Thursday

November 12, 1998

7 'M

Part II

Department of

Energy

Office of Energy Efficiency and

Renewable Energy

10 CFR Part 432

Energy Conservation Program: Test

Procedures for Distribution Transformers;

Proposed Rule

 EE-TP-98-550 COMMENT 12A
63360 Federal Register /Vol. 63, No. 218 /Thursday, November 12, 1998 /Proposed Rules

DEPARTMENT OF ENERGY

Office of Energy Efficiency and

Renewable Energy

10 CFR Part 432

[Docket No. EE-TP-98-550]

RIN 1904-AA85

Energy Conservation Program: Test

Procedures for Distribution

Transformers

AGENCY : Office of Energy Efficiency and

Renewable Energy, Department of

Energy.

ACTION : Notice of Proposed Rulemaking

and public hearing.

SUMMARY: Pursuant to Section 346(a) of

the Energy Policy and Conservation Act

as amended (EPCA), 42 U.S.C. 6317(a),

the Department of Energy (DOE or the

Department) proposes to adopt test

procedures for measuring the energy

efficiency of distribution transformers.

The Department proposes to use these

test procedures in the process of

evaluating whether and what efficiency

standards are appropriate for

distribution transformers. If standards

are promulgated, then use of these test

procedures would be required to

determine compliance and as a basis for

representations. The proposed rule

would incorporate by reference clauses

from test procedures contained in

commercial standards. The Department

is proposing to use one of two

alternative sets of standards as the

primary references: alternative (A) is

primarily based on American National

Standards Institute (ANSI) /Institute of

Electrical and Electronics Engineers

(IEEE) standards C57.12.90-1993 and

C57.12.91-1995, and alternative (B) is

based on National Electrical

Manufacturers Association (NEMA)

standard TP 2-1998, pending its

approval by ANSI.

DATES: The Department will accept

comments, data, and information

regarding the proposed rule no later

than February 5, 1999. Ten (10) copies

must be submitted. In addition, the

Department requests that an electronic

copy (31/2" diskette) of the comments on

WordPerfectTM 6.1 be provided.

A public hearing will be held on

January 6, 1999, in Washington, DC.

Requests to speak at the hearing must be

received by the Department no later

than 4:00 p.m., December 23, 1998. Ten

(10) copies of statements to be given at

the public hearing must be received by

the Department no later than 4:00 p.m.,

December 23, 1998, and the Department

requests that a computer diskette

(WordPerfectTM 6.1) of each statement

also be provided at that time.

ADDRESSES : Requests to make

statements at the public hearing and

copies of such statements should be

addressed to Ms. Brenda Edwards-Jones,

and written comments should be

addressed to Ms. Kathi Epping, each at

the following address: U.S. Department

of Energy, Office of Energy Efficiency

and Renewable Energy, EE-43, 1000

Independence Avenue, SW,

Washington, DC 20585-012 1. All such

documents should be identified both on

the envelope and on the documents as

"Energy Conservation Program for

Commercial Products: Test Procedures

for Distribution Transformers, Docket

No. EE-TP-98-550." The hearing will

begin at 9:00 a.m., on January 6, 1999,

and will be held in Room 1E-245 at the

U.S. Department of Energy, Forrestal

Building, 1000 Independence Avenue,

SW, Washington, DC. For more

information concerning public

participation in this rulemaking

proceeding, see section IV, "Public

Comment," of this notice.

Copies of the transcript of the public

workshop and public comments

received may be read in the Freedom of

Information Reading Room (Room No.

lE-190) at the U.S. Department of

Energy, Forrestal Building, 1000

Independence Avenue, SW,

Washington, DC between the hours of

9:00 a.m. and 4:00 p.m., Monday

through Friday, except Federal holidays.

Copies of the standards to be

incorporated by reference may be

viewed at the Department of Energy's

Freedom of Information Reading Room

at the address stated above. Copies of

the referenced standards may be

obtained by request from Global

Engineering Documents World

Headquarters (for NEMA Standards TP

1-1996 and TP 2-1998), 15 Iverness

Way East, Inglewood, CO 80112-5776 or

the American National Standards

Institute (for ISO Standard 9001-1993

and ANSI standards C57.12.90-1993,

C57.12.91-1995, C57.12.00-1993, and

C57.12.01-1989), 11 West 42nd Street,

New York, N.Y. 10036.

FOR FURTHER INFORMATION CONTACT:

Kathi Epping, U.S. Department of

Energy, Office of Energy Efficiency and

Renewable Energy, EE-43, 1000

Independence Avenue, S.W.,

Washington, D.C. 20585-0121, (202)

586-7425, e-mail:

Kathi.Epping@ee.doe.gov, or Edward

Levy, Esq., U.S. Department of Energy,

Office of General Counsel, GC-72, 1000

Independence Avenue, S.W.,

Washington, D.C. 20585, (202) 586-

9507, e-mail: Edward.Levy@hq.doe.gov.

SUPPLEMENTARY INFORMATION:

1. Introduction

A. Authority

B. Background

C. Summary of the Proposed Test

Procedures

II. Discussion

A. Standards to be Incorporated by

Reference

B. Distribution transformers not subject to

the test procedures

C. Reference Conditions

D. Measures of Energy Consumption

E. Basic Model

F. Number of Units to be Tested

G. New Part 432

III. Procedural Requirements

A. Review Under the National

Environmental Policy Act of 1969

B. Review Under Executive Order 12866,

"Regulatory Planning and Review"

C. Review Under the Regulatory Flexibility

Act

D. Review Under Executive Order 12612,

"Federalism"

E. Review Under Executive Order 12630,

"Governmental Actions and Interference

with Constitutionally Protected Property

Rights"

F. Review Under the Paperwork Reduction

Act

G. Review Under Executive Order 12988,

"Civil Justice Reform"

H. Review Under Section 32 of the Federal

Energy Administration Act of 1974

1. Review Under Unfunded Mandates

Reform Act of 1995

IV. Public Comment

A. Written Comment Procedures

B. Public Hearing

1. Procedures for submitting requests to

speak

2. Conduct of hearing

C. Issues Requested for Comment

1. Introduction

A. Authority

The National Energy Conservation

Policy Act of 1978, Pub. L. 95-619,

amended the Energy Policy and

Conservation Act (EPCA) to add a Part

C of Title III, which established an

energy conservation program for certain

industrial equipment. The most recent

amendments to EPCA, in the Energy

Policy Act of 1992 (EPAct), Public Law

102-486, included amendments that

expanded Title III of EPCA to include

certain commercial water heaters and

heating and air-conditioning equipment,

incandescent and fluorescent lamps,

electric motors, and electric distribution

transformers.

Among these amendments is Section

124(a) of EPACT, which amended

Section 346 of EPCA, 42 U.S.C. 6317, to

provide that the Secretary of Energy

must prescribe testing requirements and

energy conservation standards for those

distribution transformers for which the

Secretary determines that standards

11 would be technologically feasible and

 EE-TP-98-550 COMMENT 12A
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economically justified, and would result

in significant energy savings." 42 U.S.C.

6317(a). On October 22, 1997, the

Department issued a notice setting forth

its determination ("Determination

notice") that, based on the best

information currently available, energy

conservation standards for electric

distribution transformers are

technologically feasible and

economically justified and would result

in significant energy savings. 62 FR

54809. Consequently, the Department is

now proceeding to establish, by notice

and comment rulemaking, test

procedures for distribution

transformers.

In the Determination notice, the

Department construed the term

"distribution transformer" in section

346 of EPCA to mean "all transformers

with a primary voltage of 480 V to 35

kV, a secondary voltage of 120 V to 480

V, and a capacity of either 10 to 2500

kVA for liquid-immersed transformers

or 0.25 kVA to 2500 kVA for dry-type

transformers," except for transformers

which are not continuously connected

to a power distribution system as a

distribution transformer. The

Department believes this exception

would include regulating transformers,

machine tool transformers, welding

transformers, grounding transformers,

testing transformers, and other

transformers which are not 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

Department indicated that all products

included in this definition of

"distribution transformer" would be

addressed in its rulemakings on energy

efficiency test procedures and standards

for transformers.

Subsequently, the Department has

learned that industry typically classifies

transformers with a secondary voltage

up to 600 V as distribution transformers.

These transformers are included, for

example, in the scope of NEMA

standard TP 1. In light of industry usage

and practice, the Department has

decided that the term "distribution

transformer", in the statute, includes

transformers with a secondary voltage

480 V to 600 V, in addition to those

transformers in the above-mentioned

definition. These additional

transformers are covered by today's

proposed test procedures, and will be

included in the Department's

consideration of efficiency standards for

transformers.

B. Background

The Secretary's Determination notice

was based, in part, on analyses

conducted by the Oak Ridge National

Laboratory (ORNL). In July 1996, ORNL

published a report, entitled

"Determination Analysis of Energy

Conservation Standards for Distribution

Transformers, ORNL-6847" which

assessed several options for setting

efficiency standards. The report was

based on information from annual sales

data, average load data, and surveys of

existing and potential transformer

efficiencies that were obtained from

several organizations. In September

1997, ORNL published a second report,

entitled "Supplement to the

"Determination Analysis" (ORNL-6847)

and Analysis of the NEMA Efficiency

Standard for Distribution Transformers,

ORNL-6925". The purpose of this

report was to assess NEMA TP 1 along

with the options considered in the

determination study, using the more

accurate analysis model and transformer

market and loading data developed

subsequent to the publication of the

original ORNL report.

On February 10, 1998, the Department

held a public workshop with

representatives from the National

Electrical Manufacturers Association

(NEMA), manufacturers, utilities,

Federal and state agencies, foreign

government, and other interested parties

in Washington, DC. Draft Test

Procedures were presented as a basis for

discussion. In addition, the following

issues were discussed: (a) adoption of

national and international consensus

standards in the test procedures for

determining energy efficiency of

distribution transformers, (b) burden

imposed on industry, especially on

manufacturers, by additional testing and

data processing, (c) the definition of

"basic model" for distribution

transformers, (d) sampling plan for units

to be tested, (e) selection of a measure

of energy consumption for distribution

transformers, (I) selection of reference

temperatures, (g) requirement for

applying corrections to measurement

data of both liquid-immersed and drytypes of transformers, (h) requirements

for quality assurance in testing, and (i)

defining the transformers which are to

be covered by the test procedures. A

transcript of the public workshop is

available at the Freedom of Information

Reading Room.

NEMA submitted a written statement

at the workshop, and 5 comments were

received subsequent to the public

workshop. A letter from Don Ballard

(industry consultant) and a letter from

the US Department of Agriculture

63361

concerning issues relating to today's

notice were submitted to DOE prior to

the public workshop. The Department

will consider these two letters as part of

the public comment received. The

comments made at the workshop as well

as the written comments were

considered in preparing the test

procedure presented in today's

proposed rule, and recommendations

were incorporated where appropriate.

The reasons for not incorporating any

significant recommendations are

explained in section II of today's

proposed rule.

C. Summary of the Proposed Test

Procedures

The Department will use the test

procedures in today's proposed rule in

the process of evaluating whether and

what efficiency standard levels are

appropriate for distribution

transformers. If efficiency standards are

promulgated, then manufacturers would

be required to use these test procedures

to determine compliance with the

standards and as a basis for

representations they make as to the

efficiency levels of the transformers they

produce.

The Department is proposing that a

uniform set of test procedures be

applied to all distribution transformers

for which standards will be considered,

and to all for which standards are

ultimately adopted. This does not

necessarily mean, however, that a single

standard or set of labeling requirements

will be adopted for all transformers. In

possible future rulemakings addressing

standards and labeling, distribution

transformers will be divided into

classes, if appropriate. A separate class

and an appropriate standard will be

created for each group of products

where the record indicates the product

includes a utility or performance-related

feature that affects energy efficiency.

Moreover, in evaluating an efficiency

standard in a future rulemaking, the

Department will consider whether the

standard would result in any lessening

of the utility or performance of the

transformer(s) that would be covered by

the standard. Finally, even if standards

are promulgated for distribution

transformers, some classes of

transformers may be excluded from

standards.

The Department proposes today to

incorporate by reference clauses from

industry standards for measuring the

energy efficiency of distribution

transformers. The proposed rule

contains two alternative sets of

standards for testing transformers for

energy consumption and efficiency, and

the Department intends to select one of

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these alternatives for inclusion in the

final rule. Alternative (A) is primarily

based on American National Standards

Institute (ANSI) /Institute of Electrical

and Electronics Engineers (IEEE)

standards C57.12.90-1993 and

C57.12.91-1995, and alternative (B) is

based on National Electrical

Manufacturers Association (NEMA)

standard TP 2-1998. The two reference

test standards under alternative (A) are

well established within the industry and

have been used for over two decades.

Limited additional reference is made

under alternative (A) to ANSI/IEEE

C57.12.00-1993 regarding reference

temperatures, loss tolerances, and

measurement tolerances. With respect to

actual tests and measurements for

power losses leading to energy

consumption and efficiency, the

material in the C57 series standards and

TP 2 is nearly identical. The NEMA

standard TP 2-1998, referenced in

alternative (B), combines all information

applicable to tests, measurements for

energy consumption, and calculation of

efficiency in a single document

applicable to both liquid-immersed and

dry-type transformers.

The test procedure involves the

measurement of electric power

consumed by the transformer in the

form of no-load and load losses, as well

as the determination of certain other

quantities needed to establish the test

conditions: temperature of the windings

and the core; current; voltage; frequency

and waveform of voltage; and direct

current resistance of the windings.

Today's proposed rule also proposes a

sampling plan for testing a basic model

to establish its compliance with

standards and to provide a basis for

efficiency representations.

In addition to discussing the

standards to be incorporated by

reference, the following issues are

discussed below: distribution

transformers not subject to the test

procedures, the reference conditions in

the test procedure, measures of energy

consumption, the definition of a "basic

model" to permit grouping of models for

testing purposes, and the sampling plan.

II. Discussion

A. Standards to be Incorporated by

Reference

The Department is proposing to

incorporate by reference specific

portions of either three widely used

commercial standards, or of a standard

being developed by the National

Electrical Manufacturers Association

(NEMA), as a test procedure in

Appendix A of 10 CFR part 432. The

three national standards were prepared

by the IEEE and approved by ANSI: (1)

ANSI/IEEE C57.12.90-1993, "IEEE

Standard Test Code for LiquidImmersed Distribution, Power and

Regulating Transformers and IEEE

Guide for Short Circuit Testing of

Distribution and Power Transformers,"

(2) ANSI/IEEE C57.12.91-1995, "IEEE

Standard Test Code for Dry-Type

Distribution and Power Transformers,"

and (3) ANSI/IEEE C57.12.00-1993,

"IEEE Standard General requirements

for Liquid-Immersed Distribution,

Power and Regulating Transformers."

ANSI/IEEE C57.12.90-1993 and ANSI/

IEEE C57.12.91-1995 are considered

primary references as they address tests

and measurements leading to the energy

consumption and efficiency values.

ANSI/IEEE C57.12.00-1993

complements the previous two ANSI/

IEEE standards by specifying the

reference temperatures and

measurement tolerances, which are

essential in fully defining the

measurement data. The three

aforementioned standards contain more

material than the information that is

applicable to loss or efficiency testing.

Hence, only the applicable sections and

clauses are incorporated by reference in

today's proposed rulemaking.

The Department is considering

referencing a single clause, 4.11.1, of

International Standards Organization

(ISO) Standard 9001-1993, "Quality

Systems-Model for quality assurance

in design, development, production,

installation, and servicing," for

guidance purposes only, concerning

compliance with requirements for

quality assurance of the test and

measuring equipment.

The remaining reference standard

being considered by the Department was

prepared by NEMA: TP 2-1998, "Test

Method for Measuring the Energy

Consumption of Distribution

Transformers." It is also considered a

primary reference standard. This NEMA

publication is planned for submission to

the ANSI C57 committee for review and

possible approval as a national

standard, thus including in the approval

process a broader constituency, such as

the electric utility industry, which is the

principal user group of distribution

transformers.

In addition, IEEE PC57.123, "Draft

Guide for Transformer Loss

Measurement" is nearing completion

and provides additional guidance on

how to conduct transformer loss

measurements. The Department is also

aware that a revised version of ANSI/

IEEE C57.12.01 is currently being

balloted. If adopted, this revision would

make C57.12.01 more consistent with

C57.12.00 in specifying measurement

tolerances. DOE will examine these

documents for possible incorporation by

reference in the final DOE test

procedures, if they have been approved

by IEEE, their sponsoring organization

(and preferably by ANSI as well), prior

to adoption of the final rule. After the

final rule is published, however, any

subsequent amendments to any of the

referenced standards by the standardsetting organizations (ANSI, IEEE,

NEMA, ISO) would become part of the

DOE test procedure only if DOE amends

the test procedure to incorporate them.

In comments on workshop issues,

NEMA recommends TP 2-1998 as the

sole primary reference to be

incorporated in the DOE test procedure,

because it combines in one document

the subject matter that is now available

in several documents. DOE recognizes

the advantages of having all relevant

testing requirements in a single primary

reference because it enhances the

convenience for users and will facilitate

future harmonization. However, DOE

also desires to incorporate consensus

standards that have the broadest

acceptance by the stakeholders, such as

the cited ANSI standards.

The Department is concerned over

whether TP 2 has undergone broadbased scrutiny. In order for DOE to

accept TP 2, the Department would

need to have sufficient evidence that all

users and stakeholders have had an

opportunity to review TP 2. The

Department would like comments from

stakeholders, such as utilities and

contractors who specify transformers for

commercial and industrial applications

(e.g., retail, industrial, and office

buildings), on the adequacy of TP 2 to

measure transformer efficiency. The

Department also is concerned that

portions of the current version of TP 2

have been abbreviated from the ANSI/

IEEE standards, and certain portions are

ambiguous and should be made more

explicit. There are also instances in

which the terminology should be

changed. In addition, certain portions

do not read as if the current version of

TP 2 is a final document. If these

concerns with TP 2 are addressed

during the ANSI approval process as the

Department believes is likely, and if TP

2 receives approval from ANSI, the

Department would be inclined to adopt

alternative B.

B. Distribution Transformers Not

Subject to the Test Procedures

The commercial standards on which

today's proposed test procedures are

based are intended to test 60 Hz

transformers, although the standards

allow for minor variations in frequency.

Many manufacturers would need to

 EE-TP-98-550 COMMENT 12A
Federal Register /Vol, 63, No. 218 /Thursday, November 12, 1998/Proposed Rules

modify test equipment in order to

accurately conduct tests for transformers

that operate at frequencies that deviate

substantially from 60 Hz. Because such

distribution transformers comprise a

small segment of the market, they have

little potential for resulting in

significant energy savings. In addition,

transformers with frequencies other

than 60 Hz were not included in the

ORNL Determination analyses.

Consequently, the Department is

proposing that the test procedures in

today's proposed rule cover only 55 to

65 Hz transformers, and the Department

intends to evaluate only 60 Hz

transformers in a possible future

standards rulemaking. The Department

does not believe this will cause

"loopholes" because it would not be

beneficial to the manufacturers to

substitute transformers at substantially

different frequencies for 60 Hz

applications.

In addition, the Department

recognizes that the efficiency of

distribution transformers connected to

rectifier and converter circuits cannot be

readily tested or accurately measured by

the conventional loss measurement test

procedures outlined in today's proposed

rule. The nameplates of these

transformers contain a rating for the

fundamental-frequency apparent output

power and a rating for the apparent

output power with non sinusoidal

current produced by the converter. The

latter is inherently smaller than the

former, because harmonic currents

produce losses in addition to those of

the fundamental-frequency current. As a

result of additional physical and

electrical requirements in the design of

converter and rectifier transformers,

their performance is optimized for the

output power rating with non sinusoidal

current, yielding less than the optimal

performance at fundamental

frequencies, as would be required in a

general purpose distribution

transformer. Conversely, optimally

designed distribution transformers of

other types will not meet the optimal

requirements of a converter and rectifier

transformer. These transformers also

were not included in the ORNL

Determination analyses. In addition,

rectifier and converter transformers

generally have more than two windings

per phase, requiring more magnetic

material and resulting in higher no-load

losses. For these reasons, the test

procedures in today's proposed rule will

not apply to converter and rectifier

transformers with more than 2 windings

per phase, and the Department is not

inclined to evaluated these transformers

in a possible future standards

rulemaking.

For the purposes of these test

procedures, the Department proposes to

define the term "distribution

transformer" to mean all transformers

with a primary voltage of 480 V to 35

kV, a secondary voltage of 120 V to 600

V, a frequency of 55-65 Hz, and a

capacity of either 10 kVA to 2500 kVA

for liquid-immersed transformers or

0.25 kVA to 2500 kVA for dry-type

transformers, except for transformers

which are not designed to be connected

to a power distribution system as a

distribution transformer. These

exceptions would include regulating

transformers, machine tool transformers,

welding transformers, grounding

transformers, testing transformers, and

other transformers which are not

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. Converter

and rectifier transformers with more

than two windings per phase also would

not be included.

C. Reference Conditions

There is considerable diversity in the

reference conditions specified in the

existing commercial standards. Under

the current industrial practice, the load

losses of liquid-immersed transformers

are reported at the rated load and the

reference temperature of 85° C, as

specified by ANSI/IEEE C57.12.00. This

reference temperature is based on an

ambient temperature of 20° C and the

temperature rise of 65° C. The load

losses of dry-type transformers are

reported at the rated load and,

depending on the insulation system

used, at one of five specified

temperature rises in addition to an

ambient temperature of 20° C, as

specified by ANSI C57.12.01. The

resulting reference temperatures are: 80,

100, 135, 150, and 170°C. ANSI

standards C57.12.90 and C57.12.91

provide an identical algorithm for

converting the measured load loss

values to specified reference

temperatures.

For no-load losses of liquid-immersed

transformers, ANSI C57.12.00 specifies

the reference temperature of 20° C, thus

approximating ambient conditions.

Additionally, ANSI C57.12.90 provides

an algorithm for converting a no-load

loss value measured at another

temperature to that at the reference

temperature. No reference temperature

is specified for the no-load losses of the

dry-type transformers.

Finally, NEMA TP 1-1996

recommends minimum efficiencies and

63363

the following reference conditions for

distribution transformers:

Liquid-immersed

(50% of rated load)

Medium-voltage drytype (50% of the

rated load) .............

Low-voltage dry-type

(35% of the rated

load) .......................

No-load

losses

20° C

20° C

20° C

Load

losses

85° C

75° C

75° C

In order to address the inconsistencies

in the reference conditions among the

industry standards, the proposed rule

specifies the following: (1) Use a

consistent reference temperature of 20°

C for reporting the no-load losses of

both liquid-immersed and dry-type

transformers, and correct the measured

no-load loss data of dry-type

transformers to 20° C as required in

ANSI standards for liquid-immersed

transformers, if such a correction is

significant relative to required

measurement accuracy; (2) correct the

measured load loss data of dry-type

transformers for phase angle errors in

the measuring equipment as required in

ANSI standards for liquid-immersed

transformers, if such errors are

significant relative to required

measurement accuracy; (3) use an

efficiency selected at lower than the

rated loading and using a reference

temperature for load losses that

approximates the temperature rise at

new loading conditions, as opposed to

using temperature rises, as in ANSI/

IEEE standards, for rated nameplate

loading; and (4) measure losses of drytype transformers to the same accuracy

as specified for liquid-immersed

transformers.

These reference conditions enhance

uniformity in requirements and

facilitate comparison of products using

both liquid-immersed and dry-type

insulations. Therefore the proposed rule

requires that test results be reported at

the following loads and reference

temperatures: I

Establishing specific loading levels is properly

part of the energy conservation standard, but

correction of measurement data to new reference

conditions (including loading levels) must be

included in the test procedure . Today's proposed

test procedures use the loading levels in NEMA TP

1, because they appear to be widely used in the

industry and are reasonable for testing that is

conducted to consider and develop standards. Any

standards that are prescribed for transformers will

include specific loading levels, which the

Department will incorporate into the applicable test

procedures.

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No-load

losses

Load

losses

Liquid-immersed

(50% of rated load) 20 °C 55 °C

Medium-voltage2 drytype (50% of the

rated load) 20 °C 75 °C

Low-voltage3 dry-type

(35% of the rated

load) ....................... 20 °C 75 °C

Under the proposed rule, the measured

no-load and load losses used in the

efficiency computation would be

adjusted to the stated reference

conditions, the total uncertainty

(including measurement inaccuracy and

uncertainty resulting from lack of

reference condition adjustments)

exceeds 3 percent.

These reference temperatures were

selected with the objectives of obtaining

uniformity in reference conditions,

having reference conditions that best

reflect the actual operating conditions,

and maintaining consistency with the

practices of the current commercial

standards as much as possible. Fully

satisfying all three criteria, however,

was not practical or even possible, due

to the previously mentioned diversity in

the existing practice and the inherent

TABLE

differences between liquid-immersed

and dry-type transformers. The

proposed reference temperature to

which no-load losses would be adjusted

for both types of transformers is 20 °C,

which is consistent with C57.12.00 and

TP 1, but not with C57.12.01 which

does not specify the reference

temperature for no-load losses of drytype transformers. The 20 °C reference

temperature is close to the ambient

temperature; therefore losses can be

easily measured when the transformer is

cold, but this reference temperature

does not represent operating conditions.

However, because the changes in the

core losses due to temperature are small

(quoted in C57.12.90 as 6.5 x 10-4 per

unit per °C), these differences will have

only a small effect on the resulting

calculated efficiency.

If a transformer is being tested for

efficiency at less than full-rated or

nameplate loading (as may be the case

for a possible future efficiency

standard), it is proper to adjust the

reference temperature for load losses. A

well established algorithm published in

ANSI C57.12.90 and ANSI C57.12.91 is

used to perform the computational

operation to convert load losses

measured at a given temperature to

equivalent load losses at a different

reference temperature. For load losses of

dry-type transformers, TP 1

recommends a single reference

temperature of 75 °C, as a substitute for

the five temperatures at the rated load

corresponding to the five insulation

classes. To assess the adequacy of this

adjustment, reduced operating

temperatures were calculated at 50%

and 35% of rated load for all five

temperature classes of dry-type

insulation and for liquid-immersed

insulation. The relationship whereby

the temperature rise (OT) is proportional

to the 0.8th power of the dissipated

power (W) was used for this calculation.

Thus, AT = kW0•8, where k is a constant.

The assumption was made that, at the

rated load, 75% of dissipated power is

the load loss and the remainder is noload (core) loss.

The results are summarized in Table

1 for both 50% and 35% of the rated

loads. Note that for dry-type

transformers, out of 10 estimated

reference temperatures, five are below

75 °C, four are above, and one is exactly

on. Thus, the selected value in TP 1

represents a reasonable compromise,

especially if each of the 10 groups were

to have similar installed kVA capacity.

1.-CALCULATED TEMPERATURE RISES FOR TRANSFORMERS OPERATED AT LOWER THAN THE RATED

(NAMEPLATE) LOAD

Estm. ref- Estm. refTemperature Reference Temperature erence tem- Temperature erence temInsulation system temperature rating

°

rise at rated temperature rise at 50% of perature at rise at 35% of perature at

C load rated load 50% of rated rated load 35% of rated

°C °C load °C Load

°C °C

Liquid-Immersed

85 .............................................................. 65 85 35

DryType

55

130 ............................................................ 60 80 30 50 25 45

150 ............................................................ 80 100 40 60 35 55

185 ............................................................ 115 135 60 80 50 70

200 ............................................................ 130 150 65 85 55 75

220 ............................................................ 150 170 75 95 65 85

Assumptions:

No-load losses 25%; load losses 75%.

Algorithm: L T=kWo.8.

A T-temperature rise.

W-dissipated power.

k-constant.

A T rounded off to the nearest 5 °C.

For liquid immersed transformers, in

the proposed test procedure the

reference temperature for the load losses

is lowered from 85°C (in C57.12.00 and

C57.12.90) to 55°C. This adjustment

better approximates the conditions of

the actual use of these transformers, and

was arrived at using the same type of

approach that was used to calculate the

adjustment of the load loss reference

temperature for dry-type transformers.

The written comments received in

conjunction with the workshop on

February 10, 1998, support 20°C as the

reference temperature for no-load losses

of both types of transformers and 75°C

as the reference temperature for load

2 Medium voltages are considered to be greater 3 Low voltages are considered to be no greater

than 1200 volts. than 1200 volts.

 EE-TP-98-550 COMMENT 12A
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losses of dry-type transformers. For load

losses of liquid-immersed transformers,

stakeholders agreed with using a

reference temperature lower than 85°C

but did not recommend a specific value.

D. Measures of Energy Consumption

The test procedure provides for three

interrelated measures of energy

consumption: (a) total transformer

losses, (b) transformer efficiency, and (c)

estimated annual energy consumption

(EAEC). Under the test procedure, each

measure is computed at the loading

parameters used in NEMA TP 1-1996:

50% of the rated load for liquidimmersed and medium-voltage dry-type

transformers, and at 35% of the rated

load for low-voltage dry-type

transformers.

Transformer losses consist of load

losses and no load losses. Load losses

vary quadratically with the output

current and, hence, with output power.

No load losses vary with excitation

volatge. The efficiency of a transformer

varies with the output power as a result

of varying losses.

The industry practice, as required by

the cited ANSI standards, has been to

measure and report transformer losses

rather than energy efficiency. DOE

believes that efficiency is the preferable

energy descriptor because it is a

normalized measure and allows tradeoffs between the two types of losses,

load losses and no-load losses.

Workshop participants supported

efficiency as a measure for energy

conservation in distribution

transformers. Consequently the

Department is inclined to use efficiency

as the energy descriptor for any

standards that may be promulgated.

Expressing energy consumption in

terms of efficiency presents some

difficulties in calculations and

adjustment of test data (e.g. to reference

conditions) because accuracy may be

lost in the rounding-off process to the

nearest tenth of one percent. To avoid

this loss of computational accuracy,

under the proposed rule, the

intermediate calculations would use

transformer losses (in watts) or would

use percent efficiency with two digits

after the decimal point. Only the final

efficiency percentage would be rounded

off to the nearest one tenth of one

percent.

E. Basic Model

It is common for a manufacturer to

make numerous models of a product

covered by EPCA, and under the Act

each model is potentially subject to

testing for energy efficiency. Moreover,

for appliances covered by the EPCA

energy conservation program, although

not for distribution transformers, several

models often are essentially the same,

with each model having some

refinement that does not significantly

affect the energy efficiency or

performance. In order to lessen the

burden of test procedures, generally

appliance models having essentially

identical electrical and mechanical

characteristics are categorized into a

family of models. The Department has

used the term "basic model" to identify

a family of such models, which consist

of products or items of equipment

whose performance, design, 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.

Thus, the term "basic model" has

been defined as follows: "Basic model

means all units of a given type of

covered product (or class thereof)

manufactured by one manufacturer

and-* * * [as to dishwashers, for

example] which have electrical

characteristics that are essentially

identical, and which do not have any

differing physical or functional

characteristics which affect energy

consumption." 10 CFR 430.2.

At the February 1998 workshop, DOE

presented a similar definition for

transformers, but it was opposed by all

groups and individuals because

distribution transformers, unlike

consumer appliances, are not produced

in large numbers of virtually identical

units. However, NEMA presented an

approach in which a basic model could

be defined to include all transformers

having the same nominal power (kVA)

rating, the same insulation type (liquidimmersed or dry-type), and the same

number of phases (single or three), and

operating within the same voltage range.

Under NEMA's definition, "rating"

means a standard output power rating,

as tabulated in NEMA TP 1-1996, tables

4-1 and 4-2 (reproduced herein as

tables 2 and 3), but will encompass

some ratings that are close but not equal

to the standard ratings. These power

ratings are also the preferred ratings

from ANSI/IEEE C57.12.00-1993 for

liquid-immersed transformers and

ANSI/IEEE C57.12.01-1989 for dry-type

transformers.

The Department believes the

foregoing approach to defining "basic

model" is a sound means to reduce the

burden of testing. It would apply an

approach to distribution transformers

that has proven effective in the

residential appliance program, but with

appropriate modifications given the

nature of distribution transformers. The

factors outlined in this approach are the

design variables that affect a

transformer's efficiency. Design

considerations cause a transformer's

efficiency to increase as its power rating

increases. For dry type transformers,

efficiency decreases as voltage

increases, when all other factors are

held constant. In addition, liquidimmersed insulation is inherently more

efficient than dry-type insulation, and

multiple phases slightly decrease

efficiency. Consequently, the

Department believes the assignment of

minimum efficiencies will likely be

made in accordance with such

groupings. For example the Canadian

energy conservation standard for

distribution transformers implements

this approach. Therefore, the

Department is proposing the definition

for "basic model" be based on NEMA's

approach.

TABLE 2.-PREFERRED STANDARD

KVA RATINGS LIQUID-IMMERSED

DISTRIBUTION TRANSFORMERS

Power Rating:

10

15

25

37.5

50

75

100

167

250

333

500

667

833

Single-Phase

Power Rating:

15

30

45

75

112.5

150

225

300

500

750

1000

1500

2000

2500

Three-phase

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TABLE 3.-PREFERRED STANDARD

KVA RATINGS DRY-TYPE DISTRIBUTION TRANSFORMERS

Power rating, Low voltage, > 1.2

kV

Medium

kVA

15

25

37.5

50

75

100

167

250

333

500

667

833

15

30

45

75

112.5

150

225

300

500

750

1000

1500

2000

2500

Single-Phase

Three-Phase

voltage, <_

1.2 kV

The Department has some concern,

however, that this approach may allow

manufacturers who sell some high

efficiency models to deliberately under

design other transformers within that

basic model, while still meeting the

standard for the average efficiency of the

basic model. The Department is

considering addressing this point by

imposing a maximum efficiency

variation within a basic model, similar

to what is now done in ANSI/IEEE

C57.12.00 and C57.12.01, as well as

NEMA TP 2. The Department would

like comments on this concern.

F. Number of Units to be Tested

As discussed above, the classification

of transformers into "basic models" is

one step to reduce the burden of testing.

The Department also proposes to permit

the use of a statistically meaningful

sampling procedure for selecting test

specimens, so as to further reduce the

testing burden on manufacturers while

giving sufficient assurance that the true

mean energy efficiency of a basic model

meets or exceeds the efficiency level

claimed by the manufacturer.

Although the sampling plan presented

in this test procedure rule might have

some application during the evaluation

of possible efficiency standards, it

would become operative primarily if

and when standards are promulgated.

At that point, the efficiency of each

basic model of distribution transformer

would be established initially by

"compliance testing" for the purposes of

determining whether the transformer

complies with the applicable efficiency

standard and of labeling the

transformer. A sampling plan for

compliance is intended to provide a

statistically meaningful sampling

procedure for conducting tests, so as to

reduce the testing burden while giving

sufficient assurance that the true mean

energy efficiency of a basic model (i.e.,

the average efficiency of all units

manufactured) meets or exceeds a given

performance level.

For this purpose, one product under

10 CFR Part 430, § 430.24, involves

some similarities with distribution

transformers. The required sampling

plan for compliance testing of

fluorescent lamp ballasts under § 430.24

(q) (1) states, "For each basic model of

fluorescent lamp ballasts, as defined in

paragraph (14) of § 430.2, a sample of

sufficient size, no less than four, shall

be tested to insure that (i) any

represented value of estimated annual

operating costs, energy consumption, or

other measure of energy consumption of

a basic model for which consumers

would favor a lower value shall be no

less than the higher of (A) the mean of

the sample or (B) the upper 99 percent

confidence limit divided by 1.01, and

(ii) any represented value of the ballast

efficiency factor or other measure of

energy consumption of a basic model for

which consumers would favor a higher

value shall be no greater than the lower

of (A) the mean of the sample or (B) the

lower 99 percent confidence limit of the

true mean divided by 0.99."

A sampling plan for enforcement, on

the other hand, is intended to provide

a statistically meaningful sampling

procedure for conducting tests, so as to

reduce the testing burden while giving

sufficient assurance that a distribution

transformer found to be in

noncompliance will actually be in

noncompliance. The sampling plan for

enforcement testing under Part 430 is

provided in 10 CFR 430.70, Appendix

B. This sampling plan is based on the

statistical t-test yielding 97.5 percent

probability of obtaining a determination

of compliance when the true mean

efficiency is equal to the applicable

standard.

At the February 1998 workshop, DOE

presented both sampling approaches for

consideration for compliance testing for

distribution transformers. In the

comments on workshop issues, 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 favors consumers by providing 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. Most of the

error introduced by estimating the

performance of the basic model from a

sample (rather than from testing all

units) is absorbed by the producer

(manufacturer). The probability of false

determination of compliance is low and

is quantifiable from the confidence limit

and the divisor. For example, for

transformer losses, using a lower

confidence limit of 95%, 0.97 as the

divisor, and assuming a standard

deviation of 3% for a basic model and

a minimum sample size of five, possible

errors and corresponding probabilities

for false determinations of compliance

are:

Error in percent 1.5 2.0 2.9

Probability in

percent ........... 10 5 1

Under these constraints there is a

probability of less than 5% that the

estimated average losses of the entire

population exceed the true average by

2%.

Conversely, the enforcement sampling

approach in Part 430 is based on a

Student's t-test; it generally tests

whether there is a sufficiently high

probability to conclude that the average

performance of all units of the basic

model is below the standard to warrant

enforcement action. By selecting an

upper confidence limit and a minimum

sample size, the probability of the

populations not meeting the standard by

a certain amount can be established. For

example, for transformer losses, using

the upper 95% confidence limit and a

sample size of five, on a population

with standard deviation of 3%, the

possible errors and corresponding

probabilities for significant false

determinations of compliance are high

as shown in the table below:

Error in percent 0.8 2.9 5.7

Probability in

percent ........... 90 50 5

Under these constraints there is a

probability of almost 50% that the

estimated average losses of the entire

population exceed the true average by

3%.

Thus, after considerable review, the

Department is proposing in today's

proposed rule to use Part 430's sampling

 EE-TP-98-550 COMMENT 12A
Federal Register /Vol. 63, No. 218 /Thursday, November 12, 1998/Proposed Rules 63367

approach for compliance testing. For

transformer losses, the proposed lower

confidence limit is 95%, and the divisor

is 0.97, with a minimum sample size of

five.

Some manufacturers, however,

particularly small companies, have

limited output of certain basic models;

consequently, under today's proposed

sampling plan, a manufacturer would

need to test a relatively high proportion

of the units it manufactures of such a

basic model. Moreover, although the

Department could provide in its

sampling plan that the minimum

number of units tested of a low

production basic model be reduced from

five to two or three, any such basic

model would be subject to increased

risk of being determined to be in noncompliance due to the statistical

probabilities associated with testing a

small number of units. To allay these

concerns, the Department is considering

three possible approaches for sampling

limited production models:

(1) Combine two or more limited

production basic models of distribution

transformer into an aggregate "basic

model";

(2) Allow testing of a sample fewer

than five units, and also permit the use

of a represented efficiency value that

exceeds, by a specified increment, the

average efficiency of the sample, so long

as each tested unit exceeds a

minimum level of efficiency 4;

(3) Allow compliance testing over a

period of time.

The third alternative would be similar

to the Department's approach for lamps,

which permits lamp manufacturers to

submit a certification report up to one

year after the date the manufacture of a

new model commences, provided that

prior to distribution the manufacturer

submits a statement describing how it

determined the model meets the energy

conservation standard. See section

430.62(c)(2) and 42 U.S.C. 6295(i)(7).

The Department solicits comments on

these possible approaches.

G. New Part 432

10 CFR part 430 covers consumer

products as distinct from commercial

and industrial equipment. The

4 DOE is considering, as a method of

implementing this approach, the following: If fewer

than 5 units of a basic model are manufactured in

a period of 180 days, all units manufactured within

this period shall be tested, and the average

efficiency of the sample E shall satisfy the condition

E? Es [1 - 0.04 -'n (1 - Es =100) ]

where n is the number of units in the sample, and

E, is the represented value of efficiency.

For sample sizes of two, three, or four

transformers, the lowest efficiency in the sample

E,,,;,, shall satisfy the condition

En,;„ _ Es [1 - 0.08 (1 -Es-100)]

Department proposed to create a new

part 431 in the Code of Federal

Regulations (10 CFR part 431) to cover

certain commercial and industrial

equipment 61 FR 60439 (November 27,

1996). The Department is now

contemplating adding a new Part 432

which would include products

addressed under 346 of EPCA.

III. Procedural Requirements

A. Review Under the National

Environmental Policy Act of 1969

In this rulemaking, the Department

proposes provisions to establish test

procedures for electric distribution

transformers. These test procedures

would be used initially only for the

purpose of considering the adoption of

energy conservation standards. During a

subsequent rulemaking concerning such

standards, the Department will address

the extent to which these test

procedures would become generally

applicable and binding for determining

the energy efficiency of distribution

transformers.

The Department has concluded that

this rule would not have a significant

effect on the human environment, and

is covered under the categorical

exclusion A.6 of appendix A to Subpart

D, 10 CFR Part 1021, which applies to

procedural rulemakings. (10 CFR Part

1021 is a DOE regulation implementing

the National Environmental Policy Act

of 1969 (NEPA), and Appendix A to

Subpart D sets forth DOE actions

excluded from NEPA review.)

Accordingly, neither an environmental

assessment nor an environmental

impact statement is required.

B. Review Under Executive Order 12866,

"Regulatory Planning and Review"

Today's proposed rule has been

determined not to be a "significant

regulatory action," as defined in section

3(0 of Executive Order 12866,

"Regulatory Planning and Review." 58

FR 51735 (October 4, 1993).

Accordingly, this action was not subject

to review under the Executive Order by

the Office of Information and Regulatory

Affairs.

C. Review Under the Regulatory

Flexibility Act

The Regulatory Flexibility Act, 5

U.S.C. 603, requires the preparation of

an initial regulatory flexibility analysis

for every rule which by law must be

proposed for public comment, unless

the agency certifies that the rule, if

promulgated, will not have a significant

economic impact on a substantial

number of small entities. A regulatory

flexibility analysis examines the impact

of the rule on small entities and

considers alternative ways of reducing

negative impacts.

Today's proposed rule prescribes test

procedures that will be used to

determine what standards, if any, DOE

would adopt, and that would likely

become generally applicable only upon

adoption of standards. Unless and until

such standards are adopted, the

Department anticipates that

manufacturers will use the test

procedures to voluntarily test their

transformers and provide to DOE

efficiency information about their

products. No entities, small or large,

would be required to comply with these

test procedures. Therefore DOE believes

today's proposed rule does not have a

"significant economic impact on a

substantial number of small entities,"

and the preparation of a regulatory

flexibility analysis is not warranted.

D. Review Under Executive Order

12612, "Federalism"

Executive Order 12612, "Federalism,"

52 FR 41685 (October 30, 1987),

requires that regulations, rules,

legislation, and any other policy actions

be reviewed for any substantial direct

effect on States, on the relationship

between the National Government and

States, or in the distribution of power

and responsibilities among various

levels of government. If there are

substantial effects, then the Executive

Order requires preparation of a

federalism assessment to be used in all

decisions involved in promulgating and

implementing a policy action.

The proposed rule published today

would not regulate the States. At this

point, it primarily would affect the

manner in which DOE determines

whether standards should be adopted,

as prescribed under the Energy

Conservation and Policy Act. The

proposed rule published today would

not alter the distribution of authority

and responsibility to regulate in this

area. Accordingly, DOE has determined

that preparation of a federalism

assessment is unnecessary.

E. Review Under Executive Order 12630,

"Governmental Actions and

Interference With Constitutionally

Protected Property Rights"

It has been determined pursuant to

Executive Order 12630, "Governmental

Actions and Interference with

Constitutionally Protected Property

Rights," 52 FR 8859 (March 18, 1988),

that this regulation would not result in

any takings which might require

compensation under the Fifth

Amendment to the United States

Constitution.

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63368 Federal Register /Vol. 63, No. 218/Thursday, November 12, 1998 /Proposed Rules

F. Review Under the Paperwork

Reduction Act

Today's notice of proposed

rulemaking would not impose any

compliance certification, labeling or

other reporting requirements.

Accordingly, no OMB clearance is

required under the Paperwork

Reduction Act (44 U.S.C. 3501 etseq.).

G. Review Under Executive Order

12988, "Civil Justice Reform "

With respect to the review of existing

regulations and the promulgation of

new regulations, Section 3(a) of

Executive Order 12988, "Civil Justice

Reform," 61 FR 4729 (February 7, 1996),

imposes on executive agencies the

general duty to adhere to the following

requirements: (1) eliminate drafting

errors and ambiguity; (2) write

regulations to minimize litigation; and

(3) provide a clear legal standard for

affected conduct rather than a general

standard and promote simplification

and burden reduction. With regard to

the review required by Section 3(a),

Section 3(b) of the Executive Order

specifically requires that Executive

agencies make every reasonable effort to

ensure that the regulation: (1) clearly

specifies the preemptive effect, if any;

(2) clearly specifies any effect on

existing Federal law or regulation; (3)

provide a clear legal standard for

affected conduct while promoting

simplification and burden reduction; (4)

specifies the retroactive effect, if any; (5)

adequately defines key terms; and (6)

addresses other important issues

affecting clarity and general

draftsmanship under any guidelines

issued by the Attorney General. Section

3(c) of the Executive Order requires

Executive agencies to review regulations

in light of applicable standards Section

3(a) and Section 3(b) to determine

whether they are met or it is

unreasonable to meet one or more of

them. DOE reviewed today's proposed

regulation under the standards of

Section 3 of the Executive Order and

determined that, to the extent permitted

by law, it meets the requirements of

those standards.

H. Review Under Section 32 of the

Federal Energy Administration Act of

1974

Pursuant to Section 301 of the

Department of Energy Organization Act

(Pub. L. 95-91), the Department of

Energy is required to comply with

Section 32 of the Federal Energy

Authorization Act (FEAA), as amended

by Section 9 of the Federal Energy

Administration Authorization Act of

1977 (Pub. L. 95-70). Section 32

provides in essence that, where a

proposed rule contains or involves use

of commercial standards, the notice of

proposed rulemaking must inform the

public of the use and background of

such standards.

The rule proposed in this notice

incorporates by reference commercial

standards NEMA TP 2. The Department

has evaluated these standards and

concludes they were not developed in a

manner which fully provides for public

participation, comment, and review.

The rule proposed in this notice also

incorporates by reference commercial

standards IEEE/ANSI C57.12.90-1993,

C57.12.91-1995, C57.12.00-1993, and

C57.12.01-1989, as well as ISO

Standard 9001-1993. The Department

has evaluated these standards and is

unable to conclude whether they were

developed in a manner which fully

provides for public participation,

comment, and review. However, the

Department believes the IEEE/ANSI and

ISO review processes provide for

participation from a larger group of

entities than the NEMA standards

review process.

As required by Section 32(c) of the

Federal Energy Administration Act, the

Department will consult with the

Attorney General and the Chairman of

the Federal Trade Commission

concerning the impact of these

standards on competition, prior to

prescribing a final rule.

1. Review Under Unfunded Mandates

Reform Act of 1995

Section 202 of the Unfunded

Mandates Reform Act of 1995

("Unfunded Mandates Act") requires

that the Department prepare a budgetary

impact statement before promulgating a

rule that includes a Federal mandate

that may result in expenditure by state,

local, and tribal governments, in the

aggregate, or by the private sector, of

$100 million or more in any one year.

The budgetary impact statement must

include: (i) identification of the Federal

law under which the rule is

promulgated; (ii) a qualitative and

quantitative assessment of anticipated

costs and benefits of the Federal

mandate and an analysis of the extent to

which such costs to state, local, and

tribal governments may be paid with

Federal financial assistance; (iii) if

feasible, estimates of the future

compliance costs and of any

disproportionate budgetary effects the

mandate has on particular regions,

communities, non-Federal units of

government, or sectors of the economy;

(iv) if feasible, estimates of the effect on

the national economy; and (v) a

description of the Department's prior

consultation with elected

representatives of state, local, and tribal

governments and a summary and

evaluation of the comments and

concerns presented.

The Department has determined that

the action proposed today does not

include a Federal mandate that may

result in estimated costs of $100 million

or more to state, local or to tribal

governments in the aggregate or to the

private sector. Therefore, the

requirements of Sections 203 and 204 of

the Unfunded Mandates Act do not

apply to this action.

IV. Public Comment

A. Written Comment Procedures

Interested persons are invited to

participate in the proposed rulemaking

by submitting data, comments, or

information with respect to the

proposed issues set forth in today's

proposed rule to Ms. Kathi Epping, at

the address indicated at the beginning of

the notice. All submittals received by

the date specified at the beginning of

this notice will be considered by the

Department in developing the final rule.

Pursuant to the provisions of 10 CFR

1004.11, any person submitting

information which he or she believes to

be confidential and exempt by law from

public disclosure should submit one

complete copy of the document and ten

(10) copies, if possible, from which the

information believed to be confidential

has been deleted. The Department of

Energy will make its own determination

with regard to the confidential status of

the information and treat it according to

its determination.

Factors of interest to the Department

when evaluating requests to treat as

confidential information that has been

submitted include: (1) a description of

the items; (2) an indication as to

whether and why such items are

customarily treated as confidential

within the industry; (3) whether the

information is generally known by or

available from other sources; (4)

whether the information has previously

been made available to others without

obligation concerning its

confidentiality; (5) an explanation of the

competitive injury to the submitting

person which would result from public

disclosure; (6) an indication as to when

such information might lose its

confidential character due to the

passage of time; and (7) why disclosure

of the information would be contrary to

the public interest.

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B. Public Hearing

1. Procedures for Submitting Requests

To Speak

The time and place of the public

hearing are indicated at the beginning of

this notice of proposed rulemaking. The

Department invites any person who has

an interest in today's notice of proposed

rulemaking, or who is a representative

of a group or class of persons that has

an interest in these proposed issues, to

make a request for an opportunity to

make an oral presentation. If you would

like to attend the public hearing, please

notify Ms. Brenda Edwards-Jones at

(202) 586-2945. Requests to speak may

be hand delivered to the address

indicated at the beginning of the notice

between the hours of 8:00 a.m. and 4:00

p.m., Monday through Friday, except

Federal holidays.

The person making the request should

briefly describe the interest concerned

and state why he or she, either

individually or as a representative of a

group or class of persons that has such

an interest, is an appropriate

spokesperson, and give a telephone

number where he or she may be

contacted.

Each person selected to be heard is

requested to submit an advance copy of

his or her statement prior to the hearing

as indicated at the beginning of this

notice. Any person wishing to testify

who cannot meet this requirement, may

at the Department's discretion be

permitted to testify if that person has

made alternative arrangements with the

Office of Codes and Standards in

advance. The letter making a request to

give an oral presentation shall ask that

such alternative arrangements be made.

2. Conduct of Hearing

A DOE official will be designated to

preside at the hearing. The hearing will

not be a judicial or an evidentiary-type

hearing, but will be conducted in

accordance with 5 U.S.C. 553 and

Section 336 of the Act. The Department

of Energy reserves the right to select the

persons to be heard at the hearing, to

schedule the respective presentations,

and to establish the procedures

governing the conduct of the hearing.

Each participant will be permitted to

make a prepared general statement,

limited to five (5) minutes, prior to the

discussion of specific topics. The

general statement should not address

these specific topics, but may cover any

other issues pertinent to this

rulemaking. Other participants will be

permitted to briefly comment on any

general statements. The hearing will

then be divided into segments, with

each segment consisting of one or more

topics covered by this notice, as follows:

(1) proposed test procedures; (2)

adequacy of TP 2 to meet the

requirements of users; (3) distribution

transformers not subject to the test

procedures; (4) grouping of transformers

for testing purposes, as manifested by

the definition of a basic model; (5)

sampling plan for compliance; and (6)

general statutory requirements. Any

issue concerning a definition in the

proposed rule should be addressed

during the discussion of the topic(s) to

which that issue pertains.

The Department will introduce each

topic with a brief summary of the

relevant provisions of the proposed rule,

and the significant issues involved.

Participants in the hearing will then be

permitted to make a prepared statement

limited to five (5) minutes on that topic.

At the end of all prepared statements on

a topic, each participant will be

permitted to briefly clarify his or her

statement and comment on statements

made by others. The Department is

particularly interested in having

participants address in their statements

the specific issues set forth below in

Section IV-C, "Issues for Public

Comment," and participants should be

prepared to answer questions by the

Department concerning these issues.

Representatives of the Department may

also ask questions of participants

concerning other matters relevant to the

hearing. The total cumulative amount of

time allowed for each participant to

make prepared statements shall be 20

minutes.

The official conducting the hearing

will accept additional comments or

questions from those attending, as time

permits. Any further procedural rules,

or modification of the above procedures,

needed for the proper conduct of the

hearing will be announced by the

presiding official.

A transcript of the hearing will be

made, and the entire record of this

rulemaking, including the transcript,

will be retained by the Department of

Energy and made available for

inspection in the Department's Freedom

of Information Reading Room. Any

person may purchase a copy of the

transcript from the transcribing reporter.

C. Issues Requested for Comment

The Department of Energy is

interested in receiving comments and/or

data concerning the feasibility,

workability and appropriateness of the

test procedures proposed in today's

proposed rulemaking. Also, DOE

welcomes discussion on improvements

or alternatives to these approaches. In

particular, the Department is interested

in gathering comments on the following:

63369

• The adequacy of TP 2 to meet the

requirements of non-NEMA

manufacturers and users, such as

utilities and contractors who specify

transformers for commercial and

industrial applications (e.g., retail,

industrial, and office buildings);

• Distribution transformers not

subject to the test procedures;

• Grouping of transformers for testing

purposes, as manifested by the

definition of a basic model; and

• The sampling plan for compliance

(The Department is particularly

interested in discussing how small

populations should be handled.)

List of Subjects in 10 CFR Part 432

Administrative practice and

procedure, Energy conservation,

Household appliances. Incorporation by

reference.

Issued in Washington, DC., on October 2,

1998.

Dan W. Reicher,

Assistant Secretary, Energy Efficiency and

Renewable Energy.

For the reasons set forth in the

preamble, Chapter II of Title 10, Code of

Federal Regulations, is proposed to be

amended by adding a new Part 432 to

read as follows.

PART 432-ENERGY CONSERVATION

PROGRAM FOR DISTRIBUTION

TRANSFORMERS

Sec.

432.1 Purpose and scope [Reserved].

432.2 Definitions.

432.22 Reference Sources.

432.24 Units to be tested.

Appendix A to Part 432-Uniform Test

Method for Measuring the Energy

Consumption of Distribution

Transformers.

Authority: 42 U.S.C. 6317.

§ 432.1 Purpose and scope [Reserved].

§ 432.2 Definitions.

Basic model means 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).

Converter transformer means a

transformer designed for the dedicated

applications of converting direct current

(dc) to alternating current (ac), or

converting alternating current to direct

current. Its nameplate contains a rating

for the fundamental-frequency apparent

output power and a rating for the

apparent output power with non

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sinusoidal current produced by the

converter.

Distribution transformer means a

transformer with a primary voltage of

480 V to 35 kV, a secondary voltage of

120 V to 600 V, a frequency of 55-65

Hz, and a capacity of either 10 to 2500

kVA for liquid-immersed transformers

or 0.25 kVA to 2500 kVA for dry-type

transformers, except for:

(1) Converter and rectifier

transformers with more than two

windings per phase, and

(2) Transformers which are not

designed to be continuously connected

to a power distribution system as a

distribution transformer. This second

exception includes regulating

transformers, machine tool transformers,

welding transformers, grounding

transformers, testing transformers, and

other transformers which are not

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.

Dry-type distribution transformer

means a distribution transformer in

which the core and coils are immersed

in a gaseous or dry-compound

insulating medium.

Efficiency means, for a distribution

transformer, the ratio of the useful

output power to the total input power.

Liquid-immersed distribution

transformer means a distribution

transformer in which the core and coils

are immersed in an insulating liquid.

Load losses mean, for a distribution

transformer, those losses which are

incident to the carrying of a specified

load. Load losses consist of ohmic (12R)

loss in the windings due to load and

eddy currents; the loss due to

circulating currents in parallel windings

or in parallel winding strands; and stray

losses due to leakage fluxes in the

windings, core clamps, and other parts.

Low-voltage dry-type transformer

means a distribution transformer with a

primary voltage rated at 1.2 kV and

below.

Medium-voltage dry-type transformer

means a distribution transformer with a

primary voltage rated above 1.2 W.

No-load losses mean, for a

distribution transformer, those losses

which are incident to the excitation of

the transformer. No-load losses consist

of core loss, dielectric loss, conductor

loss in the windings due to exciting

current, and conductor loss due to the

circulating currents in parallel

windings.

Rectifier transformer means a

transformer designed for the dedicated

application of converting alternating

current to direct current. Its nameplate

contains a rating for the fundamentalfrequency apparent output power and a

rating for the apparent output power

with non sinusoidal current produced

by the converter.

Total losses mean, for a distribution

transformer, the total of the no-load and

load losses. It does not include losses

due to accessories, such as cooling fans.

Transformer means a static

electromagnetic device consisting of a

winding, or two or more coupled

windings, with a magnetic core for

introducing inductive coupling between

electric circuits, designed to transfer

power by electromagnetic induction

between circuits at the same frequency.

§ 432.22 Reference Sources.

(a) Materials Incorporated by

Reference. (1) General. The following

standards which are not otherwise set

forth in this part 432 are incorporated

by reference. The material listed in

paragraph (a) (2) of this section has been

approved for incorporation by reference

by the Director of the Federal Register

in accordance with 5 U.S.C. 552(a) and

1 CFR Part 51. Any subsequent

amendment to a standard by the

standard-setting organization will not

affect the DOE test procedures unless

and until amended by DOE. Material is

incorporated as it exists on the date of

the approval and a notice of any change

in the material will be published in the

Federal Register.

(2) Availability of Standards.

Option One for Paragraph (a)(2)(i) 5

(i) Copies of ANSI standards C57.12.90-

1993, C57.12.91-1995, and C57.12.00-1993

can be obtained from the American National

Standards Institute, 11 West 42nd Street,

New York, N.Y., 10036:

Option Two for Paragraph (a)(2)(i)

(i) Copies of NEMA Standards Publication

TP 2-1998 can be obtained from Global

Engineering Documents World Headquarters,

15 Iverness Way East, Inglewood, CO 80112-

5776;

(ii) All standards incorporated by reference

are available for inspection at the U.S.

Department of Energy, Office of Energy

Efficiency and Renewable Energy, Hearings

and Dockets, Forrestal Building, 1000

Independence Ave, SW, Washington, DC

20585.

5In the preamble to this proposed rule, the

Department states its intention to adopt as the test

procedure for distribution transformers either

portions of standards prepared by IEEE and

approved by ANSI, or portions of a standard being

developed by NEMA. In the proposed rule

language, passages introduced by the phrase

"OPTION ONE FOR PARAGRAPH "

constitute the language DOE proposes to use if it

decides to adopt the ANSI/IEEE standards, and the

phrase "OPTION TWO FOR PARAGRAPH "

introduces the regulatory language proposes in the

event the NEMA standard is adopted.

(iii) All standards incorporated by

reference are available for inspection at the

Office of the Federal Register Information

Center, 800 North Capitol Street, N.W.,

Washington, DC.

Option One for Paragraph (a)(3)

(3) List of standards incorporated by

reference. (i) ANSI/IEEE Standard 057.12.90-

1993, "IEEE Standard Test Code for LiquidImmersed Distribution, Power, and

Regulating Transformers and IEEE Guide for

Short-Circuit Testing of Distribution and

Power Transformers", sections 5 through

5.3.2, sections 8 through 8.4, and sections 9

through 9.4.1.

(ii) ANSI/IEEE Standard C57.12.00-1993,

IEEE Standard General Requirements for

Liquid-Immersed Distribution, Power, and

Regulating Transformers" clause 9.4.

(iii) ANSI/IEEE Standard C57.12.91-1995,

"IEEE Standard Test Code for Dry-Type

Distribution and Power Transformers"

clauses 5 through 5.4.2.3, clauses 8 through

8.3, and clauses 9 through 9.4.2.

Option Two for Paragraph (a)(3)

(3) Standard incorporated by reference.

NEMA Standards Publication TP 2-1998,

"Standard Test Method for Measuring the

Energy Consumption of Distribution

Transformers" sections 1, 2, 3, 4, 5, and 6.

Deviations from these sections are set forth

at Appendix A to Part 432 section 3.2(ii).

Option One for Paragraph (b)

(b) Reference Standard. The following

standard is referred to in the DOE test

procedure and elsewhere in 10 CFR part 432

but is not incorporated by reference and is

provided here for guidance: ISO Standard

9001-1993, "Quality Systems-Model for

quality assurance in design, development,

production, installation, and servicing"

clause 4.11.1.

Option Two Omits Paragraph (b)

§ 432.23 Test procedures for measures of

energy consumption.

Option One for Paragraph (a)

(a) Total losses, expressed in kilowatts, of

a liquid-immersed distribution transformer

operated at 50% of the rated load shall be

determined in accordance with clause 3.1.2

of Appendix A to this part. Total losses of a

dry-type distribution transformer operated at

either 50% or 35% of the rated load, as

appropriate, shall be determined in

accordance with clause 3.2.3 of Appendix A

to this part.

Option Two for Paragraph (a)

(a) Total losses, expressed in kilowatts, of

a liquid-immersed distribution transformer

operated at 50% of the rated load shall be

determined in accordance with clause 3.3 of

Appendix A to this part. Total losses of a drytype distribution transformer operated at

either 50% or 35% of the rated load, as

appropriate, shall be determined in

accordance with clause 3.4 of Appendix A to

this part.

Option One for Paragraph (b)

(b) Efficiency, expressed in percent, of a

liquid-immersed distribution transformer

 EE-TP-98-550 COMMENT 12A
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operated at 50% of the rated load shall be

determined in accordance with clause 3.1.2

of Appendix A to this part. Efficiency of a

dry-type distribution transformer, expressed

in percent, operated at either 50% or 35% of

the rated load shall be determined in

accordance with clause 3.2.3 of Appendix A

to this part.

Option Two for Paragraph (b)

(b) Efficiency, expressed in percent, of a

liquid-immersed distribution transformer

operated at 50% of the rated load shall be

determined in accordance with clause 3.5 of

Appendix A to this part. Efficiency of a drytype distribution transformer, expressed in

percent, operated at either 50% or 35% of the

rated load shall be determined in accordance

with clause 3.5 of Appendix A to this part.

(c) The estimated annual energy

consumption (EAEC), expressed in kilowatthours per year, for a distribution transformer

operating continuously at 50% or 35% of the

rated output power, as appropriate, shall be

the product of.

(1) The total losses in kilowatts as

determined in paragraph (a) of this section;

and

(2) The representative use cycle of 8766

hours per year.

§ 432.24 Units to be tested.

For each basic model of distribution

transformers, a random sample of

sufficient size , but no fewer than five

production units, shall be tested to

insure that any represented value of

efficiency shall be no greater than the

lower of the:

(a) Mean of the sample; or

(b) The lower 95% confidence limit of

the estimated true mean divided by a

number equal to [1-0.03(1-ES/100)],

where E. is the represented value of

efficiency claimed for that particular

basic model.

Appendix A to Part 432-Uniform Test

Method for Measuring the Energy

Consumption of Distribution Transformers

1. Definitions. Use the definitions in 10

CFR 432.21 and the following:

1.1 ANSI Standard means a standard

approved by a committee accredited by the

American National Standards Institute.

1.2 IEEE Standard means a standard

developed and approved by the Institute of

Electrical and Electronics Engineers. All IEEE

standards referenced in Appendix A have

been approved or recognized by ANSI.

1.3 ISO Standard means a standard

developed and approved by the International

Standards Organization.

1.4 NEMA Standards Publication means a

standard developed and approved by

National Electrical Manufacturers

Association.

1.5 Phase angle error means an error

introduced in the phase angle displacement

between voltage and current phasors by the

test equipment. Phase angle error, if

significant, can introduce errors in measured

transformer losses.

1.6 Phase angle correction means the

adjustment (correction) of measurement data

to negate the effects of phase angle error.

1.7 Reference temperature means the

temperature, specified in a standard, to

which the transformer losses shall be

corrected and reported.

1.8 Temperature correction means the

adjustment (correction) of measurements of

no load losses and load losses, obtained with

the distribution transformer under test at a

temperature that is different from the

reference temperature, to values that would

have been obtained with the distribution

transformer at the reference temperature.

1.9 Test voltage means the voltage of the

electric power supplied to the distribution

transformer under test.

1.10 Waveform correction means the

adjustment (correction) of measurement data

obtained with a test voltage that is nonsinusoidal (distorted) to values that would

have been obtained with sinusoidal voltage.

Option One for Paragraph 2

2. References.

2.1 ANSI/IEEE Standard C57.12.90-1993,

"IEEE Standard Test Code for LiquidImmersed Distribution, Power, and

Regulating Transformers and IEEE Guide for

Short-Circuit Testing of Distribution and

Power Transformers" (ANSI/IEEE C57.12.90).

2.2 ANSI/IEEE Standard C57.12.00-1993,

IEEE Standard General Requirements for

Liquid-Immersed Distribution, Power, and

Regulating Transformers" (ANSI/IEEE

C57.12.00).

2.3 ANSI/IEEE Standard C57.12.91-1995,

"IEEE Standard Test Code for Dry-Type

Distribution and Power Transformers"

(ANSI/IEEE C57.12.91).

2.4 ISO Standard 9001-1993, "Quality

Systems-Model for quality assurance in

design, development, production,

installation, and servicing."

Option Two for Paragraph 2

2. References.

NEMA Standards Publication TP 2-1998,

"Standard Test Method for Measuring the

Energy Consumption of Distribution

Transformers" (NEMA TP 2).

Option One for Paragraph 3

3. Test Procedures' Measurements and

Instrumentation, Reference Conditions,

Calculations.

The resistance of transformer windings, the

no-load losses, and the load losses of

transformers shall be measured, and the total

losses and efficiency shall be computed at

the specified loading levels and reference

temperatures, using the methods described in

the following industry standards (with

certain specified modifications and

exceptions): ANSI/IEEE standards C57.12.90-

1993 and C57.12.91-1995 (primary

references); ANSI/IEEE standard C57.12.00-

1993 (supplemental reference). The methods

to be used, including applicable sections and

clauses in the referenced standards, as well

as exceptions and modifications to such

sections and clauses, are listed in this

appendix: §§ 3.1-3.3 and their subclauses.

3.1 Liquid-Immersed Distribution

Transformers.

Using the methods specified in ANSI/IEEE

standard C57.12.90-1993 sections 5, 8, and 9,

measure the resistance of transformer

windings, the no-load losses and load losses

of liquid-immersed distribution transformers.

Perform waveform correction on the

measured no-load losses and perform phase

angle correction for the load losses.

3.1.1 Perform temperature corrections for

the loss data of § 3.1 by converting the noload losses to 20°C and converting the load

losses to 55°C with the loading at 50% of the

rated load. To perform these temperature

corrections, the provisions in sections 8.4

and 9.4.2 of ANSI/IEEE standard C57.12.90-

1993 are applicable. For the conversion to the

50% loading the quadratic relationship

P(L50)=P(LM) (50/M)2 applies, where P(L50) is

the load loss power at 50% loading, P(LM) is

the load loss power at M% loading, and (50/

M) is the ratio of the loading at the 50%

reference condition to the loading during the

measurement (near 100% loading).

3.1.2 Calculate the total losses (Pso) at 50

% loading by adding the no-load losses and

the load losses as computed in § 3.1.1, and

calculate the efficiency at 50 % loading

according to the equation:

Eso=100 [Po(se)/(P0(so)+PL(20))],

where E50 is the efficiency at 50% loading,

and PU(SO) and PL(so) are the output power and

total loss power, respectively, at 50%

loading.

3.2 Dry-Type Transformers.

Using the methods specified in ANSI/IEEE

standard C57.12.91-1995, sections 5, 8, and

9, measure the resistance of transformer

windings, the no-load losses and load losses

of dry-type distribution transformers.

Perform waveform correction on the

measured no-load losses and perform phase

angle correction for the load losses.

3.2.1 In addition to the requirements of

ANSI/IEEE standard C57.12.91-1995, the

following two additional requirements apply

to the measurements in section 3.2 of this

appendix:

(i) Perform phase angle correction for the

measured load losses as specified in ANSI/

IEEE standard C57.12.90-1993, clause 9.4.1

and Table 1;

(ii) Measure the no-load losses with the

transformer at the reference temperature of

20°C; a temperature tolerance of ±10°C is

permissible; if no-load loss measurements are

conducted outside this temperature

tolerance, perform the appropriate

temperature correction such as that specified

in ANSI/IEEE standard C57.12.90-1993,

clause 8.4.

3.2.2 Perform temperature corrections for

the loss data by converting the load losses of

medium-voltage dry-type transformers to

75°C, at 50% of the rated load, and

converting the load losses of low-voltage drytype transformers to 75°C, at 35% of the rated

load. To perform these temperature

corrections, the provisions of ANSI/IEEE

standard C57.12.91-1995, clause 9.4.1 shall

apply. For the conversions to the 50% and

35% loading levels the algorithm of § 3.1.1

applies.

3.2.3 Calculate the total losses, PL(5o)(35),

at either 50% or 35% loading, as appropriate,

by adding the no-load losses and load losses

as computed in § 3.2.2, and calculate the

efficiency of the transformer at either 50% or

35% loadings according to the equation:

E(5o)(30)=100 [Po(so)(30)/(Potsox30)+PL(50)(30))],

where E(5)(3o) is the efficiency in percent,

PO(50)(30) is the output power in kilowatts, and

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Pu5o)(3o) is the loss power in kilowatts. The

subscripts, (50) or (35), denote the loading

levels, either 50% or 35%.

3.3 Quality Assurance in Testing.

Accuracies required for measuring the

winding resistances, the no-load and load

losses, and the temperature of distribution

transformers shall be those specified in ANSI

Standard C57.12.00-1993, Section 9.4.

Test equipment and measuring instruments

shall be calibrated and maintained in their

normal operating condition. Calibration

records shall be maintained to demonstrate

compliance with the required measurement

accuracies. General guidance as to

procedures that will aid in meeting these

objectives is provided by the following

Clause 4.11.1 of ISO Standard 9001-1993,

"Quality Systems-Model for quality

assurance in design, development,

production, installation, and servicing.":

"The supplier shall establish and maintain

documented procedures to control, calibrate

and maintain inspection, measuring and test

equipment (including test software) used by

the supplier to demonstrate the conformance

of product to the specified requirements.

Inspection, measuring and test equipment

shall be used in a manner which ensures that

measurement uncertainty is known and is

consistent with the required measurement

capability."

Option Two for Paragraph 3

3. Test Procedures-Measurements and

Instrumentation, Reference Conditions,

Calculations.

The resistance of transformer windings, the

no-load losses, and the load losses of

transformers shall be measured, and the total

losses and efficiency shall be computed at

the specified loading levels and reference

temperatures, using the methods described in

the following industry standards (with

certain specified modifications and

exceptions): NEMA standard TP 2. The

methods to be used, including applicable

sections and clauses in the referenced

standards, as well as exceptions and

modifications to such sections and clauses,

are listed in this appendix: sections 3.1-3.5

and their subclauses.

3.1 Liquid-Immersed and Dry-Type

Distribution Transformers.

In accordance with NEMA TP 2, sections

1, 2, 3, 4, 5, and 6, do the following: measure

the resistance of transformer windings, the

no-load losses, and the load losses of liquidimmersed and dry-type transformers; apply

waveform corrections, phase angle

corrections, and temperature corrections to

the measured data for no-load losses and load

losses; and ensure the quality assurance

measures for testing operations.

3.2 Deviations from NEMA TP 2. For the

purpose of this DOE test procedure the

following deviations from TP 2 shall apply:

(i) Section 7 of TP 2, Demonstration of

Compliance, shall not be a part of the DOE

test procedure.

(ii) The reference conditions for reporting

the data under the DOE test procedure shall

be: 20 °C ± 10 °C for no-load losses of liquidimmersed distribution transformers and drytype distribution transformers; 55 °C for load

losses of liquid-immersed distribution

transformers operated at 50% of the rated

load; 75 °C for load losses of medium-voltage

dry-type transformers operated at 50% of the

rated load; and 75 °C for load losses of lowvoltage dry-type transformers operated at

35% of the rated load.

(iii) The exceptions listed in item 4 of the

Scope of TP 2 do not apply to the DOE test

procedure.

3.3 The total losses of liquid-immersed

distribution transformers, at the specified

reference conditions, shall be computed

according to clause 5.2.3 of TP 2.

3.4 The total losses of the dry-type

distribution transformers, at the specified

reference conditions, shall be computed data

according to clause 5.3.3 of TP 2.

3.5 Compute the efficiency values of

liquid-immersed distribution transformers

and dry-type distribution transformers at the

specified reference conditions using the

algorithm provided in clause 5.4 of TP 2.

[FR Doc. 98-30140 Filed 11-10-98; 8:45 am]

BILLING CODE 6450-01-P

 EE-TP-98-550 COMMENT 12A