U.S. DEPARTMENT OF ENERGY

PUBLIC HEARING ON ENERGY EFFICIENCY TEST PROCED

DISTRIBUTION TRANSFORMERS

LOCATION:

DATE AND TIME:

Purpose of Hearing:

PRELIMINARY AGENDA

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 AND 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

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those 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?

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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 definedfor distribution transformers. Based on NEMA's comments, in the

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proposed rule the Department defined "basic model " to mean all units of a given

type of distribution transformer manufactured by a single manufacturer and which

have a comparable nominal output power (kVA) rating, operate within the same

voltage range, have the same insulation type (liquid-immersed or dry type), and

have the same number of phases (single or three).

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

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

definition too broad?

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

who sell some high efficiency models may under-design other transformers within

that basic model (while still meeting a possible standard for the average efficiency of

that basic model)? If so, what should be done to prevent this practice?

E. Sam 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.

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® 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 Statutory Requirements

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. ADJOURNMENT

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