U.S. DEPARTMENT OF ENERGY PUB LIC HEARIN G ON ENERGY EFFICIENCY TEST PROCED

DISTRIBUTION TRANSFORMERS

LOCATION:

DATE AND TIME:

Pu rpose of H earing: PRELIMINARY AGE NDA

FORRESTAL BUILDING 1000 INDEPENDENCE AVENUE , SW WASHINGTON, DC 20585 WEDNESDAY, JANUARY 6, 1999 9:00 A.M. - 5:00 P.M.
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.

1. WELCOMING REMARKS AN D INTRODUCTION

U. 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.

III. OPENING STATEMENTS Speakers will be invited to make brief summary statements concerning the proposed rule, identifying the specific topics they intend to address later in the hearing. Rebuttals and/or comments or questionsfrom the audience or DOE are not expected at this point.

IV. TOPICS For each topic, the Department will invite speakers to make a brief summary . presentation of their issues concerning the specific topic. DOE may ask questions after each prepared statement and at other points during discussions. At the end of all prepared statements on each topic, the Department will encourage an open dialogue by
1 Enclosure 1those in attendance on the issues raised and alternatives proposed for each topic. In

addition , for the purpose of clarifying the issue raised, DOE may entertain a discussion of an alternative to the proposed rule . Each topic will be dealt with separately.

A. Proposed Test Procedures 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 ANSIIIEEE 057.12.91); or 2) a standard being developed by the National Electric Manufacturers Association (NEIVIA TP 2). Based on its review of the comments received, the Departments intends to adopt one of these test procedures in the final rule. The Department is particularly interested in receiving comments on the following: ® Which of the two approaches the Department should adopt , and why? ® Do the proposed test procedures adequately measure distribution transformer efficiency? ® Are the stated reference conditions acceptable and provide for repeatable and reproduceable results? ® Should additional standards be incorporated by reference?

B. dequacy of TP 2 to Meet the Requirements of Users 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 all 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: Have all 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?

2 Enclosure I

### C. 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. In addition, for the test procedures rulemaking, the Department has made an effort to identify and exclude transformers that cannot accurately be tested by the proposed test procedures, such as transformers with frequencies other than 60 Hz (+/- 5 Hz) and converter and rectifier transformers with more than two windings. However, the Department will not exclude distribution transformers from the test procedures just because they may have lower efficiencies than their counterparts. The Department is particularly interested in receiving comments on the following: ® Has the Department accurately characterized 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 provide sufficient evidence explaining why these transformers cannot accurately be tested. Is there a likelihood that loopholes may result from the proposed distribution transformer definition and its exclusions?

D. of a 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
3 Enclosure 1proposed 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?

E. S am in Plan for Compliance In order to reduce the testing burden on manufacturers, the Department typically permits. the use a statistically meaningful sampling procedure for selecting test specimens. 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 favorable 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; consequently, under the proposed sampling plan, these manufacturers 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 provide justification as to 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.
4 Enclosure 1® If you have an alternative sampling approach , please provide evidence of the way 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.

F. General Statuto ry R equir emen ts The proposed rule was reviewed under general statutory requirements, including environmental impact, impact on small entities , effect on States, information collection and recordkeeping and use of commercial standards. The Department is interested in receiving any comments on this portion of the notice of proposed rulemaking.

V. AD JO URNME NT

5 Enclosure 1