12A

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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW G UIDE

TABLE OF CONTENTS

A. ENGINEERING ANALYSIS

................................ ................................ .............................. 1
B. MARKET QUESTIONNAIRE

................................ ................................ ......................... 24
C. MANUF ACTURER IMPACTS

................................ ................................ ........................ 2512A

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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW G UIDE

A. ENGINEERING ANALYSIS

The purpose of the engineering analysis is to estimate the relationship between the manufacturer’s selling price of a transformer and its corresponding efficiency rating. This relationship serves as the basis for the subsequent cost

- benefit calculations for individual consumers, manufacturers, and the nation

.

Th e engineering analysis considers 13 design lines of distribution transformers that group together kVA ratings based on similar principles of design and construction. The 13 design lines differentiate the distribution transformers by insulation type (liqui d

- immersed or dry

- type), number of phases (single or three), the primary voltage (low

- voltage or medium

- voltage for dry

types) and primary insulation levels (with three different BIL s for medium

- voltage dry

- types).

DOE then selected one unit with a given kVA rating from each of the engineering design lines for study in the engineering analysis. DOE will then extrapolate the results from these representative units to the other kVA ratings in its engineering design line. The design lines and representative units chosen for this engineering analysis are the same ones used in the October 2007 Final Rule for distribution transformers and the 2004 ANOPR (in the case of low

- voltage dry

- types). 1

A.1 Design Options

DOE considers different design options to increase transformer efficiency in order to analyze the relationship between a manufacturer’s selling price and the efficiency of a distribution
transformer. M easures taken to reduce no

- load losses typically increase load losses , and vice

versa

. The following tab le presents design options that DOE is currently considering and their typical impacts on transformer efficiency and cost :

1 These publications are available online: http://www1.eere.energy.gov/buildings/appliance_standards/commercial/distribution_transformers.html

.12A

- 2 No

- load
losses Load

losses Cost

impact
To decrease no

- load losses
Use lower

- loss core materials Lower No change* Higher
Decrease flux density by: (a) Increasing core cross

- sectional area (CSA) (b) Decreasing volts per turn Lower
Lower Higher

Higher Higher

Higher Decrease flux path length by decreasing conductor CSA Lower Higher Lower Use 120 ̊ symmetry in three

- phase cores** Lower Lower TBD
To decrease load losses
Use lower

- loss conductor material No change Lower Higher Decrease current density by increasing conductor CSA Higher Lower Higher Decrease current path length by: (a) Decreasing core CSA (b) Increasing volts per turn Higher Higher Lower

Lower Lower

Lower Use 120 ̊ symmetry in three

- phase cores** Lower Lower TBD

* Amorphous

- core materials would result in higher load losses.
** First commercialized by Hexaformer AB of Sweden . This is discussed in more detail in the followin g sections.

A .1

- 1 Design Options: Please comment on the design options listed above. Are any of the design options impractical to manufacture? Are there other design options that DOE should consider to improve transformer efficiency?

Design Options Screened Out

During the previous rulemaking on distribution transformers, DOE screened out several design options based on: 1) technological feasibility, 2) practicability to manufacture, install, and service, 3) adverse impacts on product utility or produ ct availability, and 4) adverse impacts on health or safety. The following table lists the design options that DOE screened out in the previous rulemaking on distribution transformers. DOE believes that each of these design options should be excluded fro m the current rulemaking.

Design Option Excluded Screening Criteria

Silver as a Conductor Material Practicability to manufacture, install, and service

High

- Temperature Superconductors Technological feasibility; Practicability to manufacture, install, and service Amorphous Core Material in Stacked Core Configuration Technological feasibility; Practicability to manufacture, install, and service Carbon Composite Materials for Heat
Removal Technological feasibility

High

- Temperature Insulating Material Technological feasibility

Solid

- State (Power Electronics) Technology Technological feasibility12A

- 3

A .1

- 2 Design Options Screened Out: Should any of these design options be considered in the current rulemaking? Are there any additional design options that should be excluded from the analysis that are not listed in the table above?

Less

- Flammable Liquid

- Immersed Transformers

In the 20 07 final rule, DOE determined that less

- flammable liquid

- immersed (LFLI) transformers ( i

. e ., those with fluids of a higher flash point than mineral oil ) should be analyzed in the same product class as liquid

- immersed transformers that use mineral oil. DOE concluded that the design of a transformer (i.e., dry

- type or liquid

- immersed) was a performance

- related feature that affects the energy efficiency of the equipment, and thus dry

- type and liquid

immersed were analyzed as different product classes. Furthe rmore, DOE found that LFLI transformers could meet the same efficiency levels as any of the liquid

- immersed transformers that use mineral oil. As a result, DOE did not separately analyze LFLI transformers, but relied on the analysis for the mineral oil li quid

- immersed transformers.

A .1

- 3 Less

- Flammable Liquid

- Immersed: Please comment on this decision and whether LFLI transformers should be analyzed differently in this rulemaking. Are there any distribution transformer applications that require a dry

- type transformer (i.e., where a n LFLI transformer would not be suitable)? Can LFLI transformers achieve the same maximum efficiency rating as liquid

- immersed transformers that use mineral oil? Why or why not?

Symmetric Core Designs

DOE is aware of a design concept for three

- phase transformers that utilizes 120 ̊ symmetry and continuously wound cores. These symmetric core designs, such as the Hexaformer ® design created by Hexaformer AB, have several benefits over a traditional transformer design,
inc luding: lower losses, lower inrush current, lower weight, and lower external magnetic field. Chalmers University in Sweden has conducted a study on symmetric core designs and provided an overview of the design and insights into modeling the technology. 2 DOE understands that symmetric core designs represent a significant shift from current industry practice for manufacturing distribution transformers.

A .1

- 4 Symmetric Core Designs: Please comment on any e xperience your company has with symmetric core desig ns. Would any barriers exist to implementing this type of technology on a large scale?

2 Available online: http://www.hexaformer.com/ExternaDokument/chalmers_report1.pdf

.12A

- 4

A.2 Test Procedure

DOE published its test procedure for distribution transformers in 2006. Since then,
manufacturers and other stakeholders have raised issues on several points in the test procedure.

Dual/Multiple

- Voltage Winding Configurations

The test procedure states that the manufacturer must determine the basic model’s efficiency either at the voltage at which the highest losses occur or at each voltage at which the transformer is rated to operate. This provision was implemented to address dual

- or multiple

- voltage transformers, which have d ifferent losses for each of their winding configurations (in series or in parallel)

. Some manufacturers have stated that this requirement effectively raised the previous efficiency standards published by DOE in 2007. This is because the standards were se t based on analysis using the series winding configuration at the higher voltage level , which tends to be
more efficient

.

A. 2

- 1 Dual/Multiple

- Voltage Winding Configurations: Has this requirement made it more difficult to meet the current efficiency stand ards? Approximately what percentage of distribution transformers are operated in a parallel winding configuration at the lower voltage level? What is the typical difference in losses between the different winding configurations? Do efficiency improvemen ts in the series winding configuration always result in efficiency improvements in the parallel winding configuration?

Reference Loading and Peak Loading

The test procedure specifies that losses be measured at 50 percent of the rated load for liquid

immersed and medium

- voltage dry

- type transformers, and 35 percent of the rated load for low

voltage dry

- type transformers. These load factors are based on root

- mean

- square loading data
for the nation. Some manufacturers have stated that different load factors should be analyzed based on load growth projected from electric vehicles and smart grid initiatives. Additionally, some manufacturers have stated that DOE should analyze a peak load scenario.

A. 2

- 2 Reference Loading and Peak Loading: Please comment on the appropriateness of the 50 percent and 35 percent load factors used in the test procedure. Please provide any data available on projected load growth, including timeline. Do manuf acturers optimize transformer designs at these load factor s or other load factors?

A.2

- 3 Other Issues with the Test Procedure: Are there any other issues or concerns with the current test procedure that DOE should be aware of?12A

- 5

A.3 Liquid

- Immersed Engineer ing Analysis

Design Lines and Representative Units

The following table represents the five design lines and representative units DOE is analyzing for liquid

- immer sed distribution transformers. Design Line # of Phases KVA Range Primary BIL Primary Taps, Full Capacity Representative Unit for Design
Lines

1 1 10

- 167 30

- 150

kV Four 2.5% taps,
two above and two
below nominal 50 kVA, 65  ̊C, single

- phase, 60Hz,

14400 V primary, 240/120 V secondary, rectangular tank

2 1 10

- 167 30

- 150

kV Four 2.5% taps,
two above and two
below nominal 25 kVA, 65  ̊C, single

- phase, 60Hz,

14400 V primary, 120/240 V secondary, round tank

3 1 250

- 833 30

- 150

kV Four 2.5% taps,
two above and two
below nominal 500 kVA, 65  ̊C, single

- phase,

60Hz, 14400 V primary, 277 V secondary

4 3 15

- 500 30

- 150

kV Four 2.5% taps,
two above and two
below nominal 150 kVA, 65  ̊C, three

- phase, 60Hz,
12470Y/7200 V primary,
208Y/120 V secondary

5 3 750

- 2500 95

- 150

kV Four 2.5% taps,
two above and two
below nominal 1500 kVA, 65  ̊C, three

- phase,

60Hz, 24940GrdY/14400 V primary, 408Y/277 V secondary

A .3

- 1 Liquid

- Immersed Design Lines : Please comment on the appropriateness of the design lines and representative units chosen for the liquid

- immersed distribution transformers. What percentage of total shipments does each representative unit constitute within its design line? Should any other representative units be selected?

Design Option Combinations

For each representative unit, DOE is considering several design option combinations that characterize a range of efficien cy levels for distribution transformers. This range spans from the efficiency level requirements set forth in DOE’s 2007 final rule to the maximum technologically available level. While many combinations of design option s are possible to achieve these efficiency levels, DOE tried to select the most common designs in the industry.

A .3

- 2 Previously Unanalyzed Core Steels : DOE is examining some new core steels that were not considered in the previous rulemaking. These include an M2 and M3 steel with Lite12A

- 6

Carlite insulation and an M5 core steel. Are there any manufacturing or engineering
issues that DOE should be aware of w hen analyzing these core steels? Does your company produce distribution transformers using these core steels?

A.3

- 3 Amorphous Cores: DOE is examining amorphous cores as a design option for the liquid

- immersed design lines. Each of these amorphous desi gns utilizes a distributed gap wound core, which DOE assumes is purchased from an amorphous core manufacturer. Does your company currently manufacture liquid

- immersed transformers with an amorphous core? If so, for what kVA range are amorphous cores used ? Does your company purchase amorphous ribbon or a finished amorphous core? If a finished amorphous core is purchased, who supplies the cores for your company? Are there any design issues associated with using an amorphous core in a liquid

- immersed tran sformer?

A .3

- 4 Liquid

- Immersed Design Option Combinations : In the tables below, p lease comment on the appropriateness of the design option combinations selected to characterize the range of possible efficiencies for each representative unit. Are these de sign option combinations similar to transformers that you r company sell s ? Are there any additional designs that should be considered?12A

- 7

Design Line 1 : 50kVA, 65 ̊ C, single

- phase, 60 Hz, 14400V primary, 240/120V secondary, rectangular tank
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M5 DG Core Cu Al Shell
2 M4 DG Core Cu Al Shell
3 M3 DG Core Cu Al Shell

4 M3

– Lite
Carlite DG Core Cu Al Shell

5 M2 DG Core Cu Al Shell

6 M2

– Lite
Carlite DG Core Cu Al Shell

7 ZDMH DG Core Cu Cu Shell

8 SA1

- Amorphous DG Core Cu Cu Shell

Design Line 2: 25kVA, 65  ̊ C, single

- phase, 60 Hz, 14400V primary, 120/240V secondary,
round tank
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M6 DG Core Cu Al Shell
2 M5 DG Core Cu Al Shell
3 M4 DG Core Cu Al Shell
4 M3 DG Core Cu Al Shell

5 M3

– Lite
Carlite DG Core Cu Al Shell

6 M2 DG Core Cu Al Shell

7 M2

– Lite
Carlite DG Core Cu Al Shell

8 ZDMH DG Core Cu Cu Shell

9 SA1

- Amorphous DG Core Cu Cu Core12A

- 8

Design Line 3: 500kVA, 65  ̊ C, single

- phase, 60 Hz, 14400V primary, 277V secondary
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M5 DG Core Cu Al Shell
2 M4 DG Core Cu Al Shell
3 M3 DG Core Cu Al Shell

4 M3

– Lite
Carlite DG Core Cu Al Shell

5 M2 DG Core Cu Al Shell

6 M2

– Lite
Carlite DG Core Cu Al Shell

7 ZDMH DG Core Cu Cu Shell

8 SA1

- Amorphous DG Core Cu Cu Shell

Design Line 4: 150kVA, 65  ̊ C, three

- phase, 60 Hz, 12470Y/7200V primary, 208Y/120V secondary
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M5 DG Core Cu Al 5

– Legged
2 M4 DG Core Cu Al 5

– Legged
3 M3 DG Core Cu Al 5

– Legged

4 M3

– Lite
Carlite DG Core Cu Al 5

– Legged

5 M2 DG Core Cu Al 5

– Legged

6 M2

– Lite
Carlite DG Core Cu Al 5

– Legged

7 ZDMH DG Core Cu Cu 5

– Legged

8 SA1

- Amorphous DG Core Cu Cu 5

– Legged12A

- 9

Design Line 5: 1500kVA, 65  ̊ C , three

- phase, 60 Hz, 24940GrdY/14400V primary, 408Y/277V secondary
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M5 DG Core Cu Al 5

– Legged
2 M4 DG Core Cu Al 5

– Legged
3 M3 DG Core Cu Al 5

– Legged

4 M3

– Lite
Carlite DG Core Cu Al 5

– Legged

5 M2 DG Core Cu Al 5

– Legged

6 M2

– Lite
Carlite DG Core Cu Al 5

– Legged

7 ZDMH DG Core Cu Cu 5

– Legged

8 SA1

- Amorphous DG Core Cu Cu 5

– Legged12A

- 10

A.4 Low

- Voltage Dry

- Type Engineering Analysis

Design Lines and Representative Units

The following table represents the three design lines and representative units DOE is analyzing
for low

- voltage dry

- type distribution transformers. Design Line # of Phases KVA Range Primary BIL Primary Taps, Full Capacity Representative Unit for Design
Lines

6 1 15

- 333 10 kV Universal* 25kVA, 150 ̊C, single

- phase, 60Hz, 480V primary, 120Y/240V secondary, 10kV BIL

7 3 15

- 150 10 kV Universal* 75kVA, 150 ̊C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL

8 3 225

- 1000 10 kV Universal* 300kVA, 150 ̊C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL * Universal Taps = 2 above and 4 below 2.5%

A .4

- 1 Low

- Voltage Dry

- Type Design Lines : Please comment on the appropriateness of the design lines and representative units chosen for the low

- voltage dry

- type distribution
transformers. What percentage of total shipments does each representative unit constitute within its design line? Should any other representative units be selected?

Design Option Combinations

For each representativ e unit, DOE is considering several design option combinations that characterize a range of efficiency levels for distribution transformers. This range spans from the efficiency level requirements set forth in the Energy Policy Act of 2005 to the maximum

t echnologically available level. While many combinations of design options are possible to achieve these efficiency levels, DOE tried to select the most common designs in the industry.

A .4

- 2 Previously Unanalyzed Core Steels: DOE is examining some new core steels that were not considered in the previous rulemaking. These include an M12 and M2 core steel. Are there any manufacturing or engineering issues that DOE should be aware of when analyzing these core steels? Does you r company produce distribution transformers using
these core steels?12A

- 11

A .4

- 3 Amorphous Cores: DOE is examining amorphous cores as a design option for the low

voltage dry

- type design lines. Each of these amorphous designs utilizes a distributed gap
wound core, which DOE assumes is purchased from an amorphous core manufacturer. Does your company currently manufacture low

- voltage dry

- type transformers with an amorphous core? If so, for what kVA range are amorphous cores used? Does your company purchase am orphous ribbon or a finished amorphous core? If a finished amorphous core is purchased, who supplies the cores for your company? Are there any design issues associated with using an amorphous core in a low

- voltage dry

- type transformer?

A .4

- 4 Core Type: DOE plans to examine designs for low

- voltage dry

- type transformers using
either a stacked butt

- lap core or a stacked full

- miter core. What core types does your

company use in its low

- voltage dry

- type transformer designs? Are there any manufacturing iss ues that DOE should be aware of when considering the different core types?

A .4

- 5 Low

- Voltage Dry

- Type Design Option Combinations : In the tables below, p lease comment on the appropriateness of the design option combinations selected to
characterize the ra nge of possible efficiencies for each representative unit. Are these design option combinations similar to transformers that your company sells? Are there any additional designs that should be considered?12A

- 12

Design Line 6: 25kVA, 150  ̊ C , single

- phase, 60 Hz, 480V primary, 120Y/240V secondary,
10kV BIL
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M12 Stacked

Butt

- Lap Al Al Core

2 M6 Stacked

Butt

- Lap Al Al Core

3 M5 Stacked

Butt

- Lap Al Al Core

4 M4 Stacked

Butt

- Lap Al Al Core

5 M3 Stacked

Butt

- Lap Al Al Core

6 M3 Stacked

Butt

- Lap Al Al Shell

7 H

- 0 DR Stacked

Butt

- Lap Cu Cu Core

8 SA1

- Amorphous DG Core Cu Cu Core

Design Line 7: 75kVA, 150  ̊ C , three

- phase, 60 Hz, 480V primary, 208Y/120V secondary,
10kV BIL
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M12 Stacked

Butt

- Lap Al Al 3

– Legged

2 M6 Stacked

Full Miter Al Al 3

– Legged

3 M6 Stacked

Full Miter Cu Cu 3

– Legged

4 M4 Stacked

Full Miter Al Al 3

– Legged

5 M3 Stacked

Full Miter Al Al 3

– Legged

6 H

- 0 DR Stacked

Full Miter Cu Cu 3

– Legged

7 SA1

- Amorphous DG Core Cu Cu 3

– Legged

8 SA1

- Amorphous DG Core Cu Cu 5

– Legged12A

- 13

Design Line 8: 300kVA, 150  ̊ C , three

- phase, 60 Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M6 Stacked

Butt

- Lap Al Cu 3

– Legged

2 M6 Stacked

Full Miter Al Cu 3

– Legged

3 M5 Stacked

Butt

- Lap Al Cu 3

– Legged

4 M4 Stacked

Butt

- Lap Cu Cu 3

– Legged

5 M4 Stacked

Full Miter Cu Cu 3

– Legged

6 M3 Stacked

Full Miter Cu Al 3

– Legged

7 H

- 0 DR Stacked

Full Miter Al Cu 3

– Legged

8 SA1

- Amorphous DG Core Cu Cu 3

– Legged

9 SA1

- Amorphous DG Core Cu Cu 5

– Legged12A

- 14

A.5 Medium

- Voltage Dry

- Type Engineering Analysis

Design Lines and Representative Units

The following table represents the five design lines and representative units DOE is analyzing for
medium

- voltage dry

- type distribution transformers. Design Line # of Phases KVA Range Primary BIL Primary Taps, Full Capacity Representative Unit for Design
Lines

9 3 15

- 500 20

- 45

kV Four 2.5% taps,
two above and two
below nominal 300kVA, 150 ̊C, three

- phase, 60Hz,

4160V Delta primary, 480Y/277V secondary, 45kV BIL

10 3 750

- 2500 20

- 45
kV Four 2.5% taps, two above and two
below nominal 1500kVA, 150 ̊C, three

- phase,

60Hz, 4160V primary, 480Y/277V secondary, 45kV BIL

11 3 15

- 500 46

- 95
kV Four 2.5% taps,
two above and two
below nominal 300kVA, 150 ̊C, three

- phase, 60Hz,

12470V primary, 480Y/277V
secondar y, 95kV BIL

12 3 750

- 2500 46

- 95
kV Four 2.5% taps,
two above and two
below nominal 1500kVA, 150 ̊C, three

- phase,

60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL

13 3 225

- 2500 96

- 150
kV Four 2.5% taps,
two above and two
below nominal 2000kVA, 150 ̊C, three

- phase,

60Hz, 12470V primary, 480Y/277V secondary, 125kV BIL

A .5

- 1 Medium

- Voltage Dry

- Type Design Lines : Please comment on the appropriateness of the design lines and representative units chosen for the medium

- voltage dry

- type distribution transform ers. What percentage of total shipments does each representative unit constitute within its design line? Should any other representative units be selected?

Design Option Combinations

For each representative unit, DOE is considering several design option combinations that characterize a range of efficiency levels for distribution transformers. This range spans from the efficiency level requirements set forth in DOE’s 2007 final rule to the maximum technologically available level. While many combinations of design options are possible to achieve these efficiency levels, DOE tried to select the most common designs in the industry.

A .5

- 2 Previously Unanalyzed Core Steel: DOE is examining a new core steel (M2) that w as not considered in the previous rulemaking. Does your company currently manufacture any medium

- voltage dry

- type transformers using M2 core steel? Are there any12A

- 15

manufacturing or engineering issues that DOE should be aware of when analyzing th is
core steel ?

A.5

- 3 Amorphous Cores: DOE is examining amorphous cores as a design option for the
medium

- voltage dry

- type design lines. Each of these amorphous designs utilizes a distributed gap wound core, which DOE assumes is purchased from an amorphous core manufacturer. Does your company currently manufacture medium

- voltage dry

- type transformers with an amorphous core? If so, for what kVA range are amorphous cores used? Does your company purchase amorphous ribbon or a finished amorphous core? If a finished amorphous core is purchased, who supplies the cores for your company? Are there any design issues associated wi th using an amorphous core in a medium

- voltage dry

- type transformer?

A .5

- 4 Core Type: DOE plans to examine designs for medium

- voltage dry

- type transformers using either a stacked butt

- lap core or a stacked full

- miter core. What core types does

your com pany use in its medium

- voltage dry

- type transformer designs? Are there any manufacturing issues that DOE should be aware of when considering the different core types?

A .5

- 5 Medium

- Voltage Dry

- Type Design Option Combinations : In the tables below, p lease comment on the appropriateness of the design option combinations selected to characterize the range of possible efficiencies for each representative unit. Are these design option combinations similar to transformers that your company sells? Are there

an y additional designs that should be considered?12A

- 16

Design Line 9 : 300kVA, 150  ̊ C , three

- phase, 60 Hz, 4160V Delta primary, 480Y/277V secondary, 45kV BIL
Core
Material Core

Type Conductor

HV Conductor

LV Design

Type Comments

1 M6 Stacked

Full Miter Cu Cu 3

– Legged

2 M5 Stacked

Full Miter Al Al 3

– Legged

3 M4 Stacked

Full Miter Al Al 3

– Legged

4 M3 Stacked

Full Miter Cu Al 3

– Legged

5 M2 Stacked

Butt

- Lap Al Al 3

– Legged

6 H

- 0 DR Stacked

Full Miter Cu Cu 3

– Legged

7 SA1

- Amorphous DG Core Cu Cu 3

– Legged

Design Line 10: 1500kVA, 150  ̊ C , three

- phase, 60 Hz, 4160V primary, 480Y/277V secondary,
45kV BIL
Core
Material Core Type Conductor
HV Conductor

LV Design

Type Comments

1 M5 Stacked Cruc

.

Mitered Cu Al 3

– Legged

2 M4 Stacked Cruc

.

Mitered Cu Al 3

– Legged

3 M4 Stacked Cruc

.

Mitered Cu Cu 3

– Legged

4 M3 Stacked Cruc

.

Mitered Cu Cu 3

– Legged

5 H

- 0 DR Stacked Cruc

.

Mitered Cu Cu 3

– Legged12A

- 17

Design Line 11: 300kVA, 150  ̊ C , three

- phase, 60 Hz, 12470V primary, 480Y/277V secondary,
95kV BIL
Core
Material Core Type Conductor
HV Conductor

LV Design

Type Comments

1 M6 Stacked Full

Miter Cu Cu 3

– Legged

2 M 5 Stacked Full

Miter Al Al 3

– Legged

3 M 4 Stacked Full

Miter Cu Al 3

– Legged

4 M 3 Stacked Full

Miter Cu Cu 3

– Legged

5 H

- 0 DR Stacked Full

Miter Cu Cu 3

– Legged

6 SA1

- Amorphous DG Core Cu Cu 5

– Legged

Design Line 12: 1500kVa, 150  ̊ C , three

- phase, 60 Hz, 12470V primary, 480Y/277V secondary,
95kV BIL
Core
Material Core Type Conductor
HV Conductor

LV Design

Type Comments

1 M6 Stacked Cruc

.

Mitered Al Al 3

– Legged

2 M5 Stacked Cruc

.

Mitered Al Al 3

– Legged

3 M4 Stacked Cruc

.

Mitered Cu Al 3

– Legged

4 M4 Stacked Cruc

.

Mitered Cu Cu 3

– Legged

5 M3 Stacked Cruc

.

Mitered Cu Cu 3

– Legged

6 H

- 0 DR Stacked Cruc

.

Mitered Cu Cu 3

– Legged12A

- 18

Design Line 13: 2000kVA, 150  ̊ C , three

- phase, 60 Hz, 12470V primary, 480Y/277V secondary, 125kV BIL
Core
Material Core Type Conductor
HV Conductor

LV Design

Type Comments

1 M6 Stacked Cruc

.

Mitered Al Al 3

- Legged

2 M6 Stacked Cruc

.

Mitered Cu Cu 3

- Legged

3 M5 Stacked Cruc

.

Mitered Cu Al 3

- Legged

4 M4 Stacked Cruc

.

Mitered Cu Al 3

- Legged

5 M4 Stacked Cruc

.

Mitered Cu Cu 3

- Legged

6 M3 Stacked Cruc

.

Mitered Cu Cu 3

- Legged

7 H

- 0 DR Stacked Cruc

.

Mitered Cu Cu 3

- Legged12A

- 19

A.6 Material Prices, Markups , and Labor Rates

Material Prices

DOE recognizes that material prices make up a significant portion of total cost for manufacturing distribution transformers. The following table contain s DOE’s estimates for material prices for
distribution transformers in each of the past five years. The prices listed do not include any markups for scrap , handling, factory overhead, non

- production costs , or profit , but rather represent the price a manufacturer would pay for the material. All prices are listed in historic dollars (e.g., $2007 for year 2007, and $2009 for year 2009).

A .6

- 1 Material Prices : Please comment on the appropriateness of each material price. Does your company pay a similar price for these materials? If not, what price does your company pay? Would a five

- year average of each material price be a fair characterization of its cost? If not, what time period should be used?12A

- 20

Material Units 20 10 200 9 200 8 200 7 200 6 Comments M36 core steel (26 gauge) $/lb 0.69 0.69 0.69 0.84 0.60 M19 core steel (26 gauge) $/lb 0.95 0.85 0.98 0.95 0.73
M12 core steel $/lb 1.08 1.13 1.31 1.24 1.10
M6 core steel $/lb 1.52 1.95 1.87 1.78 1.50
M5 core steel $/lb 1.58 1.96 1.93 1.84 1.55
M4 core steel $/lb 1.74 2.02 1.98 1.89 1.59
M3 core steel $/lb 1.90 2.05 2.10 2.00 1.62 M3 core steel (Lite Carlite) $/lb 1.98
M2 core steel $/lb 2.02 2.1 0 2.22 2.12 1.66 M2 core steel (Lite Carlite) $/lb 2.13

H

- O DR core steel (laser scribed) $/lb 2.06 2.10 2.28 2.14 1.76

ZDMH (mechanically

scribed core steel) $/lb 2.05 2.09 2.27 2.16 1.75

SA1 (amorphous) finished core, volume production $/lb 2.38 2.27 2.86

Copper wire, formvar,
round #10

- 20 $/lb 4.72 4.01 5.69 5.45 4.99

Copper wire, enameled,
round #7

- 10 flattened $/lb 4.95 3.98 5.56 5.33 5.28

Copper wire, enameled, rectangular sizes $/lb 5.26 4.97 5.21 5.01 4.45

Copper wire, rectangular 0.1 x 0.2, Nomex wrapped $/lb 4.87 4.10 5.83 5.68 5.20

Aluminum wire, formvar,
round #9

- 17 * $/lb 5.94 4.17 4.47 4.05 1.68

Aluminum wire, formvar,
round #7

- 10 * $/lb 4.39 4.19 4.50 4.12 1.71

Aluminum wire, rectangular 0.1 x 0.2, Nomex wrapped $/lb 2.73 1.92 2.05 1.93 1.91

Copper strip, thickness

range 0.02

- 0.045 $/lb 4.55 3.40 4.90 5.28 4.74

Copper strip, thickness range 0.030

- 0.060 $/lb 4.25 2.61 3.66 3.40 3.05

Aluminum strip, thickness range 0.02

- 0.045 $/lb 1.67 1.80 2.15 2.18 2.01

Aluminum strip, thickness range 0.045

- 0.080 $/lb 1.72 1.89 2.28 2.30 2.12

Kraft insulating paper with
diamond adhesive $/lb 1.81 1.80 1.78 1.75 1.66

Nomex insulation $/lb 24.50 24.50 22.80 19.89 17.07 Cequin insulation $/lb 5.53 5.07 4.78 4.93 8.50
Mineral oil $/gal 3.78 3.20 3.50 2.30 1.82 Impregnation $/gal 22.55 22.50 21.45 21.35 21.35 Winding combs $/lb 12.34 12.58 12.10 11.52 7.56
Tank/Enclosure Steel $/lb 0.56 0.46 0.60 0.58 0.50 * DOE notes that the price quotations it received for aluminum wire, formvar, round #9

- 17 and #7

- 10 seem high
relative to other materials and relative to the price in 2006. DOE asks for input on these material prices.12A

- 21

Markups

DOE applies markups to all material prices to reflect a manufacturer’s internal markups. DOE’s analysis assumes that manufacturers will purchas e a prefabricated amorphous core rather than purchasing raw material and construct ing a core from it. For this reason, DOE applies different markups to the amorphous core price compared to the other raw material prices for scrap factor and factory overhea d :

Scrap and handling factor: Applies to variable materials (e.g., core steel, windings,
insulation , etc. ). It accounts for the handling of material (loading into assembly or winding equipment) and the scrap material that cannot be used in the production of a finished transformer (e.g., lengths of wire too short to wind, trimmed core steel).

o Amorphous scrap factor: Accounts for breakage of prefabricated cores. Since amorphous cores are considered to be prefabricated, the regular scrap and handling factor does not apply, but a factor for breakage is considered.

o Mitered scrap factor: A higher scrap markup applies to steel used in full

- mitered cores. This markup is higher than the regular scrap and handling factor to account
for material cut from the notch in the yoke.

Factory overhead: Includes all the indirect costs associated with production, indirect
materials and energy use (e.g., annealing furnace), taxes, and insurance. This markup is only applied to the direct material production costs.

Amorphous factory overhead: Reduces the factory overhead markup used for raw materials to adjust for a prefabricated core . Only accounts for portions of factory overhead that apply to a prefabricated core.

Non

- production: R eflects costs including selling, general and administrative, R&D, interest payments, and profit factor. This markup is applied to the sum of direct mat erial, direct labor, and factory overhead.

A .6

- 2 Markups : Please comment on the appropriateness of the following markups. Do they represent the markups your company uses? If not, what markups are used by your company? Would the amount of these markups differ greatly for any particular design type? Would your company reduce the markup allocation for prefabricated cores, such as was done for amorphous cores?12A

- 22

Type of Markup * Markup [%] Comments Scrap and handling Regular scrap and
h andling 2.5

Amorphous scrap 1.5 Mitered scrap 4.0 Factory overhead Regular Factory
Overhead 12.5

Amorphous Factory
Overhead 6.3

Non

- production Regular non

- production 25.0

* Only one markup from each type of markup (scrap and handling, factory overhead, and non

production) is used for a given material. For example, the amorphous markup would be 1.015 x 1.063 x 1.25 = 1.348 (a 34.8 percent markup).

Labor Rate

DOE developed a n estimate for the cost of labor by applying markups to a base hourly labor rate to obtain a fully

- burdened labor rate. The base hourly labor rate was taken from Census data for NAICS code 3353111 “Power and distribution transformers, except parts” produc tion workers hours and wages. DOE then applied the following markups to estimat e the fully

- burdened labor

rate:

Indirect Production: Ac counts for the cost of production managers, quality control, and other indirect costs associated with production.

Over head: Includes co mmissions, dismissal pay, bonuses, vacation, sick leave, and social security contributions.

Fringe: Includes pensi on contributions, group insurance premiums, workers compensation, etc.

Assembly Labor Up

- Time: Accounts for the time that workers are not assembling product and/or reworking unsatisfactory units.

Non

- Production: Reflects costs including selling, general and administrative, R&D, interest payments, and profit factor. This markup is applied to the s um of direct material, direct labor, and factory overhead.12A

- 23

A .6

- 3 Labor Rate : Please comment on the appropriateness of the following labor rate markups. Does the fully

- burdened cost of labor represent your company’s fully

- burdened labor rate for production? If not, what is your company’s fully

- burdened labor rate, and which markups would you adjust?

Type of Markup Markup [%] Rate per hour

[$] Comments

Labor cost per hour $ 16.80
Indirect Production 33 % $ 22.35
Overhead 30 % $ 29.05 Fringe 24 % $ 36.03 Assembly Labor Up

- time 43 % $ 51.52

Non

- Production 25 % $ 64

. 40 Fully

- Burdened Cost of Labor $ 64

. 4012A

- 24

B. MARKET QUESTIONNAIRE

B

- 1 Market Share : What is the estimated market share of your company in the U.S. distribution transformer industry? In the liquid

- immersed, low

- voltage dry

- type, or medium

- voltage dry

- type market?

B

- 2 Domestic Manufacturing : What percent of distribution transformers sold in the U.S. are imported? What percent are manufactured domestically?

B

- 3 Delivery Channels: Who are the different intermediaries in the deliv ery channel between

your company and the ultimate end users for liquid

- immersed, low

- voltage dry

- type and
medium

- voltage dry

- type transformers?

B

- 4 Transformer Purchasing Behavior: Has c usto mer purchasing behavior changed in recent years, particularly in light of minimum efficiency sta ndards? Do cu st o mers still

pur chase predominantly based o n the lowest total owning cost for liquid

- immersed transformers and based on lowest first cost for dry

- type transformers ? What is the estimated percentage of customers who provide no

- load and load loss A and B values when purcha sing a new distribution transformer? What, in $/W, are the average specified

no

- load and load loss values?

% that specify No

- load loss (A) $/Watt Load loss (B)

$/Watt

Liquid

- immersed

Low

- voltage dry

- type ( < 600V)

Medium

- voltage dry

- type ( > 600V)

B

- 5 Sales of Transformers by Efficiency: What is the range of efficiencies for distribution transformers that your company sells? What percent of transformers sold are at the minimum efficiency standard established by the previous DOE rulemaking? Does your company offer a premium efficiency di stribution transformer , such as NEMA Premium
rated transformers for low

- voltage, dry

- type ? If so, what is its rated efficiency level at the kVA values used for DOE’s analysis?12A

- 25

C. MANUFACTURER IMPACTS

During the Preliminary Analysis phase of the rulemaking, DOE attempts to characterize distribution transformer manufacturers on a high level . This includes any relevant issues they may face resulting from increased efficiency standards. During the next phase of the rulemaking, the Notice of Proposed Rulemaking (NOPR) phase, DOE will perform an in

- depth analysis of the impacts on manufacturers.

C

- 1 Key Issues : What are the key issues for your company regarding any new energy
conservation standards for distribution transformers ?

C

- 2 Your Company’s Niches : Wh at are your product lines, niches and relative strengths in
the distribution transformers market?

C

- 3 Company Demographics : Where are your production facilities located, and what is the product mix manufactured at each location? Does the bulk of your c ompany’s
distribution transformer production occur domestically? What are your employment levels at these facilities? Are there any manufacturing or employment issues that DOE should be aware of in terms of producing more energy efficient transformers at your facility/facilities?

C

- 4 Materials and Material Prices : Are the materials necessary to build more energy

efficient distribution transformers readily available? How would material price changes affect your company’s business?

C

- 5 Impacts : Generally how would new efficiency standards on distribution transformers impact your customer mix, distribution channels and corresponding profit margins? Please explain.

C

- 6 Capital Investment : What level of capital expenditure and product conversi on costs would you anticipate you may need to make at higher standard levels? Please describe these capital investments and provide your best estimate of their respective magnitudes.

C

- 7 Small Businesses : To what extent will new standards require small businesses to acquire new equipment or cause manufacturing process changes that could destabilize their
business?

C

- 8 Facility Impacts : How would the imposition of new energy efficiency standards affect capacity utilization and manufacturing assets at your domestic production facilities?12A

- 26

Would a new standard result in stranded capital assets? Would any facilities be closed or downsized? Added or upgraded?

C

- 9 Depreciation : What are the depreciation periods for the three types of capital expenditures (building, equipment, and tooling )?

C

- 10 Compliance Costs : What specific annual compliance costs (after the effective date) do you anticipate incurring to comply with standa rds? Will they vary with standard level? Would these costs vary over time?

C

- 11 Exports and Competition : Would new standards change your projected export sales? Would new standards have an impact on the portion of the domestic market served by foreig n competition?

C

- 12 Industry Consolidation : In the absence of new standards, do you expect any industry
consolidation?

C

- 13 Competitive Positioning : How would new standards affect your ability to compete? Could new standards disproportionately advan ce or harm the competitive positions of
some firms?

C

- 14 IP Issues : Are there concerns over intellectual property, patent licensing or other related
issue s ?

C

- 15 Impacts on Consumers : Could new standards result in disproportionate economic or performance penalties for particular consumer/user subgroups? Beyond price and energy efficiency, could new standards result in products that will be more or less desirable to
consumers due to c hanges in product functionality, utility or other features?

C

- 16 Regulatory Burden : Are there recent or impending regulations on distribution
transformers or related products that do or will impose a cumulative burden on the industry? What is the total expected impact of those other regulations?

C

- 17 Federal Tax Incentives : Are there any federal tax credits or other incentive programs to encourage you t o produce energy efficient distribution transformers?