U.S. DEPARTMENT OF ENERGY

PUBLIC MEETING ON TEST PROCEDURES

FOR DISTRIBUTION TRANSFORMERS

MONDAY,

SEPTEMBER 27, 2004

The meeting was held at 9:00 a.m. in Room 1E245 of the Forrestal Building, 1000 Independence

Avenue, SW, Washington, D.C., Cyrus Nasseri of DOE's

Building Technologies Program, presiding.

PRESENT:

DAVID BRENDER Copper Development Association

DOUG BROOKMAN Public Solutions

EDWIN BRUSH BB&F Associates

CARL BUSH Pemco Corporation

GLEN CAMPBELL Natural Resources Canada

STUART CHAITKIN Lawrence Berkeley National

Laboratory

SCOTT CHOINSKI National Electrical

Manufacturers Association

MICHAEL FAULKENBERRY Georgia Power Company

PAUL GOETHE Optimized Program Services, Inc.

EDWARD GRAY National Electrical

Manufacturers Association

ROB GREESON Federal Pacific Transformer

HARRY HAYES III Ameren Services

GERALD HODGE Howard Industries, Inc.

RICHARD LYKE AK Steel Corporation

JIM McMAHON Lawrence Berkeley National

Laboratory

STANLEY MERRITT Merritt and Associates

WALTER MOREHART Acme Electric Corporation

OSKARS PETERSONS National Institute of Standards

and Technology

MICHAEL RIVEST Navigant Consulting, Inc.

ROBERT SAINT National Rural Electric

Cooperative Association

JERRY SCHOEN AK Steel Corporation

MIKE SCHOLAND Navigant Consulting, Inc.

JOHN STOOPS Lawrence Berkeley National

Laboratory

KEN STRICKLETT National Institute of Standards

and Technology

JOHN TALBOTT NIST consultant

ALAN TRAUT Kuhlman Electric Corporation

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
2

ROBERT VAN BUSKIRK

LAURA VAN WIE

DAVID WIEGAND

ALAN WILKS

Lawrence Berkeley National

Laboratory

Lawrence Berkeley National

Laboratory

Navigant Consulting, Inc.

ERMCO Distribution Transformers

DOE REPRESENTATIVES PRESENT:

CYRUS NASSERI

BRYAN BERRINGER

CHRIS EARLY

THOMAS DePRIEST

SAM JOHNSON

RONALD LEWIS

MICHAEL McCABE

FRANCINE PINTO

JIM RAGA

JIM RANNELS

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
3

A-G-E-N-D-A

Welcome . . . . . . . . . . . . . . . . . . . . . 4

Cyrus Nasseri

Introduction and Agenda Review . . . . . . . . . 8

Doug Brockman

Overview of the Proposed Rule . . . . . . . . . . 15

Cyrus Nasseri

Comments and Issues from Participants . . . . . 21

Definition of a Distribution Transformer . . . . 24

Michael Scholand

Definition of Basic Model . . . . . . . . . . . . 27

Michael Scholand

Uniform Test Method for Measuring Energy

Consumption . . . . . . . . . . . . . . . . . . . 47

Oskars Petersons

Sampling Plans for Compliance and Enforcement

Testing

Oskars Petersons . . . . . . . . . . . . . . 64

Kenneth Stricklett . . . . . . . . . . . . . 69

Alternative Efficiency Determination Method (AEDM)

Kenneth Stricklett . . . . . . . . . . . . . 79

Other Issues . . . . . . . . . . . . . . . . . . 84

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
4

1 P-R-O-C-E-E-D-I-N-G-S

2 9:04 a.m.

3 MR. NASSERI: Good morning and welcome

4 everyone to the public meeting for the Distribution

5 Transformer Test Procedure Supplemental Notice of

6 Proposed Rulemaking. I am Cyrus Nasseri, project

7 manager for this rulemaking.

8 I would like to recognize my colleagues

9 from DOE seated here at the table, Ron Lewis from

10 Building Technologies and Tom DePriest, present, and

11 I think Francine Pinto is going to be later here at

12 some kind of a doctor appointment. And they are from

13 Office of General Counsel. I would like also to

14 recognize some of the team which supported the

15 development of this rule who are also present today.

16 Oskars Petersons and Kenneth Stricklett from

17 National Institute of Standards and Technology, and

18 Michael Scholand from Navigant Consulting.

19 Our facilitator today is Doug Brookman,

20 on my left side, and I will be chairing this public

21 meeting. On behalf of the Department of Energy, I

22 would like to thank you all for taking the time to

23 participate in this public meeting.

24 As published in the Federal Register on

25 July 29 of this year, this public meeting is a forum

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(9n91 9Rd_ddT4 1A1AQWIAI(,TIVMI n c OnnnR_ z7na ,en,n,, noolrnrncc rnm

EE-TP-98-550 COMMENT 45.11
5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

for interested parties to comment on proposed test

procedures for distribution transformers. DOE would

like to receive your comments on the proposed rule

for this product. This morning, we will follow the

agenda you received in your packets. And hopefully

you all picked up the packet at the front desk.

Ideally we would keep precisely to time. However,

Doug and I will try and be flexible to ensure we

have ample time for everyone who wants to comment.

Please note that today's meeting is on the record.

In other words, a transcript will be prepared, so I

ask that you clearly state your name -- and maybe if

for the first time you're introducing yourself, your

affiliation -- every time you start to speak. The

transcripts for this public meeting will be entered

into the docket for this rulemaking, and the

department will take all the comments you make today

into consideration. Furthermore, the written

comments period, as you probably remember from the

notice that we published, is November 8, a month and

a half from now. You will find in your participant

packet a one-pager titled "How to Comment." This is

essentially an extraction from the Federal Register

notice to make it easier for you to submit your

feedback. The department welcomes all comments on

19n91 934-44X

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINC;Tt7N n ( 9nnns_R7n1 www naalrnrncc rnm

EE-TP-98-550 COMMENT 45.11
6

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

this notice as it will assist us in preparing the

final rule.

As is provided in the Federal Register

notice, and also appearing in the How to Comment

one-pager, all the material related to this

rulemaking is posted on our website. And I'm not

going to read that,.it's a very long website, unless

you want me to do that later on. The slides that

you see today will also be posted on our website

very shortly, I would say in the next two or three

days. So please feel free to forward the link to

any of your colleagues who could not participate

with us today. As you are already seeing, there's

also a hard copy of all the slides appearing in your

packets. In approximately two weeks, or sometime

sooner, a complete copy of the transcript will be

available for inspection at the Building

Technologies Program Resource Room, located in Room

1J -- as in Jack -- 018. Anyone wishing to purchase

a copy of the transcript may make arrangements with

the court reporter sitting on my right.

To provide the department with as much

pertinent information, and as many views as can be

reasonably obtained, and to enable interested

persons to express their views, this public meeting

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(9n91 93 LAz1 q 1A1 I-IIMIrTnm n c 9n001;_17( 1 nnnnni nc^lrnrnec rnm

EE-TP-98-550 COMMENT 45.11
7

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

will be conducted in accordance with the following

procedures. We will begin with introductions, and

then proceed to short introductory presentations

from people who have asked to speak and provided us

with submitted comments. I want to stress our

request that your initial comments be limited to

general issues, and,the summary of your views, and

be no longer than five minutes. This is the policy,

but today since we have more time, we might give you

a little more time for that. Following those

presentations, we will discuss the issues on the

agenda, and any other issues you wish to discuss.

And you will have an opportunity to provide more

detailed comments on the specific issues. Please

limit your questions on the opening presentations to

general points so that we can provide everyone the

opportunity to present their summary of concerns.

During the remainder of the proceedings, questions

on the specific issues are welcome. I encourage

everyone present to participate as much as possible

so that we may get the fullest spectrum of opinions

on issues raised. The public meeting is scheduled

to recess today at 5:00 p.m.

All comments, today's transcript, and

data submissions, will be available for public

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WACHINr.T0N n r: 9nnnr;-3701 %AIW M naalrnrncc rnm

EE-TP-98-550 COMMENT 45.11
8

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

review at the Building -- again, I mentioned that

before -- Technologies Program Resource Office in

Room 1J018. The room is open between 9:00 and 4:00

p.m. Monday through Friday except federal holidays.

For more information, please contact Ms. Brenda

Edwards-Jones, and her telephone number is 202-586-

9127, and that is basically listed under our rule

also, the telephone number. Again, we appreciate

the time and effort you have taken in preparing for

this public meeting, and we are pleased to receive

your comments and opinions. Our purpose today is to

have dialogue on the issues so that all who are

interested can share and add insight to this

rulemaking.

At this point, I would like to turn the

floor to our facilitator Doug, and he will complete

the introduction of participants, review the agenda,

and start the presentations. Thank you very much.

FACILITATOR BROOKMAN: Thank you. Good

morning everybody. I'd like to give everybody a

chance to introduce him- or herself. That's a

tradition that we've had. May I start with you? If

you'd say your name and organizational affiliation.

If everybody would take your table tents and turn

them towards me so that I can read them, then I'll

!9(191 934_4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHIN(TnN n C 9nnn1;_37n1 wnnv n,airnrncc rnm

EE-TP-98-550 COMMENT 45.11
9

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

be able to recognize many of you by name. Please,

Glen.

MR. CAMPBELL: I'm Glen Campbell,

Natural Resources Canada.

MR. GRAY: Ed Gray, National Electrical

Manufacturers Association.

MR. LYKE: I'm Richard Lyke, AK Steel

Corporation.

MR. MOREHART: Gene Morehart, Acme

Electric.

MR. TRAUT: Alan Traut with Kuhlman

Electric Corporation.

MR. HAYES: Harry Hayes, Ameren

Services.

MR. BRENDER: David Brender, Copper

Development.

MR. WILKS: Alan Wilks, ERMCO.

MR. FAULKENBERRY: Mike Faulkenberry,

Georgia Power Company, Southern Company.

MR. HODGE: Gerald Hodge from Howard

Industries.

MR. LEWIS: Ron Lewis from the Building

Technologies program here at DOE.

MR. NASSERI: Cyrus Nasseri again, from

Building Technologies.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WARHINC TON n C ?0005-3701 www. nealraross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

10

MR. DEPRIEST: Tom DePriest, DOE Office

of General Counsel.

FACILITATOR BROOKMAN: Now just

continue. You first, please.

MR. STRICKLETT: I'm Ken Stricklett from

the National Institute of Standards and Technology.

MR. PETERSONS: Oskars Petersons,

National Institute of Standards and Technology.

MR. SCHOLAND: Michael Scholand from

Navigant Consulting.

MR. WIEGAND: Dave Wiegand. I'm under

contract to Navigant Consulting.

MR. GOETHE: Paul Goethe from Optimized

Program Services.

MR. STOOPS: John Stoops, Lawrence

Berkeley National Lab.

MR. MCMAHON: Jim McMahon, Lawrence

Berkeley National Lab.

MR. MCCABE: Michael McCabe, Department

of Energy.

MR. CHOINSKI: Scott Choinski, from the

National Electrical Manufacturers Association.

MR. BUSH: Carl Bush, Pemco Corporation.

MR. TALBOTT: John Talbott, consulting

25 II for NIST.

(2021 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON. D.C. 20005-3701 www.nealrqross.com

EE-TP-98-550 COMMENT 45.11
11

1 MR. RIVEST: Mike Rivest , Navigant

2 Consul t i ng.

3 MR. MERRITT: Stanley Merritt , Merritt &

4 Associates , under contract to Berkeley Lab.

5 MR. CHAITKIN : Stuart Chaitkin , Berkeley

6 Lab .

7 MR. BERRINGER : Bryan Berringer,

8 Depart t men o f Energy.

9 MR. BRUSH : Ned Brush, consultant to the

10 Copper Development Assoc i i at on.

11 MR. SCHOEN: Jerry Schoen, AK Steel.

12 MR. SAINT : Bob Saint, National Rural

13 Electric Cooperative Association.

14 MR. VAN BUSKIRK: Robert van Buskirk,

15 Lawrence Berkeley National Lab.

16 MR. EARLY: Chris Early, Department of

17 Energy.

18 MS. VAN WIE MCGRORY: Laura Van Wie

19 McGrory, Lawrence Berkeley National Lab.

20 MR. RABA: Jim Raba, Department of

21 Energy.

22 MR. RANNELS : Jim Rannels , Building

23 Technologies program.

24 MR. JOHNSON: Sam Johnson , Building

25 Technologies program.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON. D.C. 20005-3701 www.nealrqross.com

EE-TP-98-550 COMMENT 45.11
12

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

FACILITATOR BROOKMAN: Thank you. I

hope everybody has received a packet. If you

haven't signed in when you walked into the door,

please do so. A list of the attendees of this

workshop will be sent out after today via email, so

everybody should check in. The first item in your

packet is the agenda. You can see it up here on the

screen . We are now doing the introductions and the

agenda review. We're going to move from here to a

brief overview of the proposed rule by Cyrus.

Following that brief overview, we want

to provide a comment period for anybody in the room

that wishes to speak. I would ask that you not read

from your written submitted statement, that you

summarize and keep it as brief as possible. That'll

make it easier for all of us to stay focused on the

key issues. And any additional or supplemental

issues I'll be noting as we go along here.

We'll take a break mid-morning, around

about 10:15 or 10:30, depending on how the steam in

the room is at the time. Following that we'll have

a definition of distribution transformers, brief

presentation followed by the opportunity -- well,

the format, the general format which Cyrus

described, a segment of presentation followed by

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

opportunity for question and comment. And that will

be the format for the entire day. Before lunch

we'll be talking about the definition of the basic

model.

We'll take lunch midday. Following

lunch, we'll talk about the uniform test method for

measuring energy consumption. Following that,

sampling plans for compliance and enforcement

testing. We'll take a break mid-afternoon, 3:00 or

so. And after that, alternative efficiency

determination method. And finally, around about

4:00 this afternoon, or if we get there earlier, any

other issues that pertain to this supplemental

notice. And that's the plan for today.

Questions, comments, at the outset? In

particular, is there anything that people came here

to discuss that isn't in this agenda somewhere? I

see nobody has anything additional.

Okay. Let me ask your consideration.

Over the span of the years, as we have done a lot of

these appliance energy efficiency standards

workshops, norms have emerged, and you see them

posted on the wall over there to my left. I'm going

to simply ask you speak one at a time. Please say

your name for the record. You're going to have to

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
14

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

stick the microphone right square in your face and

that way we ' ll get a good recording for the

transcript . I'm going to ask that you listen as an

ally. One thing I've observed over the years is

that the listening has gotten better and the

dialogue has gotten a whole lot better in this room.

Please keep the focus here. If you need

to take a cell phone call -- please turn off your

cell phone ringers -- if you need to take a cal

we'll understand you going out of the room. If you

need to engage the person next to you in a sidebar

conversation, we'll understand if it's going to be

more than 10 or 15 seconds that you will take that

out of the room as well. We're trying to keep it as

focused here as possible. Please be concise, share

the airtime. There are a lot of people that have a

lot to say on this subject, and we're going to

provide everyone the opportunity to do that.

I'm going to be cuing people to speak.

I'll be cuing you by name to the extent I can. I'll

be pointing otherwise. And I do wish, however, to

not shut off the follow-on comments. Please make it

possible for this to work gracefully. That is,

especially if you're following on, try to be as

brief as possible. If I drop you out of the queue,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
15

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

don't let me get away with it. Start waving your

arms or something like that, okay? So that's the

general information before we start. And as we get

towards the break, we'll talk about other kinds of

issues.

Anything else, any other questions

before we begin? So Cyrus, are you ready?

MR. NASSERI: Yes. Good morning again.

The next presentation would be the overview of

today's public meeting for this test procedure.

Thank you. And I'm going to present this part of

the presentation.

The purpose of this public meeting, as I

state in the four bullets, is to present the

department's proposed test procedure that you have

seen in July 29 of this year. Seek comments from

participants on proposed methodology and

requirements. Discuss and respond to specific

issues or questions related to the proposal. And

finally, discuss the next steps.

Steps in the Distribution Transfer Test

Procedure Rulemaking. As you see here, the

determination analysis was mandated by Congress in

1992, that DOE has to make a determination for this

product. And you see the detail of that analysis

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
16

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

was published in a notice on October 22, 1997.

Almost seven years ago. And some of you probably

know what our determination was. Shortly, I should

mention the determination was that efficiency rule

or establish a minimum efficiency for this product

is feasible, and DOE should proceed for the next

step.

The next steps for this, after this

determination, was to develop a test procedure. So

we had a workshop in February 10, 1998, to discuss

the test procedure where the stakeholders were

interested parties. And obviously the NEMA TP-2 and

some of the ANSI, or IEEE, sorry, IEEE procedures

were discussed. So we basically reviewed the

comments that were made during that workshop, and

did our analysis further. And in November of that

year, we published a Notice of Proposed Rule. You

have probably seen that, and the review of that is

mentioned in the SNOPR that we published on the 29th

of July.

When we published the SNOPR, there was a

series of comments on the Notice of Proposed Rule.

In the meantime, we find out that there are some

areas that we have to reopen the comments and see

what the views of the experts and the stakeholders

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
17

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

on those issues are. So we did. We reopened the

notice on June 23 of 1999, and we have received many

comments on the issues that we mentioned in that

reopen notice. And gather all those comments, and

then we developed the Supplemental Notice of

Proposed Rulemaking, which we published on the 29th,

and the subject of today's public meeting.

Well, from here, obviously we're going

to hear your comments. And as I mentioned earlier

in my opening remarks, the comment period's deadline

is November 8, 2004, a month and a half from now.

And after we go through your comments or anybody

else who's interested to make comments, we will

start developing a final rule, and we will make all

efforts possible to have that done by September

2005.

The Test Procedure Overview. We

determined that the test procedure in five major

areas. In each of these proposed areas, they're

either new or different from what was previously

published. And I would like to make all my effort

in a few words to tell you what the differences are

and which ones are new. In the definition of the

distribution transformer, in the previous NOPR we

published, we were very much qualitative,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
18

1 generalized definition. And we decided that we have

2 to give more quantitative numbers for these

3 definitions for the transformers, primary,

4 secondary, what. And we did that. And that's a

5 major difference on new definition.

6 And definition of basic models. In

7 basic models, the way we defined previously in NOPR,

8 simply we said basic models are the one that have

9 the same kVA, they are the same insulation

10 requirements, either submerged, liquid submerged, or

11 dry type transformers. Having the same range of

12 voltages, and having the same phase, either single13 phase or three. Later on when we reviewed that, we

14 found out that is a little problematic. And the

15 reason for that was that with that basic model

16 definition, there was a way of interpreting it that

17 a series of transformers, the same as -- defined as

18 the same basic model might have different

19 performance, which affects efficiency. So because

20 of that, we basically in this notice that we

21 published, we take all the provisions that

22 previously we state in the basic model definition,

23 with additional requirements. And that requirement

24 is that there should not be any differentiating in

25 performance, electrical, or functional of that basic

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
19

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

transformer which affects efficiency. These two

areas will be presented by Michael Scholand of

Navigant Consulting later on, as we proceed. The

third area is Uniform Test Method for Measuring

Energy Consumption. This area will be presented by

Oskars Petersons.

What we have proposed in the past was

basically incorporated by reference standards, such

as NEMA TP-2, and IEEE standards, the four

standards. The series of comments we received

during the original NOPR reopening notice, and some

of the review of our technical team on TP-2 and

IEEE, we decided that we would like to have one test

procedure that will stand by itself, DOE test

procedure. But I have to mention at this point that

we basically referenced and incorporated almost

every requirements in NEMA TP-2 and IEEE standards.

The fourth area that we're going to talk

today is sampling for compliance and enforcement

testing. The sampling would be presented by Oskars

Petersons again. And as you recall, originally we

basically took the sampling plan that we basically

have in the Code of Federal Regulation Part 430,

which was established for consumer products. And we

find that later on with a number of comments, that

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
20

1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

for this product, which is unique, and not being

similar to household products, we have to basically

have something different. What we have done, if

some of you are familiar with the motor rule that we

published a few years back. And that is in the Code

of Federal Regulation part 431. This, what we are

proposing today, is very much similar to that rule

for the motor sampling. Again, that is going to be

presented by Oskars.

The enforcement part of this

presentation is going to be presented by Kenneth

Stricklett. And this is something new. We have not

proposed this previously. And you will see and

discuss it when he is presenting that area.

And finally, the last area is the

Alternative Efficiency Determination Method, that

many of you might be familiar with. And also if

you're in a motor, manufacturing motors, we had that

method in the motor rule. And this is something new

in this rulemaking.

Next steps. Obviously today we are here

to hear your oral comments. We are going to be on

the record. Transcripts are available for DOE's

review later on. And also, your written comments

which I already mentioned, the deadline would be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
21

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

November 8. So we take all the transcripts, your

written comments, any other comments from the

stakeholders, and start developing the final rule

for this product. Obviously the timing for final

rule depends on the nature of the comments the

stakeholder's going to make. But, we are going to

make our efforts, and we probably -- there's a

commitment to do that. That we are going to publish

the final rule before the start of the -- before the

publication of NOPR for efficiency standards, which

would be the nature of the subject for tomorrow's

public meeting.

And at this time, I would like to turn

back the floor to Doug to go through the next steps

of the agenda. Thank you.

FACILITATOR BROOKMAN: Thank you. This

is the opportunity for people that wish to make

summary comments, and list other issues to take up

more specifically as the day goes on . So I'll turn

the lights up. And some of you presented summary

comments , written comments in advance. I know the

department appreciates that greatly. So then let's

start with those summary comments now. Who would

like to start? Please, Ed.

MR. GRAY: I am Ed Gray of the National

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
22

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Electrical Manufacturers Association. Our formal

written statement was submitted to DOE on September

13, 2004. My comments today serve to briefly

highlight our issues as per DOE's request. We may

have additional written comments to submit by the

November 8 deadline.

First of all I'd like to state that we

favor high efficiency products at NEMA. Secondly,

we don't like the approach that was taken this time

to come up with a standalone test procedure. What

we would like to see happen is the stakeholders

agree at this proceeding and the other one as to

what testing efficiency standards and labeling are

needed. And then we can revise the industry

consensus standards appropriately. And then DOE's

rule could be a very simple thing, just refer to the

industry standards.

In lieu of the sampling plan proposed in

the SNOPR, manufacturers must be given the option of

testing all transformers of a basic model or some

basic models. This and the other comments I'm

making are provided in a little more detail in our

written comments. NEMA agrees with the proposed 15

kVA lower limit for dry-type transformers. We do

not agree with the extension of dry-type energy

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

23

efficiency standards to ratings below 15 kVA. NEMA

shares DOE's concern that buyers could possibly use

what DOE calls harmonic distribution transformers

exclusions to avoid purchase of transformers meeting

efficiency standards. Consequently, NEMA proposes

elimination of these exclusions. NEMA believes that

strong enforcement of efficiency standards once

standards are adopted are a vital part of energy

conservation. NEMA believes that the basic model

definition is too vague and needs clarification.

And again, in our written comments we provide an

example of where we think that clarification is

needed.

FACILITATOR BROOKMAN: Thank you. Say

again what needs clarification?

MR. GRAY: The basic model definition.

FACILITATOR BROOKMA.N: Thank you. Who's

next? And I appreciate you being focused and

offering your comments in summary form. Who would

like to proceed next? No additional comments at

this time? There will be plenty of opportunity for

people to comment following the beginning of the

presentation. So if no one additional wishes to say

anything now then we'll proceed.

Okay. Then let's go to the next

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
24

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

presentation, which is Mike Scholand.

MR. SCHOLAND: That's a very hidden

light switch back there. The man behind the

curtain, pay no attention. My name is Michael

Scholand. I work at Navigant Consulting here in

Washington, D.C. We are supporting the Department

of Energy in the distribution transformer rulemaking

process, both the test procedure and the efficiency

standard which we'll be talking about tomorrow.

This morning I want to start by

discussing the definition of a distribution

transformer. The discussion of this definition can

be found in Section 2 (b) of the preamble of the

Federal Register notice, and the definition itself

appears in Subpart B of Section 432.10 of the

proposed rule, just to give you some crossreferences for that. For the definition overview,

the purpose of the definition is to identify the

transformers to which the department's test

procedure would apply. The definition is the

Supplemental Notice to Proposed Rule, or the SNOPR,

provides generalized numerical criteria and specific

exclusions, as you' ve seen . The definition has been

redrafted to be consistent with the scope of the

IEEE definition of a distribution transformer and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
25

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

with NEMA TP-1 and TP-2, which both have a scope

definition for coverage. But I'll talk about that

more in the next slide.

The previous proposed definition had

emphasized application description. I have a little

quote here from the previous, the 1998 Notice of

Proposed Rulemaking for the test procedure. It

reads that, "a distribution transformer transfers

electrical energy from a primary distribution

circuit to a secondary distribution circuit, or

within a secondary distribution circuit, or to a

customer service circuit. The problem with that as

discussed in the NOPR is the definition is imprecise

and could be subject to misinterpretation. So the

department developed a more quantitative-based

approach which we feel is more accurate.

In terms of the comparison between the

department's definition and TP-1 and TP-2, the kVA

range for both liquid-immersed and dry-type

transformers is the same. The primary and secondary

voltage ranges are the same. The DOE exclusions

list is largely the same as the exclusions in NEMA

TP-1 and 2. However, two differences to point out:

harmonic transformers are treated differently in the

department's proposed definition, and secondly the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
26

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

department does not exclude retrofit transformers.

We'll be discussing both of these issues in more

detail later in this presentation.

Let me go and present the department's

definition. The definition being proposed reads,

"Distribution transformer means a transformer with a

primary voltage of equal to or less than 35 kV, a

secondary voltage equal to or less than 600 V, a

frequency of 55 to 65 hZ, and a capacity of 10 kVA

to 2500 kVA for liquid-immersed units, and 15 kVA to

2500 kVA for dry-type units, and does not include

the following types of transformers." And then it

lists 15 exclusions. And each of these exclusions

are defined in the notice itself, as you've probably

seen.

Now let's look at five specific areas

where the department invites comments on the

definition. That is the exclusion of the 5 and 10

kVA dry-type, the exclusion of sealed and nonventilated units, the definition of a specialimpedance transformer basically by establishing

normal impedance tables, the K-factor threshold of

K-13 for exemption, and finally retrofit

transformers. Now I'm going to look at each of

these five issues and then at the end of each of the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

27

slides for these five issues we're going to stop and

have a discussion about it if there's any comments.

Okay, so let's start with the 5 an 10

kVA exclusion. The department's prior proposed

definition included these kVA ratings as

distribution transformers. However, stakeholders

commented that 5 and 10 kVA are not typically found

in distribution applications. The department

therefore is proposing now to exclude these ratings,

but we do invite further comment on this decision.

Doug? I don't know if you need to facilitate. Do

people have additional comments they'd like to make

at this time on 5 and 10 kVA being excluded from a

definition of a distribution transformer for drytype units?

FACILITATOR BROOKMAN: No additional

comments? Okay.

MR. SCHOLAND: Great, okay. Go to the

next slide. The exclusion of sealed and nonventilated units. Comments that were received in

the 1999 reopening notice for this test procedure

indicated that unique features for these products

may impose a hardship for some manufacturers in

testing them. Sealed and unventilated units

constitute a very small market share, and the

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
28

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

department believes that excluding them would not

result in the loss of significant energy savings.

These transformers are listed as exclusions in NEMA

TP-1 and TP-2. Therefore, the department is for

these reasons also excluding them from its

definition today. We invite comment and discussion

on this proposal to adopt this exclusion. Are there

any comments? Easy crowd today.

Alright, I'll go to the next slide.

Okay, there is -- for defining a special impedance

transformer, there is no precise IEEE definition for

special impedance. Second point, that the

department's proposed definition is based on

defining what constitutes a normal impedance. These

are the normal impedance tables which I alluded to

earlier. We are inviting comment on the tables of

normal impedance. Let me just read the definition

here. Special impedance transformer means any

transformer built to operate at the impedance

outside of the normal impedance range for that

transformer's kVA rating. The normal impedance

range for each kVA rating is shown in Tables 2.1 and

2.2. So if you turn the page in your handouts,

you'll see the two tables defining special

impedance. These are tables -- the first slide is

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
29

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

the normal impedance ranges for liquid-immersed

transformers by kVA rating, and then the next slide

shows the normal impedance ranges for dry-type

units.

Now, I was going to stop here and have a

discussion. We can have a discussion now about it

if you'd like, or you can also submit comments, of

course, by November 8. Give you more time to study

the tables and decide if you think these ranges are

reasonable ranges for normal impedance for each of

these kVAs. Yes, Jerry?

MR. HODGE: Gerald Hodge from Howard

Industries. How did you go about determining the

upper limit for those impedance limits? What basis

do you have for determining for that?

MR. SCHOLAND: Okay, thanks Jerry. The

question, just so everyone can hear, is how did we

determine the upper limit of the normal impedance

ranges for these kVA units. We actually used both

Paul Goethe and Dave Wiegand, the gentlemen seated

behind you, to put together these tables for the

definition, because there was no definition. So

this is just based on their experience with the

industry. So we're very keen on having

manufacturers and customers comment on whether they

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
30

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

think these are reasonable ranges.

FACILITATOR BROOKMAN: And let me note

that when the department asks specifically for your

comment, they would like to hear whether you like it

or don't like it both.

(Laughter)

FACILITATOR BROOKMAN: You know what I'm

saying? They're seeking specific comment.

MR. SCHOLAND: And if you don't like it,

what you would suggest instead. Thank you. Other

questions or comments at this time? Okay. We'll be

looking forward to some written comments on these.

Thank you.

The next slide referring to the

exclusion of K-factor transformers of K-13 and

greater. NEMA TP-1 excludes harmonic transformers

and transformers designed for high harmonics. The

department's definition broke that down into two

groups: harmonic mitigating and harmonic tolerating,

or K-factor transformers, and proposed definitions

of both exclusions. Part of the reason for this is

what happened, what was observed in Minnesota, where

a state standard was adopted, and basically

customers all started purchasing K-4 transformers to

basically circumvent the standard. Therefore, the

NEAL. R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
31

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

department proposed a cutoff of K-13 as the

exclusion for K-factor transformers, basically to

avoid that problem. So K-4 and K-9 or any other K

rating below K-13 would be considered distribution.

So the definition appears at the top of

this slide, that a K-factor transformer means a

transformer with a K-factor of 13 or greater that is

designed to tolerate the additional eddy current

losses resulting from harmonics drawn by non-linear

loads, usually when the ratio of non-linear loads to

the linear load is greater than 50 percent. So I

wanted to stop at this point and have a discussion

on K-factor transformers, noting that Ed Gray made

in his opening remarks a comment that NEMA believes

there's no need for this breakdown, and that all

harmonic transformers could be excluded. Sorry, we

don't need an exemption for harmonic transformers.

FACILITATOR BROOKMAN: Ed, do you want

to say a little more about that, explain your

position a little more fully?

MR. GRAY: Well, we made a pretty brief

comment, not as brief as I made a minute ago, but a

pretty brief comment in our September 13 comments.

I mean, I have no personal knowledge of people

trying to get around standards by using these

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

32

transformers, but if that is going on, NEMA doesn't

want that to continue. We want high quality

products in the marketplace. So that's why we made

the comment we did.

FACILITATOR BROOKMAN: Thank you.

MR. SCHOLAND: Okay, thanks.

FACILITATOR BROOKMAN: Additional

comments on this subject? And particularly from

manufacturers or other members of this community.

Yes, please. Walter.

MR. MOREHART: Walter Morehart, Acme

Electric. I believe that the K-factor, and I was

part of the NEMA task force committee on writing the

TP-l. One of the reasons for leaving out K rated

transformers was that there is no way, practical

way, to test the losses with those harmonics.

However, there is the problem that people are using,

and I have run into it Ed, K-4 transformers to get

around the requirement of the efficiency. So it is

necessary now to go back and revisit our position,

and that's the reason why NEMA will be taking out

the K-factor transformer. But we will have to

specify, and this is not figured out, but we will

have to specify how we are going to determine what

the efficiency of that unit is. But it's almost

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
33

2

going to be impractical to do it by testing.

don't know how you're going to generate the

I

3 different harmonics to get the unit tested. So it

4 can be done by calculation, and that's the method

5 that we ' ll have to come up.

6 FACILITATOR BROOKMAN: And Walter, do

you have a perspective on the approach the DOE is

8 suggesting here?

9 MR. MOREHART: I don't feel that K-13

10 will stop the practice. You take a small dry-type

11 transformer, and you multiply the straight losses by

12 13, you're not going to increase it much. So it'll

13 be more practical for a manufacturer to come in and

14 offer a K-13 transformer in place of a high

15 efficiency transformer.

16 FACILITATOR BROOKMAN: So do you have

17 any suggestions for the department about how they

18 proceed with this?

19 MR. MOREHART: Well, the NEMA suggestion

20 has been, or will be, that we're going to look at

21 changing that exclusion, eliminate it. The K rated

22 transformer should be part of TP-1. However, in

23 addition to that, we will have to add a section in

24 there how we're going to determine that efficiency.

25 Because it is not a testable efficiency, that I know

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
34

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

of.

MR. SCHOLAND: Thanks.

FACILITATOR BROOKMAN: Thank you for

that comment. Do we have any additional comments

following onto Walter's? Yes, please, Rob.

MR. GREESON: Rob Greeson, Federal

Pacific Transformer. Just adding to that comment, I

work a great deal with quoting transformers from day

to day. And I see a very large number of energy

efficient transformers required to comply with TP-1.

However, they have no qualms about adding additional

K-factor requirements on that as well. And we have

repeatedly pointed out that they are excluded in the

NEMA TP-1 standard K-factor transformers. However,

that does not seem to be something that they care to

hear. They just, well, it has to be both. So given

the fact of the problem of measuring the losses, and

it's not really covered in the standard. Typically

what we have to do is make a statement that the

transformer is compliant only as a -- under linear

loads, or K = 1. And that's the way we've addressed

that.

Now, I provide that just to really share

that that's something we run into, but we quote

every day transformers that are K-factor and TP-1.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
35

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

We have to make that further definition to state

that it's TP-1 compliant only if you treat it like

it's K-l. And that's kind of what we've -- and I'm

not saying that's a good thing or a bad thing, but

that's about the only choice that we have at this

point.

MR. SCHOLAND: A very useful comment,

thank you. Other comments on K-factor? Okay.

Now my fifth issue, the fifth slide

here, the department does not have an exclusion for

a retrofit transformer. In both the test procedure

NOPR and the reopening notice, the department sought

specific input from stakeholders on how to handle

retrofit transformers. Comments received indicated

that retrofit transformers may be larger than

existing ones that could impose expensive

installation costs such as breaker and switch gear

replacement, adjusting terminal locations, and/or

enlarging the transformer room or access doors to

where the transformer is installed.

Additional clarification or specific

information pertaining to the definition of a

retrofit transformer was not provided in response to

the reopening notice. So there is no exclusion in

today's proposal for a retrofit transformer. And

NEAL R. GROSS

COURT REPORTERS Al D TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
36

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

the department is seeking comment on the treatment

of retrofit transformers. We have some comments

now, some discussion on retrofit transformers.

FACILITATOR BROOKMAN: I'm wondering why

no comments showed up the first time around on

retrofit transformers. Ed Gray.

MR. GRAY: In our discussions, we saw it

as a problem, but we had not as yet come up with

some proposed solutions, so it's not in our

comments.

FACILITATOR BROOKMAN : I see . Are you

getting towards creating a proposed solution? Do

you not have a recommendation yet for the

department?

MR. GRAY: That's correct.

FACILITATOR BROOKMAN: Okay. Yes,

please, Gerald Hodge.

MR. HODGE: Gerald Hodge from Howard

Industries. We too are called upon at times to

provide a retrofit transformer that the customer has

certain requirements in order to be able to put this

new unit in in place of some 1942 model. And I

think we've got to find some way to be able to do

that. I'm not sure what the answer is yet myself,

but I can understand his needs, and the cost issues

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
37

1 involved. It makes a lot of sense to provide some

2 way to do that.

3 MR. SCHOLAND: Well, Jerry, we look

4 forward to some written comments in that regard from

5 you. Thank you.

6 FACILITATOR BROOKMAN: Additional

7 comments on this slide and the preceding slides?

8 And any other issues related to this cluster.

9 Definitions, generally.

10 MR. SCHOLAND: I guess you've all had a

11 chance to look at the 15 exemption definitions.

12 They're derived from the IEEE, primarily. Some of

13 them, such as special impedance, were crafted in14 house. If there's any of the 15 that you want to

15 discuss specifically I do have a slide on each of

16 them. So that was the idea at this point was to

17 discuss any other issues or questions that you might

18 have on a definition of distribution transformer.

19 (No response)

20 Okay, great. Well, that's the

21 definition. Thank you.

22 FACILITATOR BROOKMAN: So we're ahead of

23 schedule, and we're going to proceed to definition

24 of the basic model, and Mike Scholand's going to

25 keep presenting. He's going to press on with the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
38

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

next set of slides.

MR. LEWIS: Doug?

FACILITATOR EROOKMAN: Yes, sir. Yes,

Ron.

MR. LEWIS: Ron Lewis, Department of

Energy. Ed, you had mentioned earlier in your

comments and I think in your letter that you

submitted that you thought the definition previously

used was vague and needed clarification. Do you

think that the specificity put in there is going in

the right direction, is helpful in that regard?

MR. GRAY: Well, in our written comments

we indicated specifically the area that we thought

was a problem. I'm sure it was intended to be

helpful, but there was a phrase at the end of the

definition that said, "and do not have many

differentiating electrical, physical, or functional

features that affect energy consumption." And we

were concerned that that particular phrase could add

to additional basic models at some later date, you

know, just kind of confuse the testing and all that

was actually needed. So we would like a pretty

tight definition of what that means.

MR. SCHOLAND: Just a point of

clarification, that Ron and Ed are discussing this

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

39

presentation, the definition of a basic model. The

comments that Ed was giving did not relate to a

definition of a distribution transformer.

MR. GRAY: That's right.

MR. SCHOLAND: Okay. Right.

FACILITATOR BROOKMAN: So then let's

proceed, then, with these slides, and take

additional comments.

MR. SCHOLAND: Not very many slides in

this presentation. The purpose of a basic model is

to reduce the testing burden by enabling

manufacturers to group products having essentially

identical characteristics with respect to energy

consumption into the same basic model. Basic model

is the finest level of disaggregation at which

manufacturers rate the efficiency of a distribution

transformer. And manufacturers will rate the

efficiency of each basic model either by testing a

representative sample or by applying a substantiated

AEDM. That's the Alternative Efficiency

Determination Method, which Cyrus alluded to

earlier, and that will be the final presentation

today, on the AEDM.

So, the next slide. Changes from the

previous definition of a.basic model from the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE. ISLAND AVE., N.W.

(202) 234-4433 WASHINGTGN, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
40

1 reopening notice. It's essentially the same basic

2 model as proposed in the NOPR, with a requirement

3 that Ed Gray just read, that the basic model should,

4 quote, "not have any differentiating electrical,

5 physical, or functional features that affect energy

6 consumption." These are some other changes which

7 are a little more subtle . We omit the provision

8 that transformers within a basic model must operate

9 within the same voltage range as this is encompassed

10 in the new requirement that I read above in the

11 previous bullet. And it also revises the provision

12 from, quote, "have a comparable nominal output power

13 kVA rating" to "have the same standard kVA rating."

14 We just felt that the language was a little clearer

15 that way.

16 The standard kVA ratings are defined as

17 those appearing in the IEEE standards C57.12.00 and

18 C57.12.01. And stakeholders had sought in the past

19 that basic model be essentially all designs having

20 the same nominal kVA rating. However, this is

21 inconsistent with the nature of groupings the basic

22 model is meant to permit in the context of

23 Department of Energy test procedures.

24 So let me go to the next slide. The

25 basic model definition reads, "Basic model means a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

41

group of distribution transformers manufactured by a

single manufacturer that have the same insulation

type (i.e., liquid- immersed or dry-type), have the

same number of phases (i.e., single or three), have

the same standard kVA rating, and do not have any

differentiating electrical, physical, or functional

features that affect energy consumption." And then

the standard kVA ratings are defined in the table

that you see.

Now, with respect to a kVA rating, there

are many design option combinations of core steels,

windings, dimensions, number of turns, and so on,

that can be changed. And as these variants in the

design will affect energy consumption, it would

appear that within one kVA rating you could have

several different basic models.

So I'd like to stop at this point and

have a discussion on the definition of a basic

model. Ed, does this provide any clarification in

terms of that sentence?

MR. GRAY: Well, we made another written

comment that was -- there is a table in there that

has basic models, and there's some footnotes on the

table, and our written comments sort of get to that.

It's sort of like if the table is the basic models,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

42

and the only basic models, if you want to look at it

that way, then maybe that's alright . But we were

concerned that this phrase at the end could be

construed to generate additional basic models later,

additional burden on the manufacturers.

FACILITATOR BROOKMAN: Would you suggest

what to do with that phrase? How to modify it for

the department's benefit?

MR. GRAY: I can take that back to the

members and we can provide something in the written

comments.

FACILITATOR BROOKMAN: Thank you, that

would be helpful.

MR. SCHOLAND: John Talbott. Do you

want to grab a microphone, John?

MR. TALBOTT: John Talbott, consultant

with NIST. And I think this issue gets to some of

the old definitional problems we used to have. And

it concerns product classes and basic models.

Sometimes it's easy to say they're the same thing,

but a product class is these various distinctions of

which a manufacturer could make all of them. And

then within a product class, a given manufacturer

could make more than one version of that product

class. And that's what we're trying to define as

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

'1,:23 RHODE ISLAND AVE., N.W.

(202) 234-4433 t `ASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

43

basic model. And that's where -- you don't get that

difference. Maybe with distribution transformers

there may not be any other differentiating things

within a product class. So there is only one basic

model for that product class.

But if you have something that's

physically different that affects energy efficiency,

then that would constitute a different basic model.

So you would have, for example, a high efficiency

version of a 10 kVA single-phase transformer. And

you would have a standard efficiency version of a 10

kVA transformer. And those would be different

represented values for those basic models. So

hopefully that helps. It's product class and basic

models. To some people they're the same thing.

FACILITATOR BROOKMAN: Thanks John. Any

comment following that explanation?

MR. GRAY: It seems to me --

FACILITATOR BROOKMAN: Ed Gray speaking.

MR. GRAY: It seems to me if you have an

energy efficiency standard for that basic model

that's what the standard is. I mean, if you wanted

to produce a transformer more efficient than that

you certainly may. But that the standard has a

certain baseline efficiency level that has to be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
44

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

satisfied.

MR. SCHOLAND: That's correct, Ed, and

the basic model could be your design that's

compliant with the standard. And then you may have

different basic models that are more efficient than

the standard. And even at the same efficiency

you've got a combination of core and coil losses.

And if you do a different tradeoff to arrive at the

same efficiency at a given loading point, those

would also be different basic models.

MR. GRAY: I think what I'm saying here,

and this is kind of reacting to the comment, is I

don't understand why that's a different basic model.

It seems to me if you have a certain basic model, if

the customer wants a higher efficiency transformer

with that same rating, then the manufacturer will

provide that. But I don't see what that has to do

with creating another standard, another basic model.

FACILITATOR BROOKMAN: John? John

Talbott.

MR. 'TALBOTT: John Talbott. The

difference is that you have a high efficiency

version of the same product class. That's the

concept. You may want to represent the efficiency

of a higher efficiency version of a given product

(202) 234-4433

NEAL R. GROSS

13OURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

45

class. And that would constitute a different basic

model. You're distinguishing your high efficiency

line within a product class. Now we expect that's

going to happen. And it may be manufacturers would

have three different versions of a given product

class, and there would be three different basic

models. And we're at the test procedure phase, so

we're talking about just representing your

efficiency, not meeting the standard. The standard

is down the line. This'll come up later in the

sampling provisions as well.

MR. GRAY: Well, we currently have a

similar circumstance in a lot of products. You

know, we may have an efficiency standard for some

product, and we may have an Energy Star product, or

something like that that's voluntary that has a

higher efficiency. But I still don't see what that

has to do with coming up with another basic model

which conceivably could have different testing,

different efficiency standards, and labeling. I

don't understand why we need that.

MR. TALBOTT: Well, it's so --

FACILITATOR BROOKMAN: John Talbott.

MR. TALBOTT: You would have confidence

in the Energy Star level representation. It has to

NEAL R. GROSS

COUF r REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 rIASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
46

1 meet the statistical quality as meeting a minimum

2 efficiency standard.

3 FACILITATOR BROOKMAN: Ed Gray.

4 MR. GRAY: That's a voluntary program,

5 and that's handled in the context of that program.

6 That's not handled in the context of an energy

7 efficiency baseline standards program. I guess

8 that's the point I'm making. And we can address

9 that further in our written comments later now that

10 I understand the thinking behind it.

11 FACILITATOR BROOKMAN: Thank you.

12 Additional comments on this? Mike Rivest.

13 MR. RIVEST: I'd like to say something.

14 FACILITATOR BROOKMAN: Mike Rivest.

15 MR. RIVEST: This draws more on my

16 experience on other consumer products, but a basic

17 model is basically locking in the configuration, a

18 physical design that can then be tested and

19 extrapolated to every similar design without having

20 to retest. So it's not about the minimum efficiency

21 standard. It's not -- you see? It's about

22 extrapolation to a larger population. If you have a

23 transformer which is made of different core steels,

24 different copper, you know, different configurations

25 core, you cannot just test the one which is built a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

47

certain way and then extrapolate or label something

built completely differently with the same

efficiency. Neither of them attest to meeting the

minimum standard. So it's not a new standard level

to meet, or something like that, which I thought

there was some confusion there.

FACILITATOR BROOKMAN: Okay. Comments?

MR. SCHOLAND: Okay. That's actually

the whole presentation. Trying to keep it brief so

there's time for discussion. So if people have any

other remarks to make on the definition of a basic

model? We look forward to other comments in

writing.

FACILITATOR BROOKMAN: Okay. It's now

10 minutes after 10:00. I'm going to suggest we

keep plugging along. We didn't start till 9:15

almost, so let's press on with the next

presentation, which is Oskars Petersons. The

Uniform Test Method for Measuring Energy

Consumption.

MR. PETERSONS: My name is Oskars

Petersons. I'm with the National Institute of

Standards and Technology. Used to be employee at

one time there. Right now I'm consultant or

contractor.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

48

I'm going to outline Uniform Test Method

for Measuring Energy Consumption of Distribution

Transformers. This topic is covered in the proposed

rule 10 CFR Part 432, Subpart B, Appendix A. It's

towards the end of the document.

General characteristics of the proposed

test method. Content is based largely on the four

IEEE standards in C57 series 12.90, 12.91, and then

12.00, 12.01, and also on NEMA standard TP-2.

Organization of the document is similar to that of

the NEMA standard TP-2. In some items, more detail

is added, and language modified, because a proposed

DOE test procedure is mandatory and not a voluntary

guideline. Any comments at this point on general

considerations? Okay.

Key elements of the test method are

listed in this slide. They are similar to those in

TP-2. I shall comment on each of them as I present

the next five slides. Well, first, key element.

Test system accuracy requirements. The table is

identical to that in TP-2, and 12.90 and 12.91. So

no change there.

The next one is resistance measurement

element. Includes measurement of winding

temperature, direct current resistance measurement,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
49

transformer windings, including instrumentation

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

and conversion of the measured resistance to the

value at the reference temperature. The DC

resistance measurement is required only for one unit

of a basic model, since this measurement is

considered as design type measurement in IEEE

standards. Any comment on resistance measurement?

The next key element is loss measurement

element. Includes description of test sites for

measurement of electric power loss, measurement of

no-load loss, and application of corrections to the

measured data. That is if these corrections are

significant and therefore required. The measurement

of load loss and application of corrections. And

finally, adjustment of load loss data to reference

temperature. Any comments on loss measurement?

Then determination of efficiency. It

includes adjustment of the load loss to the value at

which the efficiency is rated. And this is at 35

percent of the rated full load for low voltage drytype transformers, and 50 percent of the rated full

load for all liquid-immersed transformers, and

medium voltage dry-type transformers. The losses

are calculated, and then the efficiency is

calculated. The total losses are calculated, and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

50

then the efficiency. Any discussion comments here?

Now, the final element is test equipment

calibration and certification element. It is

similar, almost identical, to that in NEMA 2, and

describes all steps involved in use, maintenance,

and calibration, and record-keeping of test

equipment. Comments? No.

Now, finally, an opportunity for you to

discuss other issues related to the test method.

FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: Yes, this is Ed Gray. This

is our comment that we made in writing, which is we

had the motor standard which is out there, we have

experience with, doesn't use this approach. It

refers to industry consensus standards, the IEEE

standards, the NEMA standards, IEC standards. And

the people skilled in the art know what's in those

standards. So what's being done here with this

approach is laying a standard out there. I'm not

commenting on how good, bad, or indifferent the

standard is, but something that people are going to

have to learn all over. You know, it takes many,

many years for somebody to be skilled in these

standards. There are representatives from the

stakeholders that thoroughly understand what's in

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WAS"s EINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

51

TP-2 and the IEEE standards, and now it's like we're

saying, well, you know, we sort of took bits and

pieces from those, and our best judgment, DOE's best

judgment on where things could be improved, and now

the participants in the industry are going to have

to learn all this all over again. And these

standards always have lots and lots of nuances that

requires a lot of experience for people to fully

understand. So I think this is going to create a

lot of difficulty in the industry. And it seems to

me that referring to the standards -- changing the

industry standards where they need to be changed, we

don't have a problem with that if the stakeholders

decide that those changes are needed. But rather to

toss the baby out with the bathwater we don't think

is a very good idea.

FACILITATOR BROOKMAN: Can you be

specific about what you would propose the department

do?

MR. GRAY: Well, what we would like to

see is to, as the motor standard does, refer to the

industry consensus standards that are out there.

The people that are in the business of designing,

manufacturing, testing these components know their

business, their day-to-day jobs. And so if you

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
52

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

would like changes in TP-2, if everybody thinks

that's a good idea around this table, all

stakeholders involved, then we would be willing to

consider doing that. And then the final rule could

just refer to the industry consensus standards,

NEMA's, IEEE's, whatever, as opposed to something of

whole new cloth.

FACILITATOR BROOKMAN: Thank you.

Additional comments from other persons?

Manufacturers, interested parties? Cyrus.

MR. NASSERI: Well, the department

policy always has been, not for this product, for

other products, to reference industry standards,

consensus standards. But in the rule that we

published, we stated very clearly the comments we

have about TP-2. And we basically in the preamble

part we stated all those. The lack of clarification

being the mandatory language compared to voluntary

language. And as you recall originally we did

reference either the method of TP-2 or IEEE. And

because of the nature of comments and the view of

the nature of the test procedure, the decision was

that we will have a test procedure as we said. We

incorporate almost every requirement of the TP-2 and

IEEE in our test procedures.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

53

But one thing that again I mentioned is

our sensitivity about timing. And that we have to

have a test procedure in place before the

publication of a NOPR for the standard rulemaking,

as you know it is a parallel line you're doing. And

if NEMA is going to make comments and you would like

to hear that, that they would like to revise,

whatever the committee is handling TP-2, in

accordance with what DOE's proposal is, assuming

that they accept what we say in our proposal, the

only issue of sensitivity that we have is that the

timing. When are you going to revise the 1998 TP-2?

And do we, I said, very sensitive about the timing,

do we have time to go ahead and reference that. And

then if that happens, do we need to reopen the NOPR

again because of the certain things we are going to

change and is not basically discussed in this

meeting which sometimes can happen? And again, we

are very much sensitive about the time for this

rule.

FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: The thing about referring to

existing standards is people understand what they

mean. And we can change places here and there, in

TP-2 or wherever, to satisfy stakeholder needs. But

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

54

if we go to what's proposed here, we have to have a

whole lot of people throughout the industry really

thoroughly understand what you're proposing in lieu

of TP-2 and the IEEE standards before we can even

comment on what you've done. I mean, this is going

to be a very difficult, detailed, time-consuming

process that perhaps isn't needed.

My understanding, and we haven't

discussed that here, is that a key DOE concern about

TP-2 is the CAFE-like nature of it. In other words,

the way TP-2 is worded is you have a 6-month rolling

testing of your output of a given manufacturer, and

the rolling average has to satisfy the overall

efficiency standard. We could argue about whether

that's good, bad, or indifferent, but my

understanding is that that's a concern. We

discussed this in the NEMA membership, and we are

willing to have every basic model satisfy the

standard, and not this rolling average of production

of all the transformers. So that's, again, why

we're pretty concerned about getting the basic model

definition, some reasonable number, because we're

saying that every one of those has to meet the

standard.

(202) 234-4433

FACILITATOR BROOKMAN: Yes, Cyrus.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
55

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Please.

MR. NASSERI: Well, the CAFE standard

obviously is a sensitive issue because in other

appliances that we have we cannot apply that to the

efficiency and compliance, basically, for the

deficiency. But what our concern is is that the TP2 being very much a general test procedure --'for

example, in TP-2 refers to keystone bridge, and

doesn't say, you know, well, talking about experts,

they might know. But what we get to sample, we kind

of throw a figure for keystone bridge, what it is,

and be very detailed, since our standard's mandatory

for the manufacturers or the interested parties to

follow. We were not able to really have a standard

which is not in detail. And our feeling is TP-2 is

not as detailed as we need for a DOE test procedure.

FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: Well, we have the same

situation, and maybe I don't want to say this, but

we have the same situation in all the other products

we have standards on. You know, we have industryaccepted ways of testing lamps, lamp ballasts,

electric motors, you name it. Everything that has a

standard has a generally understood industry

consensus way of doing the test. And the DOE rule

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
56

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

says that you shall comply with such and such a

standard, and that gives it the force of law. This

is no different than ASHRAE standards in states

around the country. They don't have any standing as

a law or a regulation till some agency like yourself

declares that they are. And at that point, if TP-2

gets references, then people would have to comply

with that as of some date. So all we're saying is

why should this be different than all the other

standards that are out there, all the other testing

methods. I don't think we have to get down to EE101

in this kind of a standard.

FACILITATOR BROOKMAN: Ron Lewis.

MR. LEWIS: So your major concern is the

methodology approach of establishing a DOE versus

the TP-2 or the existing standards generally. And

you anticipate having further comments as far as any

issues within there where you take exception to.

The two different tracks, one is the methodology,

and the second would be the specifics? Is that?

MR. GRAY: Yes, we'll do that. I don't

know how much between now and November we'll be able

to go through the details. I mean, there may very

well be some disagreement technically, possibly with

something you've chosen to put in there. I'm in no

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

57

position to know that or not know that at this time.

MR. LEWIS: Thanks.

FACILITATOR BROOKMAN: Well, Ed, one

thing that I thought I heard the department

referring to was the timetable involved here, and

the potential for revising TP-2. Can you respond to

that? Would it be possible for NEMA to respond to

the DOE's intended timeline to revise TP-2?

MR. GRAY: Well, first of all we'd have

to of course get all the stakeholders involved, and

there's a lot of people in this room. You know,

there's utilities in here, manufacturers that aren't

NEMA members, and so forth. We would have to have

some consensus on what revisions would be needed.

It turns out that TP-2 for better or worse is not in

the American National Standards Institute process,

and the utilities have had problems with that in the

past. The good news is the ANSI standards process

has lots of stakeholder involvement. The bad news

it can take a long time. So we could, I would

think, revise TP-2, if we could agree on the

changes, pretty rapidly from a process standpoint.

You might -- just for people's

information, the energy bill that's been stalled in

Congress has TP-l, 2, and 3 in there for low voltage

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
58

1

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

dry-type transformers. And there was an

implementation date of the first of next year in

there. So I think if we could understand what the

game plan is very quickly then we could react to

that. But if it's simply a matter of changing each,

you know, the idea of the rolling average of

efficiency versus each individual model that

wouldn't be very hard to change. However, the

nature of these standards is, and I think a lot of

the people in this room understand this, is there is

a certain level of skill involved in the people that

write the standards, that use the standards, and so

forth. And we don't have to dot every `i' and cross

every `t' for them to know what they're doing in

their day-to-day jobs. And that's kind of what's

different about this particular DOE proposal.

FACILITATOR BROOKMAN: Ron Lewis.

MR. LEWIS: Ed, if we had people that

were available to point out, answer questions on

where you've got questions of things that are in TP2 or IEEE, and what's embedded here just on what we

did of what's in there to assist, would that be of

help to you as you're going through it looking for

where are those differences?

MR. GRAY: Yes, that would certainly be

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
59

1 helpful. I think, however, we're starting kind of

2 in different places. I'm starting from sort of like

3 the motors rule. In order to apply the motors rule

4 you have to be expert in NEMA standards, IEC

5 standards, IEEE standards. And the assumption is

6 that people are. And you know, that's the law of

7 the land now for that particular type of product.

8 And so -- and that was a lot easier to get ourselves

9 through, I think, than this approach of starting

10 from completely new cloth.

11 FACILITATOR BROOKMAN: I think we have

12 an additional comment. Your name, please, for the

13 record?

14 MR. WIEGAND: Dave Wiegand, contract

15 employee of Navigant. Just in comparing the IEEE

16 standards, IEEE C57.12.90 and 12.91 with the DOE

17 test procedure, there is really awfully close

18 concurrence between the two. But DOE tries to bring

19 the loading down to 50 percent load for liquid20 filled transformers, and also some of the dry-type

21 transformers, and a 35 percent load for most of the

22 dry-type transformers. Okay. There is one

23 difference in all of this that sticks out in my

24 memory, and that is the reference temperature for

25 liquid-filled transformers in the test procedure,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
60

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

recognizing that the intended load is 50 percent,

the temperature is 55 degrees Celsius as a reference

temperature. In NEMA, which reflects the IEEE

standards, there is the same 50 percent load spoken

about, but the reference temperature is given as 85

degrees Celsius. That is the only difference that

I'm aware of. Now, having looked at NEMA TP-2, and

I brought a copy of it along, I have it back at my

hotel room for closer reference if called upon, it

leaves a few of the details floating, incomplete,

whereas the test procedure picks up those floating

details and carries them through to completion. So

I would just like to -

FACILITATOR BROOKMAN: Thank you for

that comment. Ed, do you wish to respond now?

Oskars Petersons has an additional comment.

MR. PETERSONS: I'd just like to add

that with respect to technical content, there is

essentially no difference between the proposed DOE

test procedure and various items in IEEE and TP-2.

We did start out with TP-2 to be referenced in

whole. Well, we went, started the review process.

It was rejected because of too abbreviated language

in it, as was said, left things uncertain.

Suggestion was, well, why did you not go

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. :20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
61

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

to IEEE standard? There was another problem which

was earlier addressed that in that case we would

have to take various paragraphs out of four

standards and reference to those. That was

considered unsatisfactory also. So basically in

proposed document, the technical content is nearly

identical to existing standards.

MR. GRAY: Well, I mean, it would be

good if you could --

FACILITATOR BROOKMAN: Ed Gray is

speaking.

MR. GRAY: -- provide us that list of

where the "nearly's" are so we understand what's

different.

FACILITATOR BROOKMAN: Okay? Good,

that's helpful. I'm certain the department and its

contractors can provide that. Ron Lewis?

MR. LEWIS: Ed, I think that as you were

approaching it and trying to discuss it with the

committee that works on the TP-1 and TP-2 standards,

et cetera, that you are bound to have questions. I

think having a contact point for you where you can

ask things, rather than trying to come up with all

the answers in advance, just saying here's a list.

I could see a dynamic point where we're not getting

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
62

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

into things we can't do during the comment period,

we have certain limitations, but trying to help you

to understand where it is and how it compares to

things. Simply clarifying from an educational

standpoint, we can give you a lot of assistance

there as you're trying to do it, rather than just

give you a static list and say this is just what we

see right now. Because there may be other

questions. So I don't want it to stop at just

here's a conveyance, here's a contact.

MR. GRAY: Thank you.

MR. LEWIS: That, by the way, is not

just for NEMA. This is a general reference. And

we're not looking for addressing just anybody. You

were bringing up specifically the NEMA's TP-2

standard, so I'm addressing that. But it's not to

be to the exclusion of non-NEMA stakeholders.

FACILITATOR BROOKMAN: I think I hear

you making a general invitation from anybody here or

beyond here that wants to seek additional

information to contact you and be prepared to make

your comments prior to the comment deadline.

MR. LEWIS: Yes. We want everybody to

clearly understand what's embedded, what's the

content, what are the technical things that are in

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

63

the test procedure. And we actually held a webcast

trying to help people to understand the tools that

are in the ANOPR that we're going to talk about

tomorrow and other rulemakings in the test

procedure, trying to make sure that everybody's

comfortable with what's there and there is a

dialogue. And we tried to off-load some of these

things so we could have more discussion and have

more input and not have just a one-way taking turns

talking kind of thing, but working together to try

to gravitate to something that makes sense and

that's fully understood.

FACILITATOR BROOKMAN: Final comments on

this set of slides? Okay, I see none. We have

scheduled on the agenda two more

presentation/discussion periods, followed by an open

comment period following those two. It's now 10:35.

Do you want to take a break now? Let's take a break

now. It's 10:35. We will resume at 10:50. And it

seems right now we're on course to finish early

today for those of you that are wanting to know how

this may proceed. So we will resume at 10:50 and

thanks for a good start on the day.

(Whereupon, the foregoing matter went

off the record at 10:36 a.m. and went back on the

NEAL R. GROSS

COURT REPORTERS AID TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
64

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

record at 10:53 a.m.)

FACILITATOR BROOKMAN: Our next

presentation and comment/question period following

the presentation segments is on sampling plans for

compliance and enforcement testing, and we'll be

hearing again from Oskars Petersons, and also Ken

Stricklett.

MR. PETERSONS: Well, in this

presentation Ken Stricklett and I are going to

outline sampling plans for compliance and

enforcement testing. I will start with the

compliance plan and then Ken will continue with the

enforcement plan.

Well, the purpose of compliance testing

is to establish on a one-time basis the efficiency

of the basic model. Selection of units. For each

basic model, a sample of five or more units is

selected. If fewer than five units are available,

all units are tested, but a basic model is used for

substantiation of AEDM, Alternative Efficiency

Determination Method, the sample size must be at

least five units.

The next step is use of the operating

equation. The average efficiency of the sample is

calculated, and the results are compared in the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
65

first equation. For compliance, the average

2 efficiency of the sample must be equal to or larger

3 than the right-hand side of the equation, which does

4 contain the represented efficiency. Compliance can

5 be expressed also in terms of power loss according

6 to the second equation, which gives a simpler

7 presentation.

8 MR. SCHOLAND: Oskars?

9 MR. PETERSONS: Yes.

10 MR. SCHOLAND: Do you want to comment on

11 the edit we made, rated efficiency versus

12 represented efficiency in the first equation?

13 MR. PETERSONS: Right. Well, here RE is

14 -- okay. Yes, in first equation, RE is defined on

15 slide here as represented efficiency.

16 Unfortunately, when handouts were made, there was an

17 error where instead of represented efficiency, rated

18 efficiency is used. Once we have the standard out,

19 they sort of become synonymous, but at this stage it

20 is represented efficiency.

21 FACILITATOR BROOKMAN: So what's in the

22 slide there, for that first equation on Slide 4,

23 should read RE = represented efficiency, not rated

24 e ffi c i ency.

25 MR. PETERSONS: Well, for expression in

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
66

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

terms of power loss, the correct term is used,

represented power loss. Now some comments on

operating equation of the sampling plan. The

magnitude and functionality of the expanded

uncertainty term, and that is this 0.05 divided by

square root of N, that effects results very

directly. The plan is related to the statistical ztest. The statistical basis and operating

characteristics are discussed in considerable detail

in NIST Technical Note of which the copies are

available at the desk. Well, at the entrance table.

Now, opportunity for stakeholders to

make comments, suggestions. Yes, sir.

MR. WILKS: Alan Wilks, ERMCO. What if

a manufacturer chooses to test all the units 100

percent? Then the AEDM would not apply? Is that

correct?

FACILITATOR BROOKMAN: I was going to

say, please repeat the question to make sure I heard

you correctly, Alan.

MR. WILKS: Okay. If a manufacturer

chooses to test 100 percent of the units, whether

it's five or less, or five or more, the sampling

plan as described, the AEDM plan would not -- you

wouldn't have to use that, right?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
67

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. PETERSONS: That is correct.

FACILITATOR BROOKMAN: Ron Lewis.

MR. LEWIS: I believe that the AEDM was

put in place so you wouldn't have to do 100 percent

testing, and that if you are doing 100 percent

testing that the alternate route was put in place to

try to make life easier. If you're already doing

100 percent of the testing, you're taking the more

rigorous route. So it would not be appropriate

then. Is that correct, Oskars?

MR. PETERSONS: Correct. But AEDM is

really a substitute for testing so that you don't

have to test eventually all the basic models.

FACILITATOR BROOKMAN: And we'll get

into more detail on that in the next set of

presentations. Are there comments at this stage on

these details and definitions regarding the

equation, and I guess definition of the sampling

plan?

MR. GRAY: Ed Gray again. I'd just like

to clarify that the proposed rule does indeed say

what Slide 3 says, because I didn't read it that

way? If fewer than five units are available, a

reasonable time to test all units. That is what the

proposed rule in fact says?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
68

1 MR. PETERSONS: Yes.

2 MR. GRAY: Okay. Because I thought

3 there was some way of plugging different sample

4 sizes in the equation where N could be five or less.

5 MR. NASSERI: No, it --

6 MR. GRAY: Okay, thank you.

7 MR. PETERSONS: The equation addresses

8 sample size from one to entire populations.

9 FACILITATOR BROOKMAN: Those last

10 comments were from Cyrus, and then back to Oskars.

11 Ed, did you have any additional comment or question

12 at this point?

13 MR. GRAY: I thought what you just said

14 was inconsistent with what this says. You said

15 sample size from one to whatever, but the sample

16 size can't be that small a sample size. You have to

17 test everything if i t i s, ri ght?

18 FACILITATOR BROOKMAN: Oskars first.

19 MR. PETERSONS: No, you don't have to

20 test everything if you -- if for other reasons you

21 need to test everything you can do it. But you

22 don't have to test everything. You can limit to

23 sample size of five, even if you have more than five

24 units manufactured. But if you want to use entire

25 population on demonstrating compliance, you can do

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
69

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

it.

FACILITATOR BROOKMAN: Ron Lewis.

MR. LEWIS: The AEDM is the last thing

on the program today. So we're going to go through

that more thoroughly. And if you have any questions

after that part of the presentation, make sure to

jot those down and let's go through that thoroughly.

FACILITATOR BROOKMAN: Okay.

MR. PETERSONS: Thank you.

MR. STRICKLETT: I'm Ken Stricklett, and

I'm from the National Institute of Standards and

Technology. And I'd like to take a few minutes to

outline the major provisions for enforcement testing

proposed for distribution transformers. My comments

are intended only to be a brief introduction for the

day's discussion. A full description of the

enforcement testing procedures proposed for

distribution transformers can be found in the

Supplemental Notice of Proposed Rulemaking. It's

included in two sections in that proposal. There's

the general provisions are included in Section

432.13, and then there's also the sampling plan for

enforcement testing, which is the Appendix B to

Subpart B. So those are the two significant areas

you want to look at in the proposed rule.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

70

There's analysis Oskars mentioned of the

operating characteristics of both the compliance

demonstration sampling plan and the enforcement

testing sampling plan is in our tech note. There's,

again, copies at the back of the room which you're

more than welcome to have a copy. And if you have

any questions please by all means contact either

Oskars or I and we can discuss that.

This proposal for enforcement testing is

new. It had not been included in the earlier

rulemakings. And so I wanted to go into a little

bit of detail and maybe some background on it. So

it's very similar to what's in place for consumer

products and for electric motors. We basically took

what was in place for those two product classes and

modified it to what we thought was appropriate and

reasonable for distribution transformers. The key

provisions of the enforcement test procedures

include the test notice. They're also in the

general description section. There's guidelines for

the selection and preparation of units. There's

the, as I mentioned earlier, the sampling plan for

enforcement testing. And I want to emphasize that

there's also the option for the manufacturer to do

further testing which I'll explain a little bit

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE: ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
71

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

further in the next slides.

The test notice is a formal notification

of the details that are required during an

enforcement testing procedure. So that would

clarify what transformer is to be tested, how the

units are to be selected, how many units are to be

selected, and the place in time that testing would

be started and when it's scheduled. Now, so that's

the sort of notification to the manufacturer from

the Department of Energy that a testing is under

way. Before that notice is ever issued, the

department takes steps to clarify any discrepancies

in the product. The department will examine the

underlying test data and will also offer the

manufacturer an opportunity to meet with the

department to reconcile any discrepancies. And then

there's further provisions. If an AEDM, that is if

an Alternate Efficiency Determination Method is

used, then the department may ask the manufacturer

to -- they may ask that specific calculations be

conducted, or witness any re-verification of any of

the calculations, or ask that specific models,

specific transformers might be tested. So there's a

little bit of -- in that case there's a little

additional flexibility.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
72

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

The sampling plan is based on methods

that are very well established. The sampling plan

involves a test on the mean of a sample, and

ultimately it's based on what's known in statistics

as a t-test type protocol. The general provisions

for the sampling plan include that the test would be

conducted using the DOE test procedure, which Oskars

had discussed earlier, and that up to 20 units could

be selected for testing, and that five units should

be tested initially. The sampling plan is built

around a 97.5 percent confidence limit, and that

would imply or that by design the risk of a false

outcome, a false determination of non-compliance is

not greater than 2.5 percent. And there's also,

which I'll mention on the next slide, a test for the

sample size, to validate that a sufficient number of

units have been tested. And that's based on a five

percent tolerance on the losses. And there are some

other modifications of the enforcement testing plan

to accommodate the specific needs of transformers,

and that is allowances for testing small samples.

Now this slide is a flow chart for the

sampling plan. And it's fairly involved, and I

don't want to go through all the steps. I'd be glad

to discuss it with you afterwards if you have any

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

73

questions, but I want to go through a few of the key

steps. And I thought that this chart might be

useful in reviewing the proposal and in preparing

your comments for written comments. So it's

indicated that the sampling plan begins with a set

of initial tests. And here, M1 is the number of

units that are available for testing, which could be

up to 20. So that's one of the initial starting

conditions. And N1 is the number of initial tests.

That one of the accommodations that's made in the

sampling plan is that if fewer than five units are

available, then a single unit may be tested more

than once. And so that's why N1 and M1 have been

separated in this sampling plan.

Based on that initial sample, the

initial sample efficiency, sample standard

deviation, the standard error, the sample size

discount, and finally the lower confidence limit are

calculated. And then the next step on the chart is

to compare the sample mean with the lower -- I'm

sorry, the lower control limit. And then there are

sort of two outcomes. If the mean efficiency is

less than the lower control limit, the product is

non-compliant. If it is greater than or equal to

the lower control limit, then the next step is to

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

74

evaluate and ask the question if the sample size is

adequate for it to support the conclusion. And if

the calculation of the sample size demonstrates that

it is adequate, then the product is compliant and

testing is complete. If that evaluation of the

sample size indicates that enough units have not

been tested, then this sampling plan may require

that additional units be tested. And in either

case , if the product is found to be non-compliant,

these two blocks at the bottom, then the

manufacturer has the option of doing additional

tests, up to 20 is I believe what's specified.

So this completes the overview of the

major provisions. And then so I'd like to open the

floor for any comments or discussion.

FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: This is Ed Gray again. My

question isn't on the method so much, but what

starts the clock here. I mean, you know, the other

products I have experience with, there may be a

manufacturer that tests a competitor's product and

doesn't think they comply with the standards or

something, or maybe a state energy office doesn't

think something's compliant. So how do you get into

this loop to begin with?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

75

MR. STRICKLETT: I believe -- Cyrus may

want to address this.

FACILITATOR BROOKMAN: Cyrus Nasseri.

MR. NASSERI: Well Ed, this enforcement

has any meaning if we establish minimum efficiency

standards.

FACILITATOR BROOKMAN: Sorry, get the

mic closer to you, please.

MR. NASSERI: So obviously we do not

have the standard established for this product,

minimum efficiency standards for these products.

And this is assuming that we have -- this is way

ahead of our game a little bit here. The

enforcement comes into the picture when whatever the

case is, we had cases that competitors or

manufacturers claim that certain product is not

meeting the minimum efficiency established by the

department. And then we have to go through the

enforcement process. Am I answering your question,

or your question was something else?

FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: So I guess what you're saying

is that if we have comments on enforcement, we

should make that comment on the energy efficiency

process? Is that what you're saying?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
76

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. NASSERI: What I'm saying, your

comments should be in the process for enforcement

that we proposed for the first time. Assuming the

fact that we have a minimum efficiency standard

established for these products, which would be the

nature of tomorrow's meeting and the other rule that

we're doing in parallel line, whatever that minimum

is. At that time, when we establish that minimum

efficiency standards, then enforcement is basically

something that we would, and the department would

apply. But at this point we decided that we propose

this, and if you had any comments, assuming that we

had a minimum efficiency standard established.

One thing I would like to mention Doug,

because you mentioned about this NIST technical

document.

FACILITATOR BROOKMAN: Yes.

MR. NASSERI : We put that on the website

at the time that we put the proposed rule.

FACILITATOR BROOKMAN: Okay.

MR. NASSERI: So this is not the first

time they see it, by the way.

FACILITATOR BROOKMAN: Okay, good.

Thanks for mentioning that. Michael McCabe.

MR. MCCABE: Michael McCabe. A couple

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
77

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

of comments. One, in answer to a latter question

that you asked. Ed, please comment on the

procedures as part of this docket, the enforcement

procedures. The two rulemakings, the appliance

standards, ANOPR distribution transformers for the

public meeting is being held tomorrow, and the test

procedure rulemaking are very related. But the

regulations with respect to certification and

enforcement are part of this proceeding, not the

standards proceeding. Enforcement actions, as the

regulations that we've laid out in the SNOPR, deal

with both representation and standards. In answer

to your initial question when would we get into

that, it would be in response to information coming

to the department. That information, as you had

indicated, can come from a variety of sources.

It is also, as far as the process is

laid out, it's that the information, once it comes

to the department, it is reviewed by the department.

Dialogue occurs between the department and a variety

of parties. That variety would include, for

example, the party that is submitting the

information to understand that information. If we

believe that there are questions that warrant

follow-up, we would then initiate a dialogue with

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

78

the manufacturer. It is only after the questions --

we have questions that cannot be addressed resolved

that we would go into an enforcement testing. The

enforcement testing burden would be a burden on the

department.

This product, however, is very different

than, say, than the residential products where you

have basic models. Some may be just one unit that

is produced a year, or every five years. Others

might be thousands of units produced a year. And so

the enforcement provisions, the testing, we

recognize it needs to have some flexibility to meet

the needs of the product. And we're interested in

your comments on how these procedures can be applied

if there is an enforcement issue for transformers.

Have I answered?

MR. GRAY: That's very helpful, thank

you.

FACILITATOR BROOKMAN: Additional

questions or comments following this segment of the

presentation? So I think we're about ready to move

now to Alternative Efficiency Determination Method

if no one has anything additional at this point.

Okay then, Ken Stricklett again.

MR. STRICKLETT: This Alternative

MEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1:323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

79

Efficiency Determination Method, or an AEDM, is also

new for distribution transfers. And again, I'd like

to just briefly outline the major provisions in the

proposed rule, and just sort of frame the discussion

today. Full description of AEDMs can be found in

Section 432.12 of the proposed rule.

The key points regarding the AEDMs is

listed on the slide. So I'd like to just go through

this. It's a new topic. I'll go through this

material fairly quickly, and then that will allow

adequate time for comments and discussion. It looks

like we're way ahead of schedule, so we have plenty

of time to discuss this topic.

There are two ways that you can

determine the efficiency of a product. One is, as

Oskars gave in his presentation, is through testing

a sample of units. And the second option is that

you can calculate the energy efficiency through the

use of an AEDM. Now the use of an AEDM has been

proposed for distribution transformers to reduce the

testing burden. And an AEDM can be used to predict

the energy efficiency. Basic models that are rated

through that are rated through the application of an

AEDM need not be tested.

AEDMs have been successfully used to

NEAL R. GROSS

CCURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

80

reduce the testing burden for HVAC equipment and for

electric motors. And the department is suggesting

that this strategy may also be useful for

distribution transformers.

The proposed rule gives several

characteristics of an AEDM to clarify what it

intends to qualify as an AEDM. And I've sort of

paraphrased some of the language from the proposed

rule in these three bullets. An AEDM is a

computational method such as a software design tool.

It's derived from a mathematical model that

represents the electrical characteristics of the

basic model. And an AEDM is based on engineering

and statistical analysis, computer simulation or

modeling, or other analytical evaluation of

performance data.

There are limitations to the application

of an AEDM that are provided in the proposed rule.

First of all, the accuracy of an AEDM must be

substantiated. It must go through this phase of

substantiation before it can be used. A particular

AEDM can only be used to rate basic models in one of

the following groups of distribution transfers. And

those are liquid-immersed transfers, low voltage

dry-type transformers, and medium voltage dry-type

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE.ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
81

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

transformers. And then finally, an AEDM cannot be

used to rate basic models that have been tested.

The criteria for substantiation of an

AEDM include the following, that five or more basic

models must be tested using the DOE test procedure,

that five units of the transformer of the basic

model must be tested for each basic model, and that

the predicted or calculated loss should be within

+/-5 percent of measured value for each basic model

tested, and then finally that the average of the

predicted losses must be within +/-3 percent of the

average losses.

There's also guidance given for the

selection of basic models during the substantiation.

And those include that two of the basic models must

be among the five basic models with the highest unit

volumes of production in the prior year. No two

basic models should have the same combination of kVA

and voltage ratings. And at least one basic model

should be single-phase and one should be threephase.

There are some additional requirements

that are stipulated if an AEDM is to be used. And

those include that there be periodic verification,

and that there be a maintenance of records to sort

NEPAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

82

of a traceability path on the AEDM. The department,

as mentioned during the enforcement discussion, the

department may also request that specific

simulations be conducted, and that the analysis of

previous simulations be provided, and/or that sample

testing may be conducted on select basic models.

This completes the overview of the

provisions for the use of the AEDM proposed in the

test procedure. And at this time I'd like to open

the floor for comments and discussion. There are

some particular issues that the department is very

interested in receiving comments on. And those are

the limitations on the applications of an AEDM, the

criteria proposed for the substantiation of an AEDM,

the accuracy and reliability of using AEDMs in

general, and on the criteria for the selection of

basic models during the substantiation of an AEDM.

FACILITATOR BROOKMAN: So, questions and

comments, and particularly the department has, as

you said, those four bulleted items on 9 on your

sheet. Any comments on those? And others as well.

Yes, please, Gerald Hodge.

MR. HODGE: Yes, Gerald Hodge from

Howard Industries. Going back to Number 8, where it

talks about the periodic verification of an AEDM.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
83

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Are we talking about a specific period of time, or

is that up to the manufacturer, or that just seems

somewhat vague in my opinion.

MR. STRICKLETT: There is no specific

time given in the proposal. And if -- Francine did

you have a -- Prior to the meeting we had some

discussions. That was one of the issues that you

thought might be a -- So I think if you have

specific suggestions that you feel would be

appropriate, then the department would be very

interested in receiving those.

MR. HODGE: Okay, will do.

FACILITATOR BROOKMAN: Michael, did you

wish to comment? No? Okay. Additional comments,

especially as they relate to limitations on

applicability, criteria for substantiation, accuracy

and reliability, and selection of basic models.

Department welcomes your comments on those items.

Okay.

So I guess then that finishes that slide

segment. This is a slide that says how to submit

comments. And in your packet there was a single

page that had all this information in a very clear

and well laid out format. I would call your

attention to that as the way to submit your

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
84

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

comments, and the deadlines are there, and

everything else. So now we wanted to preserve an

opportunity for anybody that had any additional

questions or comments they wish to make, or make any

summary comments at this time, because we're nearing

the end of this workshop, it seems . Ed Gray?

MR. GRAY: This is just a minor detail,

I guess. We looked at the NEMA standards during the

break, and we have the same temperature , 55 degrees

C, as I guess IEEE has in their standard. There was

some comment that was different I remember earlier.

FACILITATOR BROOKMAN: So thank you.

Anybody else with any additional or summary comments

at this time? I don't see any. So then Cyrus

Nasseri.

MR. NASSERI: I just wanted to emphasize

the fact that the timing is important for us to go

to the final rule for this test procedure. Also in

the test procedure, as we said , the provisions of

TP-2 and IEEE are all there. Nothing new. And then

we state very clearly what our comments on the TP-2

are, the present TP-2, the 1998 version. And I

think at one time we discussed the fact that Ed said

that he would like to have some future discussion.

My feeling is that we already stated all of the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-441°3 WASHINGTON. D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

85

changes in the SNOPR, that differences or the things

that we feel, the department feels should be

basically corrected or according to ours, and then

we welcome any comments on what our determination

has been.

FACILITATOR BROOKMAN: Okay, thank you.

That clarification I think is useful. Ron Lewis.

MR. LEWIS: We have tried to change the

public meeting and the process here slightly to take

pressure off time. We off-loaded a bunch of the

presentation of the highly technical stuff, the

tools, the presentations of what's on the website,

what are we using as background as we're analyzing

all the data. And rather than have everybody sit

here through the whole day and present all the data

to you, we chose to try to give the emphasis to time

for you to have your questions and give your

comments and interact, rather than it being a

monologue. We did a webcast in advance to go over

the tools, and go through the higher technical

content, hoping that the pressure wouldn't be on the

day for us to get through the extensive

presentations. I'm not sure how to interpret here.

We're getting through so quickly, there's been a

minimum of dialogue.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS -

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

86

Our intent -- I hope that you see that.

By having the webcast out early, by publishing

things early, by having more time for dialogue,

we're trying to make proper provision. Because this

is the point in the process for you to really get us

on the right track. If there are things that you

have concerns about and we've missed something, it's

important. We're not here to be defensive or argue

perspectives. It's important that your perspective

and your viewpoint be heard. And we wanted to give

an emphasis to that, and that's why we've changed

the format here, to off-load some of the technical

information. So I personally would be interested in

your comments on that part of the process as well.

We want to have the user-friendly, and trying not to

have a just taking turns talking, but have a true

dialogue, and have you engaged in the process so

that we fully understand your concerns and you fully

understand what we've done. So I hope this is going

in the right direction, and again I'd be quite

interested in your input on that.

As Ed and I had spoken of earlier, Cyrus

mentions that there is quite a bit of information in

the Federal Register notice of things where we saw

areas that we were not comfortable with. But if

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
87

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

there are -- rather than just offer, here is an

exhaustive sheet of all the areas that are

different, I'm really concerned about making sure we

understand your perspective and what's behind the

concerns as well. So I don't want it to be just a

static process of here it is, take it or leave it.

We want to make sure that thoroughly we've explained

what we have, and that we're available to help you

understand.

Again, during the comment period we're

limited. We don't want to in any way be trying to

persuade you of our perspective, or trying to lead

you in any way. We're just trying to gather the

information, make sure you understand what the

analysis is that we've done, and then we want to

understand just as clearly what your concerns and

input is on the topic. So we're trying to be userfriendly, and hopefully this process is going to get

us to something at the end that's very much

developed together, where DOE has its charge and its

mission, and you have your interests, and that we've

assessed everything when we're going forward. So

again, your input on the general process would be

helpful as well.

FACILITATOR BROOKMAN: Thank you. So I

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-TP-98-550 COMMENT 45.11
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

88

believe we've covered all the items that are listed

on the agenda. And we've heard from the department

their invitation to both seek them out and provide

additional comments. So then perhaps I guess we're

at the point where I personally am going to sign off

and say thank you, and see if the department has any

closing remarks as well.

MR. NASSERI: Well, closing remarks. We

really appreciate taking your time and coming. And

we look forward for your comments. I was expecting

to see more comments about the proposed, and we are

hoping that by the end of the comment period, which

is November 8, that you provide us with as much

comments that would help us to come up with a final

rule, which would be something that you're

comfortable with, the manufacturers are comfortable

with, and we achieve the fact that it is a good

method for rating the product. Thank you very much.

FACILITATOR BROOKMAN: Thank you.

(Whereupon, the foregoing matter went

off the record at 11:34 a.m.)

(9(191 7 t-44'i'i

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

'*23 RHODE ISLAND AVE., N.W.

WASHW(.T(lN n c, 9Ml5_17M AAiW naalrnrr rnm

EE-TP-98-550 COMMENT 45.11
89

CERTIFICATE

This is to certify that the foregoing transcript in the

matter of: Public Meeting

Before: U.S. Department of Energy

Date: September 27, 2004

Place: Washington, DC

represents the full and complete proceedings of the

aforementioned matter, as reported and reduced to

typewriting.

EE-TP-98-550 COMMENT 45.11