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 allprepared statements on each topic, the Department will encourage an open dialogue by those in attendance on the issues raised and alternativesproposed for each topic. Each topic will be dealt with separately.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 Break10:40

- 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 intent for 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

### 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 Samp ling 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.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