U.S. DEPARTMENT OF ENERGY

PUBLIC HEARING ON ENERGY EFFICIENCY TEST PROCEDURES

DISTRIBUTION TRANSFORMERS

AGENDA

LOCATION:

DATE AND TIME:

FORRESTAL BUILDING

ROOM I E-245

1000 INDEPENDENCE AVENUE, SW

WASHINGTON, DC 20585

WEDNESDAY, JANUARY 6, 1999

9:00 A.M. - 4:00 P.M.

Purpose of Hearing : The objective of the hearing is to discuss the test procedures proposed for

electric distribution transformers and to receive information on the adequacy

of the test methods proposed, and information on alternatives to the

proposed test procedures.

Outcome of Hearing: To receive comments and information on the proposed approach in order to

develop a final test procedure for covered products.

9:00 - 9:10 VMLCOMING REMARKS AND INTRODUCTIONS

9:10 - 9:20 AGENDA REVIEW

Attendees will be invited to review the agenda, the topics proposed, and propose additions

and/or deletions to the proposed list of topics to be discussed.

9:20 - 9:30 OPENING STAT NTS

Opening statements should be brief, of a general nature, and not discuss the specific

agenda topics.

TOPICS

For each topic, the Department will invite speakers to make a brief summarypresentation

concerning the specific topic. DOE may ask questions after each prepared statement and

at other points during discussions. At the end of a prepared statement or all prepared

statements on each topic, the Department will encourage an open dialogue by those in

attendance on the issues raised and alternatives proposed for each topic. Each topic will

be dealt with separately.

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9:30 - 10:30 Proposed Test Procedures and Adequacy of TP 2 to Meet the Requirement of Users

The Department proposed two test procedures for consideration, either to incorporate by

reference: 1) three widely used commercial standards (ANSI/IEEE C57.12. 00, ANSI/IEEE

C57.12.90, and ANSI/IEEE CS7 12.91); or 2) a standard being developed by the National

Electric Manufacturers Association (NEMA TP 2). The Departments intends to adopt one

of these test procedures in the final rule. The Department is concerned over whether TP 2

has undergone broad-based scrutiny and that it is acceptable to all users and stakeholders.

In particular, we want to ensure TP 2 meets the needs of utilities and contractors who

specify transformers for commercial and industrial applications (e.g., retail, industrial,

and office buildings). In order for DOE to accept TP 2, we would need to have sufficient

evidence that users and stakeholders have had an opportunity to review TP 2 and that their

concerns have been addressed.

The Department is particularly interested in receiving comments on the following:

General

• Do the proposed test procedures adequately measure distribution transformer

efficiency?

• Which ofthe two approaches the Department should adopt, and why?

• Have users and stakeholders (including non-NEMA members) had an opportunity

to review TP 2? Have their comments been addressed in the final version of TP 2?

• Is TP 2 adequate to meet the needs of utilities and contractors who specify

transformers for commercial and industrial applications?

• Have manufacturers and users tested transformers with TP 2? Does it work?

ERMCO Statement

Dynapower Statement

Specific

• Should additional standards be incorporated by reference?

• Are the stated reference conditions acceptable and provide for repeatable and

reproducible results?

NEMA statement

10:30 - 10:40 Break

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10:40 - 12:00 Distribution Transformers Not Subject to the Test Procedures

In the 1997 Determination Notice regarding distribution transformers, the Department set

forth a definition for the term "distribution transformer. " This definition was intended to

include transformers designed to transfer electrical energy from a primary distribution

circuit to a secondary distribution circuit, or within a secondary distribution circuit, or to

a consumer 's service circuit. The definition was not intended to include transformers

which are not designed to be connected to a power distribution system as a distribution

transformer. In the proposed rule, the Department refined the definition of "distribution

transformer" to clarify which transformers are, covered and which are excluded.

However, if a particular transformer does not fall within our definition of distribution

transformer, it is automatically excluded, and there is no need to specifically identify it as

excluded.

The Department 's intentfor the test procedures rulemaking is to include all distribution

transformers which can be accurately tested with the test procedures . We made an effort

to identify and exclude transformers that cannot accurately be tested by theproposed test

procedures, such as transformers with frequencies other than 60 Hz (+/- S Hz) and

converter and rectifier transformers with more than two windings. However, the

Department does not intend to exclude distribution transformers from the test procedures

just because they may have lower efficiencies than their counterparts. Efficiency issues

will be dealt with during the efficiency standards rulemaking.

The Department is particularly interested in receiving comments on the following:

In the NOPR, has the Department accurately defined the term "distribution

transformer"?

• Has the Department correctly identified distribution transformers that cannot

accurately be tested by the test procedures in the proposed rule?

• Are there additional distribution transformers that cannot be accurately tested with

the test procedures in the proposed rule? If so, please explain why these

transformers cannot accurately be tested, and provide or identify evidence that

supports this explanation.

Rectifier Converter Transformers and transformers designed for high harmonics.

Mr. Kline's Statement

NEMA Statement

Transformers with frequencies other than 60 Hertz.

NEMA Statement

Other requested exclusions

NEMA Statement

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Loopholes

• Is there a likelihood that loopholes may result from the proposed distribution

transformer definition and its exclusions?

12:00-1:00 Lunch (on your own)

ro pi g of Transformers for Testing rpo , as Manifested by the Definition of a 1:00 - 1:30

Basic Model

In order to lessen the burden of test procedures, the Department typically categorizes

products into "basic models" consisting of items of equipment whose performance, design,

electrical, mechanical, and functional characteristics are essentially the same.

Components of similar design may be substituted in a basic model without requiring

additional testing if the represented measures of energy consumption continue to satisfy

applicable provisions for sampling and testing. Only representative samples within each

"basic model" are tested.

The Department tried to apply this approach to distribution transformers. At the workshop

on February 10, 1998, NEMA. provided comments on how "basic model " should be

defined for distribution transformers. Based on NEMA's comments, in the proposed rule

the Department defined "basic model" to mean all units of a given type of distribution

transformer manufactured by a single manufacturer and which have a comparable

nominal output power (kVA) rating, operate within the same voltage range, have the

same insulation type (liquid-immersed or dry type), and have the same number of phases

(single or three).

The Department is particularly interested in receiving comments on the following:

• Is the definition of "basic model" used in the proposed rule adequate? Is the

definition too broad?"

Given the broad definition of basic model, is there a concern that some

manufacturers who sell some high efficiency models may under-design other

transformers within that basic model (while still meeting a possible standard for the

average efficiency of that basic model)? If so, what should be done to prevent this

practice?

ERMCO Statement

1:30 - 3:00 Sampling Plan for Compliance

In order to reduce the testing burden on manufacturers, the Department typically permits

the use of a statistically meaningful sampling procedure for a manufacturer to select test

specimens to determine the efficiency of a basic model. At the February 10, 1998

workshop, the Department presented both the sampling plan for compliance and the

sampling plan for enforcement typically used under 10 CFR Part 430.

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In comments to the workshop, NEMA recommended the enforcement sampling test also be

used for demonstration of compliance . However, after reviewing these approaches more

closely, the Department believes the sampling plan for compliance in Part 430 is more

suitable because it provides a high statistical probability that the mean performance of the

basic model meets or exceeds the performance level claimed by the manufacturer based on

testing a small number of models. Consequently this approach was used in the proposed

rule.

The Department is concerned about manufacturers, particularly small companies, who

have limited output of certain basic models; under the proposed sampling plan, a

manufacturer would need to test a relatively high proportion of the units it manufactures of

such a basic model. In the preamble to the proposed rule, the Department provided three

approaches for sampling limited production models (63 FR 63367).

The Department is particularly interested in receiving comments on the following:

Is the sampling plan provided in the proposed rule reasonable for distribution

transformers? If not, please explain why the Department's sampling plan is

unacceptable.

• How should limited production basic models be handled? Please provide

comments on the three approaches for sampling limited production models found

on page 63367 of the notice.

If you have an alternative sampling approach, please provide evidence of how your

approach will provide a high probability that the mean performance of each basic

model will meet or exceed the performance level claimed by the manufacturer.

3:00 - 3 : 10

NEMA Statement

Break

3:10 - 3:40 Other Issues

3:40 - 4:00

Does anyone have any other issues to raise that have not been addressed?

Closing Business

4:00 Adjourn

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