From: Gaytan Cavazos, Carlos (GE Energy, Non‐GE) [mailto:Carlos.Gaytan@ge.com]  

Sent: Friday, September 23, 2011 6:47 PM

To: Richard Parker; ahoffman@publicpower.org; pkumar@publicpower.org; Aaron Meyers; Andrew

Delaski; Art Rosenfeld; Bob Saint; Brian Coffey; Bruce R Hirsch; Bruce Smith; Caitlin Johnson; Charlie

Drexler; Chris Bolduc; Chuck Simmons; Dan Cohen; Daniel Young; Dave Millure;

Eric.Petersen@aksteel.com; Gary Fernstrom; Greg Coulter; Greg Rosenquist; James Lass; Jeremiah

Freeman (CONTR); Jerry Corkran; Jerry Hodge; Jerry Schoen; Jim Creevy; Joanna Mauer; John Caskey;

John Cymbalsky; jrossetti@mlgw.org; kcoughlin@lbl.gov; Ken Winder; Mahesh P. Sampat; Meg Waltner;

Michael Hyland; Michael Rivest; Paul Ryan; Phil Hopkinson; Raymond Polinski; Rick Anderson; Rob

Greeson; Robert Berman; Robin Roy; Scott Beck; Steve Nadel; Steve Rosenstock; Tim Ballo; Tom

Eckman; Wes Patterson; Zhimei Luo

Subject: RE: MV Working Group: Follow‐up to Sept 15/16 Mtg

Dear Mr. Parker and Colleagues:

I just noted that a portion of my comments was missing, and for that reason I want to re‐submit them.

You can delete my earlier message.  

1) Comments to TSDs and Cost Assumptions for 8/23/2011 Designs and LCCs:

We were expecting to have the requested back up data with comments relative to changes in the TSD’s,

design approach, and key costs related to the 8/23/2011 Engineering Data and LCC etc. results.  At this

time, we have seen nothing on the DOE DT website related to this important review information.  When

can we expect to see this additional information?

2)            Global Demand, Supply, Capacity, and Price Sensitivity Analyses:

As the possible EL’s move up the efficiency range from today’s standard EL0, the significance of

premium core materials such as ZDMH and Amorphous to designs and resulting LCC outcomes increases

rapidly.  For many ratings, the DOE optimum designs already use ZDMH and quickly transition to

Amorphous as efficiency increases.  The differential between these premium core material designs and

those that use the better grades of silicon steel readily available from multiple sources also becomes

significant essentially making the economics of M3 designs non‐competitive.  Thus, the higher EL level

results are dependent on the price and availability assumptions of ZDMH (or other HiB materials)  and

Amorphous.  During the first negotiation session, the participants requested that DOE conduct price

sensitivity analyses on these materials which have been and are already somewhat limited in supply

globally.  We are very concerned that with a rule forcing the use of these materials, the price

assumptions used in the DOE models could be invalidated by market price changes in a high demand

situation.  Thus, we respectfully again request a price sensitivity analysis and report and ask that DOE

commit to a date to provide this, preferably sufficiently ahead of the next negotiation meeting to allow

time for participants to review and comment on the results.

3)            Efficiency Requirements for Dual/Multiple‐Voltage Secondaries:

DOE should align its requirements with those of IEEE standards (C57.12.00 for liquid‐filled, NEMA ST20‐

1992: 3.3 for low voltage), requiring testing in the “as shipped” condition.  For units with multiple

(series‐parallel) low voltage ratings, the efficiency standard should be based on the highest voltage

(series) connection, which matches the IEEE standard and industry practice.  To do otherwise would be
counter to the current industry standards and practices of testing and shipping multiple low voltage

rated units at the higher voltage (series) rating.  For example, the most popular low voltage rating for

single‐phase US Liquid‐Filled DT’s is the 120/240 volt rating consisting of two half‐capacity low voltage

windings connected internally in series.  IEEE standards require such units to be connected and tested at

the higher 240 volt (series) connection.  For 240/480 volt ratings, the series connection would be at 480

volts.  Our recommendation is that DOE match this requirement for efficiency standards compliance.   

4) Dual/Multiple‐Voltage Transformers with Varying Basic Impulse Levels:

DOE should align its requirements with those of IEEE standards (C57.12.00 for liquid‐filled, NEMA ST20‐

1992: 3.3 for low voltage), requiring testing in the “as shipped” condition.  For units with two or more

high voltage ratings, the efficiency standard should be based on the highest voltage (highest BIL)

connection, which matches the IEEE standard and industry practice.  To do otherwise would be counter

to the current standards and industry practices of testing and shipping D/V units at the higher voltage

rating.  For example, the most popular D/V rating for US LFDT’s would be the 12470GrdY/7200 x  

24940GrdY/14400 rating (95 kV BIL x 125 kV BIL).  IEEE standards require such units to be connected and

tested at the higher voltage rating – 24940GrdY/14400.  Our recommendation is that DOE match this

requirement for efficiency standards compliance.

5) Multiple kVA Ratings:

In addition to multiple‐voltage secondaries (ES.3.1) and multiple Basic Impulse Levels (ES.3.2)

distribution transformers also have multiple KVA ratings with natural cooling, forced cooling, or a

combination of both natural and forced cooling.  The current regulation does not address the situation

of multiple KVA ratings.  

Distribution transformers can have multiple natural cooled KVA ratings ‐ typically ONAN/ONAN, 55C/65C

for liquid, AA/AA, 80C/150C for dry‐type.  For such transformers the KVA specification is 12% higher at

the 65C rating for liquid‐filled and 30% higher at the 150C rating for dry‐types. The regulation should

clearly state the efficiency regulation applies only to the KVA at the base thermal rating (55C or 80C).

Distribution transformers can also have a combination of natural and forced cooled KVA ratings ‐ 

typically ONAN/ONAF, 65C for liquid, AA/FA, 150C for dry‐type.  For such transformers the KVA

specification is typically 15% higher at the ONAF rating for liquid‐filled and 30% higher at the FA rating

for dry‐types. The regulation should clearly state the efficiency regulation applies only to the KVA at the

base (lowest) thermal rating (ONAN or AA).  

Distribution transformers can also have multiple combinations of natural and forced cooled KVA ratings

‐ typically ONAN/ONAF/ONAF, 55C/65C/65C for liquid, AA/FA/FA, 80C/150C/150C for dry‐type.  For such

transformers the KVA specification is typically 29% higher at the ONAF/65C rating for liquid‐filled and

77% higher at the top FA rating for dry‐types. The regulation should clearly state the efficiency

regulation applies only to the KVA at the base thermal rating (ONAN or AA) which is the lowest kVA

rating.

Best Regards

Carlos Gaytan
Manager of Engineering

Prolec GE ‐ Distribution Transformers

From: Richard Parker [mailto:richardparkerdc@gmail.com]  

Sent: Wednesday, September 21, 2011 5:06 PM

To: ahoffman@publicpower.org; pkumar@publicpower.org; Aaron Meyers; Andrew Delaski; Art

Rosenfeld; Bob Saint; Brian Coffey; Bruce R Hirsch; Bruce Smith; Caitlin Johnson; Charlie Drexler; Chris

Bolduc; Chuck Simmons; Dan Cohen; Daniel Young; Dave Millure; Eric.Petersen@aksteel.com; Gary

Fernstrom; Gaytan Cavazos, Carlos (GE Energy, Non‐GE); Greg Coulter; Greg Rosenquist; James Lass;

Jeremiah Freeman (CONTR); Jerry Corkran; Jerry Hodge; Jerry Schoen; Jim Creevy; Joanna Mauer; John

Caskey; John Cymbalsky; jrossetti@mlgw.org; kcoughlin@lbl.gov; Ken Winder; Mahesh P. Sampat; Meg

Waltner; Michael Hyland; Michael Rivest; Paul Ryan; Phil Hopkinson; Raymond Polinski; Richard Parker;

Rick Anderson; Rob Greeson; Robert Berman; Robin Roy; Scott Beck; Steve Nadel; Steve Rosenstock; Tim

Ballo; Tom Eckman; Wes Patterson; Zhimei Luo

Subject: MV Working Group: Follow‐up to Sept 15/16 Mtg

Dear Colleagues,

A few items to follow‐up for meeting of Sept. 15‐16 which I thought was quite productive.

Ground Rules

Attached for your review are the Ground Rules discussed and approved at our Sept. 15‐16 meeting.  

After we adjourned one member asked for more time to allow in‐house counsel to review the

document.  This is reasonable so I am re‐opening the comment period for the ground rules to allow

further comment, with a request that you do your internal review and send along any comments by

close of business on Monday, Sept. 26, so that we can discuss any proposed modifications online and

hopefully finalize the rules either before or at the beginning of the next meeting.  Remember that the

agreement allows modifications so you are never barred from seeking changes to the agreement that

you deem necessary or helpful.   

Clarification of the Sept. 23 "deadline" for comments on the Engineering and LCC/NPV Analysis

At the meeting I asked that Members review the revised Engineering and LCC/PBP/NPV Analysis now

posted on the DOE website and submit their comments/questions/critique by Sept. 23 so that

DOE/Navigant/LBL can respond in a timely way with clarifications, answers and/or further analysis.  A

question has arisen whether this will act as hard and fast bar to methodological critiques later on.  The

answer is no.  The deadline is an informal one.  It does not mean that additional concerns cannot be

raised later.  It means that we hope that you will carefully examine the analysis and get us your

comments and concerns by no later than Sept. 23 (and preferably sooner) so that Navigant/LBL can

respond and we can discuss how best to proceed prior to the next meeting.  As a practical matter, the

later your concerns are put on the table the more difficult it will be to accommodate them analytically.   

As you consider your comments, please keep in mind that data are limited and resources are limited.

This proceeding is already far along analytically, and Navigant/LBL cannot at this stage undertake an

exhaustive new investigation that entails gathering and analyzing large amounts of new data.  

CSLs

Concerns were expressed at the meeting about changes in the CSLs and ELs between the April and the

August analyses.   My understanding is that absent compelling reason to change, which we don't
foresee, the CSL's that appear in the August analysis will not be altered going forward.   

Miscellaneous

I will send along transcript, minutes, and a firm schedule for future meetings as soon as they are

available, which I hope will be very soon.

All best,

Richard