkwy, Bolingbrook, IL USA Contact information:
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