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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

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WORKSHOP ON TEST PROCEDURES FOR

DISTRIBUTION TRANSFORMERS

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Tuesday, February 10, 1998

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The workshop was held in Room 1E-245,

Department of Energy, 1000 Independence Avenue, S.W.,

Washington, D.C., at 9:00 a.m., Kathi Epping,

Chairperson, presiding.

PRESENT:

KATHI EPPING, Chairperson

ANTHONY BALDUCCI, Facilitator

EDWARD LEVY

OSKARS PETERSONS

MICHAEL McCABE

ALSO PRESENT:

RANDY BARNES

JAMES BOHLK

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ALSO PRESENT (Continued):

JOHN BORST

LAKE COULSON

JOHN GAUTHIER

PHIL HOPKINSON

DON KLINE

GENE MOREHART

WES PATTERSON

DAVID ROLLING

KEN STRICKLETT

DAVE WIEGAND

ALAN WILKS

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C-O-N-T-E-N-T-S

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PAGE

Opening Remarks and Introductions 6

Overview of Rulemaking Process, Michael McCabe 18

Overview from NEMA 35

Discussion of Adoption of Consensus Standards 40

NEMA Position on Consensus Standards 42

Discussion of the Basic Model 51

NEMA Position on Basic Model 54

Discussion of Coverage of Transformers 60

Discussion of Sampling Plan 80

NEMA Position on Sampling Plan 94

Discussion of the Measure of Energy Consumption 112

NEMA Position on Measure of Energy Consumption 113

Discussion of Burden Imposed on Industry by

Additional Testing and Data Processing 118

NEMA Position on Additional Testing and

Data Processing 118

Discussion of Reference Temperatures 134

NEMA Position on Reference Temperature 135

Discussion of Measurement Corrections '137

NEMA Position on Measurement Corrections 138

Discussion of Quality Assurance 152

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C-O-N-T-E-N-T-S (Continued)

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PAGE

NEMA Position on Quality Assurance 153

Discussion of Length of Comment Period 159

NEMA Position on Proposed Comment Period 162

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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:01 a.m.)

3 MR. BALDUCCI: Good morning, everyone. My

4 name is Anthony Balducci, and I'll be facilitating

5 today ' s meeting.

6 The following people are with the office

7 of Codes and Standards, as well as myself: Kathi

8 Epping and Michael McCabe, who's behind Sandra, and

9 Brenda and Sandy.

10 One thing I wanted to just remind

11 everyone, if you have not signed in already or left a

12 business card, please do at the table.

13 Ed Levy with our General Counsel should be

14 here soon, and we also have Oscars Petersons with

15 NIST, who most of you already know.

16 On behalf of the Department of Energy, I

17 would like to thank all of you for taking the time to

18 participate in this workshop. The purpose of the

19 workshop is to discuss the draft test procedure for

20 distribution transformers and the issues surrounding

21

22 11 The department will consider the views

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presented in the comments submitted in formulating a

proposed rule for test procedures for distribution

transformers. We seek, the department, to gather

additional information on data on certain questions

and issues being considered by the department in its

development of this proposed rulemaking.

We do not expect to resolve all of the

questions, but do expect to gather data to guide us on

that. That's a very important point here. One of the

things we want to do today is identify issues. We

don't expect to answer all of those issues today.

It's going to be more of a data collection.

The department on January 12th sent a

letter to interested parties announcing this workshop

and provided a draft agenda, an issues paper, a draft

test procedure prepared by NIST for transformers.

Since the test procedure document was sent

out, NIST has made some changes to it. The changes,

I believe, are in the documents that were passed out

this morning, as well as the agenda for today's

meeting.

22 11 A public notice of the workshop was

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published in the Federal Register on January 20th of

this year, and anyone attending today's workshop or

anyone who submitted comments will be added to our

mailing list. We're revising our mailing list now.

What we're going to do is if you're attending the

workshop or you do submit comments, you will be added

to our mailing list for future mailings regarding

distribution transformers.

The comments received here today and

received at today's workshop will assist the

department in developing the proposed rule for

transformers.

Again, I'll just restate that I'm the

presiding officer and will facilitate the workshop.

I'll set the guidelines for conducting the workshop,

as well, as we go through this and provide other

pertinent information.

In approximately two weeks a complete

transcript will be available for inspection and

copying at the department's Freedom of Information

Room. It's right down the hall. It's 1E190.

Anyone wishing to purchase a copy of the

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transcript can see the court recorder at the end of

the workshop.

The purpose, again, of the workshop is to

discuss the draft test procedure for distribution

transformers and the issues surrounding it. The

objective is to gather views and information on the

draft test procedure for transformers before the

department -- before, that's important -- before the

department issues a notice of proposed rulemaking.

We will not be seeking to reach consensus

on the issues. We'll be trying to identify the issues

and gather information on them.

To provide the department with as much

pertinent information and as many views as can be

reasonably obtained and enable interested parties to

express their views, the workshop will be conducted in

accordance with the following procedures.

Kathi Epping will introduce and lead the

discussion on all the topics. NEMA has requested that

a five minute presentation be given before each topic,

which we have granted. Also NEMA has requested a five

minute overview before we get into each topic, which

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1 we have granted as well.

2 If there's anyone else who would like the

3 opportunity to speak, please see me, and we'll work

4 you in with regards to each topic, and all are invited

5 to participate in the discussions.

6 We'll begin with introductions after I

7 finish my opening comments. Then we'll have a

8 presentation by Michael McCabe. It'll be an overview

9 presentation of the process. NEMA will give a brief,

10 brief process. Dave who will be representing NEMA

11 will do that.

12 Then we'll go with an agenda review and

13 then proceed right into the discussion on each topic.

14 At the end of the workshop we'll have

15 closing remarks. One of the other things we also will

16 do is set a date for the comment period. We do not

17 have a date that the comment period closes yet. At

18 the end of the workshop, depending on how many issues

19 we get through and how much information we will need,

20 we'll try and set a date for that.

21 And prior to adjournment, we do ask that

22 you fill out an evaluation sheet, which will be passed

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out later in the workshop.

We'll take an hour break for lunch around

a convenient time near noon, which is on your own.

There's a snack floor one floor below us -- snack bar

one floor below us, which some of you already went to

for coffee. The cafeteria is on the second floor of

the West Building. If you need directions for that,

we can kind of set up a little train, and everybody

can hold hands and work their way over there.

Up the street there are also some

restaurants up at L'Enfant Plaza. That may take a

little bit more time. If you do elect to do that,

please remember that we want to take on hour.

We will expediate the workshop to be sure

of obtaining each participant's views, and if everyone

waits to be recognized, you will have a chance to

speak.

Please remember, and this is very

important for the court recorder and for the formal

transcript, when you do speak, introduce yourself,

your name, your company, and also you must speak into

the microphones so we can get it all on the record.

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Side conversations should be kept to a

minimum to avoid interrupting the presenter, whoever

is speaking. If you do need a private discussion,

please do take it outside the room.

Also, I apologize now. I may cut off some

debates if we get off on a tangent and we need to get

back on the agenda to cover some relevant topics. We

may cut them off. If we have time at the end, we can

come back to those discussions.

I encourage everyone to participate as

much as they can so that the department may get a full

spectrum of opinions on these topics.

We're scheduled to end by 4:30 today. We

do have the room till five o'clock if we need.

Topics which have not been completely

discussed by five, if you feel there's more input you

need, we may ask questions; you may have questions of

us. That's for the comment period. Feel free to

submit your comments by the end of the close of the

comment period, which we will discuss at the end.

All written comments and data submissions

will be available for public inspection at the DOE

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Freedom of Information Room, which is down the hall.

The phone number for that room is (202) 586-6020. The

comments should be addressed to Sandy Beall at the

Department of Energy, as noted in -- I'm getting

signals. I'm sorry. It should be addressed to Brenda

Edwards-Jones as indicated in the notice that was

published in January.

Ten copies of comments or data are

requested. If you're submitting data, please submit

ten copies.

The other thing we do request is if you

can submit those comments electronically as well, it

makes it easier for us to put in our files. We're

using Word Perfect 6.1.

No fax comments will be accepted because

it's tough for us to scan them.

Any person submitting information which he

or she believes to be confidential an exempt by law

from public disclosure should submit one complete copy

and ten copies from which information claimed to be

confidential has been deleted. So if you've got a

document that you feel you've got a paragraph or two

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confidential to your corporation or company, submit

ten full copies without that one, and then one copy

with the confidential marked "confidential."

In accordance with the procedures set

forth in 10 CFR 1004.11, the Department of Energy will

make its own determinations as to whether the

information shall be kept from public disclosure.

In keeping with the regulations for these

facilities, there is no smoking allowed in this room

or building. The restrooms are at each end of the

halls, if you need those. Phones are located in the

main lobby area.

Again, we appreciate your time and effort

you have taken in preparing for this workshop and are

pleased to receive your comments and opinion.

I would like to reiterate the purpose of

the workshop is to discuss the draft test procedure

for transformers and the issues surrounding it, not to

reach consensus necessarily on all those issues.

If you have not signed in, again, please

do, and at this time I would like to go around the

room for introductions. Why don't we start at the

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head table?

MR. LEVY: Ed Levy, Office of General

Counsel, DOE.

CHAIRPERSON EPPING: Kathi Epping. I am

the Program Manager in the Office of Codes and

Standards on distribution transformers.

MR. PETERSONS: Oskars Petersons, National

Institute of Standards and Technology.

MR. BALDUCCI : This is where it's going to

get a little difficult. I would like if everyone

could get up and speak into the mic. It's going to

take a little time, but it's worthwhile.

MR. COULSON: Lake Coulson, National

Electrical Manufacturers Association.

MR. ROLLING: David Rolling, Cooper Power

Systems.

MR. PATTERSON: West Patterson, ABB.

MR. BOSIGER: John Bosiger, ABE, South

Boston, Virginia.

MR. BORST: John Borst, ABB, Power T&D.

MR. HENRY: George Henry, Central Moloney

22 II Transformer.

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MR. GAUTHIER: John Gauthier, NEMA.

MR. WILLIAMS: Matt Williams, NEMA.

MR. STAHARA: Ron Stahara, Central

Moloney, Pine Bluff Arkansas.

MS. JENSEN: Barbara Jensen, EHV Wideman.

MR. GUICE: Dennis Guice, Southern

Transformer Company.

MR. KLINE: Don Kline, Southern

Transformer Company.

MR. WILKS: Alan Wilks, ERMCO.

MR. HARTFIELD: Tony Hartfield, ERMCO.

MR. MILLIMAN: Dennis Milliman, Niagara

Transformer.

Electric.

Navy.

MR. MOREHART: Gene Morehart, Acme

MR. PELTZ: John Peltz, Atlantic Division,

MR. GLENN: Peyton Glenn, Atlantic

Division, Navy.

MR. HALL: Ken Hall, the Edison Electric

Institute.

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MR. SIQUEIROS: Carlos Siqueiros, Cutler

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Hammer.

MR. HASTINGS: Chuck Hastings, Square D

Company.

MR. HOPKINSON: Phil Hopkinson, Square D

Company.

MR. SCHWARTZ: Wes Schwartz, Square D

Company, Osh Kosh, Wisconsin.

MR. HODGE: Gerry Hodge, Howard

Industries.

MR. EPPING: Patrick Epping, Techtran.

MR. HOLLOMON: Brad Hollomon, Pacific

Northwest Laboratory.

MR. BRUSH: Ned Brush, consultant to the

Copper Development Association.

MS. WHELAN: Valerie Whelan, Natural

Resources, Canada.

MR. WIEGAND: Dave Wiegand, Transformer

Engineering Services, from London, Ontario.

MR. VON HOLLE: Tony Von Holle, ARMCO.

MR. SHUGARS: John Shugars, Lawrence

Berkeley National Labs, here for the Federal Energy

Management Program Office.

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MR. LINK: Dick Link, General Electric.

MR. BOHLK: Jim Bohlk, United States

Department of Agriculture, Rural Utilities Service.

MR. AGUDO: Mike Agudo, RUS.

MR. SMITH: Henry Smith, PEMCO

Corporation.

MR. BUSH: Carl Bush, PEMCO Corporation.

MR. HYLAND: Mike Hyland, American Public

Power Association.

MR. STRICKLETT: Ken Stricklett from

National Institute of Standards and Technology.

MR. RABA: Jim Raba, Department of Energy,

Office of Codes and Standards.

MR. ADAMS: Carl Adams, Office of Codes

and Standards, DOE.

MR. KUMAR: B.J. Kumar, Energetics.

MR. NASSERI: Cyrus Nasseri, Department of

Energy, Office of Codes and Standards.

MR. BARNES: Randy Barnes, Oak Ridge

National Laboratory, Oak Ridge, Tennessee.

MR. McCABE: Good morning. Michael

McCabe. I'm Direct of the Office of Codes and

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Standards.

MR. BALDUCCI: Thank you very much,

everyone, for the musical chairs exercise we just went

through.

One other thing before Michael gives his

presentation. We do have some extra copies of the

reports that were distributed. One is the process

rule, the issue paper that was mailed out, the NIST

draft NOPR, as well as the determination of the NOPR.

At this time I'd like to turn it over to

Michael McCabe. He's going to give a short

presentation on the overview process.

MR. McCABE: Thank you, Anthony.

Good morning.

PARTICIPANTS: Good morning.

MR. McCABE: Welcome to Washington. It's

a little bit drier here now than what it has been,

something which I can certain appreciate since I've

been in the middle of a six and a half week process to

get a new roof, but I've been rather dry.

But the process which we're embarking on

is one that we've had -- I've been undergoing within

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1 the Department of Energy for some 25 years with what

2 started as the appliance standards program.

3 But the 1992 legislation, which many of

4 you were a part of, directed the department to review

5 a number of products, including electric distribution

6 transformers, to determine whether or not the

7 department should proceed with a rulemaking program.

8 As many of you are aware, October this

9 past year we issued a determination that standards

10 appear -- and I will stress that it's "appear" -- to

11 be technically feasible, economically justified, and

12 would result in a significant conservation of energy.

13 This is the first step in a process that we don't know

14 how long it's going to last.

15 So in stressing "appear," that is to try

16 to stress that, that once the process has been kicked

17 off as it has been now, the next step is to go into a

18 rulemaking process for test procedures.

19 I will spend a little bit of time talking

20 about the standards and our overall process because of

21 the many questions which I, Kathi, and Oskars and

22 others have received on the standards issue, but I'd

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like to reiterate that this is not a standards

rulemaking.

If somebody were to ask me whether or not

DOE, in fact, will issue a final rule on standards or

when the department will issue a final rule on

standards, I'm going to have to say I don't know when

or if we would do that because the results of the test

procedure rulemaking and any subsequent standards

rulemaking will determine whether and if there will be

a standards rulemaking.

But I'd like to deviate briefly from the

topic of today's workshop and address some of the

points on standards that have been raised. I would

like also to entertain any questions at the end of my

presentation. If there's something that is confusing

that I may make a remark in the middle, please feel

free to raise your hand and ask me to clarify the

statement that I've made.

The department has gone through a process

which lasted approximately a year to develop a new

process for conducting standards rulemakings. We will

apply that process to transformers. This is part of

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that process in many respects.

The key element to the process, in my

view, is to share information early and often with

interested and affected parties so as to make sure

that, one, we have the correct information; two, we're

interpreting it correctly; and, three, for us to get

some direction as to where to go in the next step and

for you to know where we're headed.

So this workshop, much of what we're doing

throughout the entire process, whether or not it's the

test procedure, labeling, or even a standards

rulemaking such as what we have a workshop next month

on, the standards analysis for standards for

residential clothes washers. So a major element to

the new process is this exchange.

Kathi and Oskars, for example, are

available to all. We have encouraged the NEMA staff

to use Oskars and Kathi as a resource, for example, in

the development of TP-2, and some of the feedback that

I have gotten is that that has worked well, but it's

also raised some questions.

Oskars, for example, is not a DOE staff

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person. Kathi is not the Assistant Secretary for

Energy Efficiency and Renewable Energy. So often

Oskars, Kathi, and I will make statements about what

we expect may or will happen. Those are staff

opinions. They're not the final DOE opinion.

More often than not they're on target, but

if there are questions, remember that we're staff. We

don't make policy. We just do the analysis, and we

make recommendations and provide information to the

policy makers.

But, again, we're going to strive to have

as much dialogue with you as we can throughout the

process so that there are not any surprises.

Again, standards rulemaking, if there is

one, will be initiated after the test procedure

rulemaking. One of the elements to the process

improvement is that we recognize that we need to have

the metric in place for measuring efficiency, whether

or not it's how you measure the efficiency of a

clothes washer, central air conditioner, or

transformer. You cannot set a standard, a minimum

efficiency standard, unless you know what the test

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procedure is, what the metric is, and how to measure

that efficiency.

I can remember back in the early days of

the program when we were working with two legislative

deadlines to establish energy efficiency targets for

residential equipment, and at the same time we were to

set test procedures for those products. The deadlines

in the legislation were the same, and we ended up just

blowing -- the whole process just blew up in our face

because as manufacturers were trying to give us

information on how efficient a product is for a

central air conditioner, if you're talking about

steady state efficiency, are you talking about an

outdoor temperature of 92 degrees, 88, 85, 95 degrees?

All of it gives you -- if you test at different

temperatures, you're going to get different results.

So we have committed that in order to have

an effective, valid standards rulemaking for any

product, that we will get the test procedures in place

before we go into the standards rulemaking.

And once the test procedures are

developed, the standards rulemakings for any product

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are kicked off through the prioritization process,

where we, the department, will identify through an

open process what the priorities are.

That process invites public input, where

we will share preliminary information prior to

establishing the process. In that preliminary

information, we will have staff recommend what the

staff opinion is as to what the priorities should be.

We're going to be seeking public comment

on that. We've gone through two priority setting

processes already, and this is an annual process. In

both cases we receive comment on the priorities that

resulted in us changing or the department came out

with a -- the final priorities were different than

what the staff initial recommendation was.

It is important in the priority setting

process that if you agree with the staff

recommendation you say so. If you disagree with it,

say so as well because there are parties who have

different agendas, and if we only get comments from

one side saying, "This is what we'd like to see. We'd

like to see you change the priorities for this reason

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or the other, " and everybody else is silent, you know,

we respond to where the noise is in many cases.

The priority process, the prioritization

is based primarily on the potential energy savings.

We also look at other factors that we develop, such as

the economic and the environmental impacts of such

standards.

We may look at a particular level of

efficiency as far as what its potential savings is,

but generally we will look at a range because, you

know, there are certainly for some products where you

can go with a maximum standard, very stringent

standard, but for economic reasons, impact on

consumers and the like, that level would not be

reasonable.

So we will look principally at energy

savings, but we will try to balance it with other

factors.

If a product is a priority product for

standards and we go into rulemaking, having a chemical

engineering background, which is just an advanced

22 11 plumbing degree, I kind of like this image -

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(Laughter.)

MR. McCABE: -- because to me it just

looks like a whirlpool. Otherwise some of the water

hydraulics. It just looks like a toilet.

But the process is -- and some of the

graphics really don't show up here -- and that's the

standard setting process, and we've tried to set it up

such as with a -- like each level is a finer mesh

screen.

So we'll go through a process to get

stakeholder input in order to develop the regulatory

agenda, which will be published -- the priorities

which will be published in the regulatory agenda.

We will then go through a screening

process for the standards rulemaking where we will

screen out efficiency designs which have health,

safety, utility impacts that do not warrant

consideration in the standards rulemaking in order to

narrow the range of options that are being considered

for standards such that when we come out with an

advanced notice of proposed rulemaking, with the

analysis that accompanies it, that it's our hope that

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with the engineering and economic analysis that

accompanies an advanced notice that the parties such

as yourself and manufacturers, efficiency advocates,

states, utilities, and the whole host of those who are

interested in the rulemakings whether or not it's for

motors, transformers, clothes washers, dishwashers,

central air conditioners; any of the products that are

covered by this program, that they could take a look

at this preliminary analysis and essentially take

control of the process from there on and come to an

agreement as to whether or not a standard is warranted

at a particular level and make that recommendation to

the department before we go out with the proposed rule

and then the final rule.

So we're hoping to provide information

early that will aid in some of the -- in the process

to reach a final conclusion so that you can start to

guide that conclusion.

I think there was a question.

MR. HOPKINSON: Yes, Michael, the question

I had is on the economic impact --

CHAIRPERSON EPPING: Phil, go to the

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microphone, please.

MR. HOPKINSON: I'm sorry. Phil Hopkinson

from Square D.

Michael, I'm sorry, but the economic

impact, could you comment? I don't see anyplace else

in the presentation that you have what measures you're

using to reflect the economics. Can you comment on a

period, like five-year returns, three-year return, and

so on?

MR. McCABE: In the standards analysis, as

part of the advanced notice of proposed rulemaking, at

that point we expect to have a -- our preliminary

analysis will include preliminary energy savings

forecast, preliminary life cycle cost analysis, and

price efficiency curves for the various products.

What we will strive to do before that

point, before we do the analysis for the proposed

rule, is to sit down with all the parties to define

what are the appropriate metrics to examine in the

economic analysis, in the engineering analysis, so

that it will give you an opportunity to help to

structure the analysis.

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But we're looking at both impact on the

customers, the impact on the nation, the impact on

manufacturers, and the specifics as to what those

impacts are, and we're going to look to you to help us

to find those, and the "you" is you, the manufacturers

of a residential product or in this case transformers.

If we go into the priority setting and

transformers ends up being a priority product, we will

then come back and look to those who are involved with

this product to help us structure the analysis.

So there are many other questions as far

as specifically what are we going to do, how is it

going to be structured that I can't answer right now

because it depends upon, one, whether or not it's a

priority product, and then we're going to work

together to try to structure that analysis.

MR. PATTERSON: Wes Patterson, ABB.

Where in that chart are we right now?

MR. McCABE: We're not even on this chart

now.

(Laughter.)

22 11 MR. McCABE: Les, you're a good straight

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1 man because you're setting up.

2 The purpose of today's workshop is not

3 standards.

4 (Laughter.)

5 PARTICIPANT: That was plain.

6 MR. McCABE: Yeah, he was expensive. It

7 cost me.

8 The purpose of today's workshop is test

9 procedures. We're looking for your comment, your

10 input on the issues that have been identified and the

11 material that has been sent out.

12 We're also interested in your suggestions

13 as to other test procedures. For example, Oskars --

14 I think I had mentioned that Oskars has been working

15 with NEMA's staff and NEMA members to support their

16 activities. We recognize, I recognize the activities

17 that you have underway in TP-2.

18 It is our position, our goal in the

19 department and this program, but it's also the

20 administration's goal, is to use public standards,

21 consensus based standards, wherever possible.

22 We have for our program a number of

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consensus standards that we have adopted. Some we

have incorporated entirely by reference in our

regulations. We look to do that wherever possible.

Recognize that you're working on TP-2. We

look to support that activity, and we will adopt any

consensus standard that meets our needs and

objectives. Where it does not completely meet our

needs, we will adopt that portion that does and then

supplement with the balance from our work, but we will

try to share that information with you early so that

you know the direction that we're headed and what our

needs are so that we can work together and hopefully

incorporate any consensus standard in its entirety

with a minimum amount of input from us.

Again, the process that we're looking at

and the three principal blocks in this program, the

determination notice has been completed, and we're now

in the middle block in test procedures.

Questions about the standards analysis,

how we're going to structure it, I don't know. You

probably have a better idea than I do. I can recite

what we're doing for the residential products. I can

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1 recite what we're doing for the legislation . When we

2 start getting down to the specifics as to what would

3 be appropriate for one product or another, that's

4 where we have to work together.

5 The test procedures are used for rating

6 appliances , and I will apologize that we often use

7 appliances as a catch- all to cover everything. The

8 title of the program is actually the Consumer Products

9 Program - - Energy Conservation Program for Consumer

10 Products Other Than Automobiles , and I would not try

11 to describe an electric motor, a ballast, a

12 transformer as a consumer product. Now , maybe a

13 toilet is , but that's one of our covered products, as

14 well.

15 But if I use "appliances " or anybody uses

16 "appliances ," we're using it generically to cover the

17 products that are covered.

18 Products that are covered , for example,

19 the residential products, we have test procedures in

20 place. Ratings that are used in print media,

21 wherever , those ratings for efficiency must be based

22 on the test procedure.

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The test procedure is also the basis for

labeling. The Federal Trade Commission labels most of

the residential products. We are in the process of

developing labeling rules for a number of the

commercial products.

The test procedures are also the basis for

standards. I raise this now because it's important

that when we're developing test procedures, where

there is some appreciation for standards and where

there is a link, it is the fact that the test

procedures are the foundation for any standards. You

have to have a well structured, well thought out test

procedure.

So that if the test procedure is flawed,

the standard is going to be flawed as well. The

labeling is going to be flawed. Any representations

are going to be flawed.

So it's important to do the homework, and

that's why we're focusing on test procedures first,

and then we'll look and deal with other issues that

follow.

22 II We touched on the first two bullets, that

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we're going to be working with all parties, the

manufacturers, colleagues north of the border, though

I'd have to say that the U.S. women's hockey team is

going to kick butt, Valerie.

(Laughter.)

MR. McCABE: Our goal is to have a

proposed rule on test procedures by this summer.

Given where you are, and I expect some comments on TP2, Kathi and Oskars will be available to work

together.

I'm particularly concerned about this

since we're already beginning to develop ideas about

the test procedure. That's the document that was

shared with you, and from a legal perspective, if you

don't have TP-2 in place, for example -- and I'm kind

of dancing a little bit and Ed will help me if I have

-- if you don't have TP-2 in place by the time we

issue our proposed rule, we're not going to propose to

incorporate TP-2 because it just isn't there. It

doesn't exist.

So any proposed rule that we come out

with, it has to be based on either something that' s --

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if we're proposing to adopt something, it's there. So

it's important that if you want us to consider TP-2

and have that included in the proposed rule, then

there's an awful lot of work that needs to be done,

and we would be willing to help you wherever we can.

We expect a f inal rule in the summer of

'99, and with that I think I've gone well beyond my

time, answered some questions, and I hope that there

aren't any further questions. If there are, I will

try to answer them.

I also expect to be here much of the day

so that I'll be available, and I wish everybody the

best, and I appreciate your participation.

Thank you.

MR. BALDUCCI: Thank you, Michael.

Now we'll have a brief overview of NEMA's

comments from Dave Rolling.

Dave, do you need the --

MR. ROLLING: Yeah, I'll go over to where

Mike was standing.

MR. BALDUCCI: I don't know if you need

the projector or not.

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MR. ROLLING: No

These are going to be brief. My name is

David Rolling, and I'm the Chairman of the NEMA

Transformer Section of our Equipment Division within

NEMA.

And on behalf of the largest trade

association in the United States, representing the

interests of the electric industry manufacturers, the

National Electric Manufacturers Association, NEMA, I

want to thank you for the opportunity to participate

in these important discussions.

NEMA's Transformer Products Section,

consisting of 22 member companies, is but one of the

many sections that address generation, transmission,

distribution, control, and end use of electrical

products manufactured by over 575 member companies.

NEMA's Transformer Products Section

represents about 65 percent of the domestic U.S.

shipments in the transformer industry.

NEMA members have reviewed both the Oak

Ridge report and the positive determination notice of

October 22nd. We want to compliment the DOE and Oak

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Ridge for assembling very competent folks in putting

together those reports, and we want to compliment the

quality of those reports.

We note, however, that this does not mean

we're in full agreement with everything, with all

aspects of those statements. For example, in the

determination notice, the definition of distribution

transformers was expanded down to a quarter of a kVA.

We disagree with that, and there are other points we

disagree with.

Also, we would like to reaffirm NEMA's

basic principles regarding energy efficiency

standards. We believe that energy efficiency is a

national concern and should be driven by market

forces. Industry should be proactive in establishing

voluntary efficiency standards, performance standards,

test procedures, and measurement tolerances.

Manufacturers should provide consumers

with accurate and standardized information about

energy efficiency performance that is based upon

voluntary consensus standards.

We look forward to participating in

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today's workshop and for the mutual exchange of

dialogue between all stakeholders. For many of the

items listed in today's workshop notice or agenda, a

representative from the Transformer Section of NEMA

will offer a NEMA response.

In some cases we will not have an industry

position or response and will be seeking further

clarification or seeking definition of terms on a

particular topic. For example, there were some terms

used in DOE's proposed sampling plans, such as SFE,

that were not clear to us.

In those instances, it will be helpful for

DOE to define those terms to facilitate better

understanding among workshop participants.

Thank you.

MR. BALDUCCI: Thank you, Dave.

Before we begin, I just want to do a quick

agenda review just to kind of get everyone up to speed

of where we are and where we're going.

We've already had our opening remarks.

Our rulemaking process, we're right here right now.

With regards to topics, the first topic we'll be

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discussing, and Kathi, as I said before, will be

leading the discussion on these, the issue of adopting

consensus standards.

The next topic would be on basic models,

and sampling plan, the measure of energy consumption,

then the possible potential burden on industry. We

had a little technical problem with the pen right

there.

Reference temperatures, measurement

corrections, and quality assurance. That's all in the

final agenda that was passed out today, if you follow

the numbers.

Then at the end, again, like I said, we'll

have some next steps, what we expect from you and what

you should expect from us, some closing remarks, and

in those closing remarks, we'll be discussing a date

for the close of the comment period. So try and keep

that in mind as we go through this.

Finally, we'll have an evaluation and then

an adjournment.

With what, any questions, additions or

deletions from the agenda?

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(No response.)

MR. BALDUCCI: Seeing none, I will turn it

over to Kathi, and we'll jump right into the topics,

which the first one is the question of adopting

consensus standards.

CHAIRPERSON EPPING: Hi. I'm Kathi

Epping, and I'd like to talk a little bit about the

consensus standards.

DOE would like to incorporate the existing

national consensus standards to the extent possible.

However, the consensus standards do not address issues

that are normally included, topics that are normally

included in DOE test procedures, such as the concept

of a basic model and the selection of a sampling plan,

and I know that those two issues are going to be

discussed at length later today.

While the existing standards are quite

harmonized with respect to test procedures,

measurement procedures, and reference conditions,

there are some differences that exist that might cause

ambiguities, and DOE would like to eliminate those

ambiguities and differences as much as possible when

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we issue our test procedures.

There are four primary consensus standards

that we're looking at, and the first two are ANSI IEEE

standards, and the second two listed -- these are also

listed on your agenda sheet if some of you in the back

can't read this far up here -- the second two are

requirement standards.

In addition, we'd also be looking at the

TP-1 guide and the ISO standard 9001.

And in addition, we'd also like to

consider the NEMA TP-2 draft and the PC57.153 or 123.

We know that these are nearing completion, and once

they are approved by their sponsoring organizations,

and preferably if we can get this, if they get

approval by ANSI, we'd like to consider them in our

test procedures. We would be able to refer to them if

they were an official document.

So what we'd like to know is are these

standards appropriate for us to be referencing and

would we want to do a clause-by-clause referencing or

would we want to reference appropriate chapters.

And we'd also like to know if the

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standards that are in the preparation stages, the

PC57.123 and the TP-2, if we should reference them,

and we'd also like to know from you what your schedule

is regarding getting those documents out.

So now I'd like some discussion to start.

You've seen some of the questions that we have.

MR. BALDUCCI: Before we start the

discussion, as we mentioned earlier, NEMA will be

giving a brief position on each topic. Lake, is it

going to be you?

CHAIRPERSON EPPING: I'm sorry. I forgot.

MR. BALDUCCI: That's okay.

MR. COULSON: Lake Coulson, National

Electrical Manufacturers Association.

Manufacturers from the Transformer

Products Section have been working on TP-2, a testing

procedure standard for measuring the energy

consumption of distribution transformers. NEMA has

incorporated into TP-2 the testing components from the

standards prepared by IEEE and approved by ANSI

C57.12.90, 1993; C57.12.91, 1995; C57.12.00, 1993; and

C57.12.01, 1989, and components from NEMA's TP-1 1996

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and ISO 9001, 1993.

Additionally, we have included into TP-2

additional relevant standards that are in the

preparation and approval stages, such as IEEE

PC57.1233.

In topics to be covered during today's

workshop, NEMA's response will include the relevant

section from TP-2.

The DOE issue paper indicates that DOE

intends to use uniform test requirements in the

proposed test procedures for both the liquid immersed

and dry type transformers. NEMA requests that the

department consider TP-2 as its single reference

standard for testing procedures.

NEMA believes that the six consensus

standards are appropriate as reference for the DOE

required test procedure.

However, given that the relevant portions

of the ANSI standard are included in TP-2, we believe

that for easier use TP-2 should be the referenced

document.

22 11 MR. BALDUCCI : We'd like to open it up how

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for discussion on this issue, if we have any

questions.

Again, please remember to state your name

for the microphone and the court reporter.

MR. HOPKINSON: Phil Hopkinson from Square

D.

Just to correct what I see also as

missing, NEMA ST20 is a reference document that should

be added.

Also, I believe in Mr. Coulson's

presentation that you'll find that the draft document

that he referred to is really IEEE PC57.123, Draft 11.

I think that's what's out there.

MR. BALDUCCI: Any questions or comments

regarding that?

One thing I would like to ask with regards

to TP-2, and this question Michael brought up earlier,

was DOE cannot reference a standard or a test standard

without it in place. The one thing, and I want to put

this out to industry, specifically NEMA: is there a

timetable?

22 11 You saw our schedule for when we

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anticipate a notice of proposed rulemaking for test

procedures. We were curious when NEMA anticipated

that TP-2 being finalized.

MR. GAUTHIER: John Gauthier from NEMA.

We're looking to have -- the document is

currently under review by the section. The ballot

closes on the 28th of February. I would expect the

document to be prepared. There may be some additional

editorial comments we have to make. I would believe

the document should be approved by at the latest midMarch of this year.

MR. LEVY: I have a question. Ed Levy

from DOE.

Is this TP-2 going to be in the public

domain?

MR. GAUTHIER: Absolutely.

MR. LEVY: What would its availability be

if somebody wanted to --

MR. GAUTHIER: As a matter of fact, DOE

has a copy of the draft, and as soon as we have it

approved, it will be put in for publication and would

be available to the public as soon as it's printed.

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1 I would expect it should be printed within 30 days

2 hope fu lly.

3 MR. LEVY: What would be the cost of

4 obtaining it? Would it be available for free or --

5 MR. GAUTHIER: Oh, no, no, no. It would

6 be a cost. Probably somewhere in the vicinity of

7 about $25 per copy.

8 MR. LEVY: Okay.

9 CHAIRPERSON EPPING: Kathi Epping, DOE.

10 Could you tell us a little more about the

11 ST20?

12 MR. GAUTHIER: John Gauthier again.

13 Let me just handle that. ST20 is one of

14 the two documents that NEMA has been publishing for a

15 number of years. It relates to specialty

16 transformers, dry type specialty transformers, and

17 it' s an appropriate document - - it should be - - that' s

18 part of the general references. It will be included

19 in TP-2. It was just an oversight on our part, and we

20 believe in the information that we gave you that it

21 probably was equally the same thing. It's available.

22 MR. LEVY: This is Ed Levy again.

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So it contains testing protocols for those

kinds of transformers?

MR. GAUTHIER: That's correct. It deals

with the specialty transformer product essentially

with dry types, as well.

CHAIRPERSON EPPING: Is this document

going to have ANSI approval? Do you know?

MR. GAUTHIER: ST20 is one of the

documents approved in the C89 series.

CHAIRPERSON EPPING: Okay.

PARTICIPANT: John, you might address TP-2

as a correction.

MR. GAUTHIER: Well, with regard -- the

comment was with regard to the broader consensus

approval. TP-2, as I've indicated, will be approved

by the NEMA group, which is the industry product

standard.

We have submitted it as a draft copy to

the key individuals in the ANSI process, C57. We

expect as soon as it's approved as a NEMA standard and

received comments back from their review, we'll adjust

the document and then submit it to ANSI for approval

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as an American national standard, and that process

should -- I would believe -- will begin probably midMarch if not sooner, 1998.

And of course, with regard to -- just by

way, Mr. Levy, of indicating the process, I'm the

secretary for C57, and the ballot is about a 45-day

ballot. So 45 days after I issue it, I'll give Kathi

a heads-up. After that we will have the ballot closed

and would expect that the document would be published

shortly thereafter as an ANSI standard.

CHAIRPERSON EPPING: Thank you.

MR. BALDUCCI: Any other questions or

comments with regards to the consensus standards?

Kathi, Oskars, anyone in the audience?

(No response.)

MR. BALDUCCI: Seeing none, it put us way

ahead of schedule now. We're not going to take a

break now because it's not 10:20. What we will do now

is talk about the definition of basic model for

distribution transformers, and, Kathi, would you --

I'm sorry.

22 11 MR. McCABE: This is Michael McCabe.

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Let me ask NEMA whether or not there's

anything in developing TP-2 that you would need any

input from DOE, DOE staff, contractors, and second,

ask Kathi or Oskars, particularly Oskars since he's

been involved, is, you know, what have you seen in the

development of TP-2 that you might feel that would be

useful to provide.

So it's actually two questions, one for

NEMA as far as any assistance you may need, and,

Oskars, anything that you would like to offer as far

as thoughts on what you've seen so far.

MR. GAUTHIER: John Gauthier from NEMA

again.

Mike, with regard to your first question,

we have provided a copy to your office, to Kathi and,

I think, Anthony, just the other day. We would

certainly appreciate your review and some input as to

what we need to be -- what we've missed.

And I might say with regard to your

question with regard to Oskars, we've been very

privileged to have Oskars involved in our process from

almost the get-go.

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Oskars has been a very vocal and very

insightful participant on our task force, which is

sort of the developing group, and I think perhaps only

in the area of the sampling formulae is there any

modem of difference, but I think that's a matter for

discussion here.

Do you agree, Oskars?

MR. PETERSONS: Well, if I can offer some

thoughts, I had opportunity to review TP-2 drafts,

participated in a couple of the meetings. I tried to

convey the message -- well, as I participated

originally, this was, I believe, the intent was for a

private sector standard.

I did see some opportunity to have single

standard also for future, really having -- rather than

carrying around six documents, having that in one

document. So that's certainly advantage, user

convenience.

Also, if in future there is a DOE standard

tracking the private sector document with DOE test

procedures would be much easier.

My concern was, which I also voiced and

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TP-2 people followed up on it, I'd really like to see

that TP-2 is harmonized as much as possible with the

existing primary IEEE/ANSI standards, and this has

been done also.

So really I have been quite pleased what

the progress has been, and there are obviously some

fine points where I may not agree immediately, but I

guess if the directive from DOE is to work towards TP2 as a single document, well, then I think I see that

as a green light.

MR. BALDUCCI: Great. Thank you very

much, Oskars.

Any further questions, comments, or

discussions with regard to consensus standards for

distribution transformer test procedures?

(No response.)

CHAIRPERSON EPPING: Okay. The next item

for discussion is the basic model.

EPCA products are generally grouped into

basic models partly to reduce the testing requirements

for the manufacturers, and basic models are used in

the sampling process.

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In the issues paper, you saw this draft

definition of a basic model.

Based on our discussions with NEMA, for

instance, yesterday, this definition, although it

would work for an appliance, say, like a dishwasher,

it might not be appropriate for transformers because

your product is more unique.

So we would like your help on how we

should define basic models so we don't over burden you

with testing requirements, but we can meet our

objectives, as well.

So we've already heard that there are some

problems with this definition of basic model. That

would be the first question.

We'd also like to know if it would be

possible to combine a number of models into families

or groups, if we could group models that have the same

nominal kVA rating.

And this question was not on your

original agenda, and we'd like to know if they could

be grouped by nominal kVA rating according to

normalized loss data.

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And Oskars is going to talk about this

proposed equation and how it could be done.

MR. BALDUCCI: Oskars.

This is Anthony Balducci.

Before you give your presentation, I just

wanted to recognize Deborah Miller from the Assistant

Secretary's Office. She's here representing Dan

Reicher. I just wanted to recognize her.

Thank you.

MR. PETERSONS: Well, just a very, very

brief comment. I have been aware since day one when

I started on this project that for some manufacturers,

each transformer is practically its own --

MR. BALDUCCI: Use one of the microphones,

either one.

MR. PETERSONS: -- is its own basic model,

but I believe using such a normalized approach in

representing either losses -- efficiency is already

normalized -- one can really combine all transformers,

let's say, for which the same minimum efficiency

standard applies into one basic model.

As I see what is done, for example, in TP202/797-2525

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1 and in Canadian standard, there were minimum

efficiencies or maximum losses applied to standard kVA

ratings, and I believe all transformers in that

nominal kVA rating can be combined in one basic model

either using efficiency or normalized losses,

normalized in this manner.

This is actual loss, and you subtract

mandated loss and divide and then add one, and you

will end up with a figure where 100 will be for -- 100

percent will be for loss that would correspond to

mandated; efficiency would be sort of mandated loss

level. If you go to higher efficiency, this will go

in negative direction, and if you have lower

efficiency, you have a higher losses.

So using the normalized approach, either

normalizing losses or normalizing -- well, efficiency

by itself is normalized. I cannot see any reason why

all transformers for the same nominal kVA group can't

be combined as one basic model.

MR. COULSON: With regard to NEMA's

position on the definition of basic model, we support

the following definition for basic model.

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Basic model would be defined by output

power, kVA rating, such as one of those tabulated in

NEMA TP-1, Tables 4.1 and 4.2, which include nominal

power, kVA rating; insulation type, liquid immersed or

dry type; number of phases, single or three; and the

voltage rating range, medium voltage and low voltage

for dry type transformers.

NEMA believes that if the criteria for

basic model is met or our proposed definition is

accepted, grouping many actual production models of

the same nominal kVA rating in one family of models is

acceptable.

With regard to the presentation that

Oskars just made, NEMA would like some additional

time. We don't at this point have a response to what

was presented before us, but we would like the

opportunity to review or even if any of our members

want to comment on what we've just seen, we could open

it up at this point. I don't have a -- NEMA at this

point does not have a position.

MR. PATTERSON: Wes Patterson, ABB.

Oskars, on the formula that you just gave,

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would that be measured in your mind over a basic

model, a kVA insulation phase kV rating for 180 days,

for 360 days? I mean it's not measured over one unit.

So it must be measured over a population of something.

MR. PETERSONS: It is measured over a

population, and I think I mentioned in my proposal

over 180 days. Well, that is flexible. Whatever is

reasonable.

MR. PATTERSON: So your concept is then

that this normalized loss would be over the definition

of the basic model for some defined period?

MR. PETERSONS: Right.

MR. PATTERSON: Okay. Thank you.

MR. PETERSONS: Hopefully in future the

population will not change that much.

MR. PATTERSON: Thank you.

MR. HOPKINSON: Phil Hopkinson, Square D.

In addition to the basic model definition

that Lake Coulson just presented, I think that there

should be, at least from a Square D position and I may

represent more than a Square D position, a list of

exclusions for the basic model.

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I would propose that the exclusions should

include what is listed in the scope section, 1.1 of

NEMA's TP-l, and would include then liquid filled

transformers below ten kVA, dry type transformers

below 15 kVA, drive transformers, both AC and DC, all

rectifier transformers, and transformers designed for

high harmonics, all auto transformers. It would

include non-distribution transformers, such as those

for uninterruptible power supplies. It would include

special impedance, regulation in harmonics

transformers, regulating transformers, sealed and

nonventilated transformers, retrofit transformers,

machine tool transformers, welding transformers,

transformers with tap ranges greater than 15 percent,

transformers with frequency other than 60 hertz,

grounding transformers, and testing transformers.

In addition, I would also add transformers

for unusual temperature rises

MR. LEVY : This is Ed Levy from Department

of Energy.

I take it what you're talking about here

22 11 is or what you were describing there were transformers

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that would be excluded from coverage of the test

procedures?

MR. HOPKINSON: These transformers would

not be part of the basic model.

MR. LEVY: Well, when you say "the basic

model," the purpose for -- there would be presumably

several basic models of any manufacturer depending on

what was produced. The purpose of the concept of a

basic model is to group different models of

transformers that a given manufacturer produces so as

to limit the testing burden.

I inferred from what you were saying that

the exclusions that you described would be equipment

that would not even be subject to the standards, would

not be subject to the testing at all. Is that your

intention?

MR. HOPKINSON: Yes, that's correct.

MR. LEVY: Okay. Which I see is something

we certainly need to deal with as part of this entire

effort, but it's a different question from grouping

those transformers which are covered into groups so as

to eliminate or not eliminate, but reduce the amount

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of testing that's required.

MR. HOPKINSON: Yes, we agree with that.

I think those transformers that are included would fit

the definition that Mr. Coulson presented from NEMA,

those transformers that are not included, and should

include some list, and the list that we propose is the

one that I just mentioned.

MR. PATTERSON: Wes Patterson, ABB.

Edward, the list of exclusions that Phil

just ran off pertains to in the proposed test

procedure draft, there's a definition of distribution

transformer which included all of those products. So

if there's a definition in the test procedures, you

also have to have an exclusion clause.

Thank you.

MR. GAUTHIER: John Gauthier.

Just by way of reference, TP-1 and TP-2

scope identifies these lists of equipments as excluded

from both coverages. So this is not new, but really

it's by way of just verifying it. We've already

covered it.

22 11 MR. BALDUCCI: Michael has just made a

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good suggestion. One of the things that we're going

to add on the agenda would be coverage of the test

standard and which transformers would be covered by

the test standard.

Before we move to that, do we have any

other questions or comments or concerns regarding

basic model either from the panel up here or anyone in

the audience?

MR. WILKS: Alan Wilks, ARMCO.

I understand that the normalized formula

given would be an accumulation of an average of all of

the units that go in to make up that model, and since

it is an average, I would assume also that any one

unit or units could exceed the minimum efficiency.

However, the average would be necessary to be below;

is that correct?

MR. PETERSONS: Yes.

MR. BALDUCCI: Further questions or

comments regarding basic model?

(No response.)

MR. BALDUCCI: If not, I would suggest we

move in to have a short discussion on coverage of

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transformers. We heard some comments of what's

covered and what's not covered.

Michael, did you have any comments to

start that off with or no, not to put you on the spot

at all? Because I think there's a little bit of

confusion of where we are, what the test standard

would cover, and I think we need to clarify that

before we press on.

MR. McCABE: Yeah, this is Mike McCabe.

Building on what Ed Levy has said, the

basic model, the concept for that has historically

been to recognize that while a manufacturer may have

a number of individual models and that some of them

may only be differentiated from others based on

geometry or features that do not affect efficiency,

that we have had to try -- we've come up with the

concept of basic model in order to bin, cluster,

group, or set cohorts up on the basis of efficiency.

So that if you have features that do not

affect efficiency, that there's no reason to, one,

subject all of those different models to testing; that

you can just take and clump them into one cohort and

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test them for the purposes of this program for making

ratings on efficiency.

That doesn't necessarily mean that those

are all the same models as you would consider them

because you're marketing products to a very diverse,

very specialized application, and you know, I don't

understand that market. I'll attempt to understand

that market as well as you do. That's your market,

and you're the experts there.

But we're looking for a way to reduce the

burden. Similarly, we're looking to understand and

appreciate your comments with respect to coverage.

The comment that Lake made at the outset

about the size limit that we've gone down too small,

the quarter kV transformer, that it's too small and

shouldn't be covered, I'd be interested in hearing

your comments as to why the proposed coverage that's

in the test procedure, why that should be adjusted,

what should be eliminated and why, in order to provide

that rationale because when we come out with the

proposed rule, there will be a debate as to whether or

not a quarter kV transformer should or shouldn't be

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covered.

If we're going to take a position and say

they should not, it's not going to be because Lake

said so, because Valerie, representing Natural

Resources, Canada, may have a very different position.

So we'd like to have an open discussion

and the rationale in order so that we can make a

reasonable decision and put that into the language in

the proposed rule.

MR. ROLLING: Dave Rolling from Cooper

Power Systems.

I can address parts of the exclusion, not

all of it. Generally speaking, each of the items that

was identified for exclusion has some particular

characteristic about it as a product that makes it

difficult to let energy efficiency be the overriding

need.

For instance, when you're designing a

rectifier transformer, many times there are -- it has

voltage in a kVA, but it also has a certain set of

load characteristics based on the load it's driving

that has to be designed to,'wherein if you don't do

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that, the product won't work properly.

So efficiency, while you could try to get

it, it cannot be your overriding consideration.

Another situation would be if you're

trying to retrofit a transformer into a building, into

a particular basement area or something like that, you

have dimensional constraints, and so the overriding

constraint in that transformer design doesn't become

efficiency. You may not have room to work with in the

location you're trying to put the transformer to hit

the type of efficiency that the minimum efficiency

standard would want you to make.

And you could go down that whole list of

transformers and come up with the fundamental reasons

that each of them has some other overriding design

constraint.

MR. LEVY: Let me raise a question with

you, Dave.

This is Ed Levy again.

MR. ROLLING: Yes.

MR. LEVY: The question here is whether

or not a particular transformer is appropriately

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described as a distribution transformer. That's what

the department is charged with regulating or at least

examining the issue of regulation.

And if it's a distribution transformer,

then it would be covered. Now, that does not mean

that the points you're raising are not appropriate for

consideration. Those points may affect the precise

test procedure for that kind of transformer or the

standard level for that kind of transformer.

So the question here is not so much what

distinction should be made among transformers, but

rather at a sort of broader level. What should be

properly classified as a distribution transformer and

what should be classified as not being a distribution

transformer?

I don't know if your comments really

address that question.

MR. McCABE: Mike McCabe.

Excuse me for interrupting here. Let me

add one other point.

MR. BALDUCCI: Michael, leave it on.

MR. McCABE: How's that?

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Many of us are much like myself in being

task oriented and look very specific in using some

examples, and so to add to what Ed has said, we can

deal with many of those issues you raised in the test

procedures by establishing different categories of

products.

The first question now that we have is

whether or not it appropriately is a covered product

and whether or not it is a transformer.

So, for example, one of the first tasks I

had to do with this program was to define whether or

not a packaged terminal air conditioner was a covered

product for this program. At that time, the program

was strictly dealing with residential products.

A packaged terminal air conditioner, as

you may or may not be familiar with them, are through

the wall air conditioning products that are used in

commercial environments, typically in motels. It's a

commercial product, not a residential product. It

looks like a through the wall room air conditioner,

but it is not covered by the program, but we had to

come up and define it in our regulations as what a

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PTAC was in order to exclude it from the program

because the program at that point in time was intended

for residential products, not for commercial products.

So that one question we'd be looking to is

is this a transformer. Is this a product that was

intended to be covered by the legislation when the

legislation directed DOE to issue a determination?

Secondly, there may be products that are,

in fact, covered products, but they can't be tested.

The test procedure physically cannot be able to cover

those products.

Another example is with respect to water

heaters. The test procedures that we've established

for water heaters are limited in their ability to

evaluate certain sizes of water heaters. So while for

the purpose of the program a water heater -- a

residential water heater is a residential water

heater, it has a very broad definition.

Then in the test procedure we have a

definition as to water heaters that are covered by the

test procedure, which is a smaller set than what is

covered by the program.

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So by defining the definition of water

heaters for coverage under test procedures, we

eliminated products, some of which you're getting to,

that physically couldn't test, and there will be

others that -- maybe other issues as to why it can't

be tested or why they shouldn't be covered. They're

not distribution transformer, and I'm not -- I have a

hard time in this industry since a chemical engineer

can understand water flowing, but why current goes one

way and electrons go the other, that's beyond me.

(Laughter.)

MR. McCABE: But I'm looking for you to

give us direction. So instead of going like that

(indicating), to say this is the reason why. This is

what makes sense.

Granted there are reasons why you cannot

design any more efficiency into a product because of

space limitations, but that has been addressed in many

instances before, and Chuck Hastings when he was

working with some of the residential products can

appreciate that we can establish classes, and we have,

which those classes recognize some of those

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limitations, and through the process of establishing

classes, that if it gets into a standards venue, those

classes may or may not be subject to standards.

So what we're looking for in coverage is:

is this a transformer? Is this a product that should

be covered by this program? Is it a product that's

covered by TP-2? Is it a product that's covered by

the ANSI standards? Is it a product that we should

consider for test procedures?

But then when it gets into standards,

there's a whole different set of questions that we're

going to have to address.

MR. ROLLING: Unfortunately the choice of

words, "distribution transformers," that was in the

original legislation is very ambiguous terminology,

and I think if you had the folks in this room define

that terminology, you'd come up with at least 20

different definitions probably within this room.

So we start from that rather broad

categorization in the original legislation, and that

does make this difficult, not overly difficult, but it

does mean that we'd have to come to grips with the

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definition of distribution transformer first.

MR. McCABE: This is Mike McCabe.

That's key. Every product that we cover,

the first thing that we have to do is define what that

product is so that we then know what is covered and

what we're talking about.

MR. PATTERSON: Wes Patterson with ABB.

If you go to page 16 of the draft

document, test procedures, there's a definition by the

DOE of what a distribution transformer is. In this

definition, they have taken what has been historically

a definition in the industry and broadened it to

include things that the industry typically did not

include as distribution transformers, point one.

Point two says that distribution

transformer means a transformer for transferring

energy from primary circuit to secondary distribution

circuit or customer service circuit or between

circuits on the customer's premises.

A very strong case can be made that a

quarter kVA transformer never meets that paragraph,

never, and almost every product that Phil mentioned

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never meets that paragraph.

So all that was, all that Phil was trying

to do was to elaborate on the specific instances of

that paragraph which do not pertain, but people can

translate from the following paragraph to be included.

So we have a confusion between these two

sentences in this paragraph, and all we're trying to

do is clarify either that or maybe in your test

procedure you can just remove the definition of

distribution transformer and pick it up over in the

energy efficiency standard later on down the road and

not try to establish definitions in this document.

Just establish how we're going to test them, which is

also what's normally done in the standards industry.

MR. LEVY: But we do need to establish a

definition, and I think that the comments that we're

getting here on this issue are entirely pertinent and

helpful, but I would ask you also how is the second

sentence too broad. You said at the outset of your

comment here that the second sentence --

MR. PATTERSON: For instance --

MR. LEVY: -- doesn't incorporate --

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MR. PATTERSON: For instance --

MR. LEVY: -- things that would be

considered distribution transformers.

MR. PATTERSON: It says, "For the purpose

of this DOE test procedure, transformers of the

following rating are included: primary voltage of 480

to 35 kV." Okay?

MR. LEVY: Yes.

MR. PATTERSON: Starting off with a

primary voltage of 480 and contending that that is a

distribution class voltage is counter to what the

entire industry has done for the past 100 years.

Distribution is usually rated much higher than 480.

MR. LEVY: Where would you set the floor

on that?

MR. PATTERSON: Personally I would set it

at 1.2 kV and above. You can sample all of the

manufacturers here and see where they would put it,

but most of them probably will not put 480 volt

because that's usually an application voltage, not a

distribution class voltage.

Okay. The next thing is that between

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1 liquid and dry there are two definitions. Is that

2 right? Rated liquid from ten kVA to 2,500 dry, from

3 ten kVA. No, it's a -- but I thought that was changed

4 someplace, that there was now a definition. I guess

5 it was with the .25 kVA f or dry.

6 We're trying to come up with a definition

7 for distribution different between liquid and dry when

8 we extended it to .25 kVA. That's not justifiable by

9 any sense.

10 MR. LEVY: Which is not justifiable?

11 MR. PATTERSON: Trying to say that a

12 transformer because of its insulation class determines

13 whether or not it's distribution. The insulation

14 class has nothing to do with distribution. It's the

15 application of the product that has to do with whether

16 or not it's distribution.

17 The most correct statement in this whole

18 paragraph is sentence one. All the rest of it is --

19 you have problems with it. So you have to get more

20 explicit if you're going to put that definition in

21 this document.

22 And all Phil was trying to do was to

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become more explicit. When you look at his specialty

transformers, they are not being deployed in

distribution class service. They are being deployed

in end use service. They've being hooked up to a

piece of equipment like the transformer that's inside

that light box, and that shouldn't be considered

distribution.

MR. LEVY: Well, we need to get that on

the table now. So I think --

MR. PATTERSON: Thank you.

MR. LEVY: -- that's very helpful.

MR. BALDUCCI: Do we have any other

comments or questions or clarifications on that point?

Oskars, you look like you were ready to

say something or no?

MR. PETERSONS : Well, the way I arrived at

that definition, I believe, was the first part comes

from IEEE dictionary and inclusion or exclusion, I

think, came from data in a determination of this, the

voltage ratings, but that can be modified.

MR. HOPKINSON: This is Phil Hopkinson

from Square D.

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I was just reading from the Federal

Register on October 22nd of 1997. It says, "The Oak

Ridge National Lab analysis," which we presumed is a

forerunner for this meeting today, "did not consider

transformers which are not continuously connected to

a power distribution system, such as distribution

transformer. For example, transformers that are part

of machinery which are switched off from electrical

power were considered by the study as a component of

the machinery circuit and not part of the power

distribution circuit. Also special purpose control

and signal transformers," which these quarter kVAs, by

the way, would represent, "as well as bulk power

transformers were excluded from consideration because

they are not classified as distribution transformers."

So that our position would be that

transformers like control power transformers, which

the fractional kVA transformers represent, are not

distribution transformers.

MR. LEVY: Just to follow on to that, if

you go on in the next paragraph, it articulates the

definition in terms of primary voltages and

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capacities, stating that the language that you just

described would be accepted from that.

Are you saying that in some of these

capacity ranges, for example, that there are no

transformers that don't fall within these accepted

areas of distribution?

MR. HOPKINSON: I would say that I would

agree with the definition that primary distribution

transformers are above 1.2 kV class primary, and

secondary distribution transformers are those below

1.2 kV class primary, but that fractional kVA up and

below ten kVA would be considered as excluded because

they are predominantly not distribution transformers.

MR. LEVY: Now, when you say

"predominantly," I mean, how predominant?

MR. HOPKINSON: Well, as an example, 75 to

80 percent of those transformers would be machine tool

control type transformers. They'd be part of another

piece of equipment. They wouldn't be used separately

as a power transformer.

MR. LEVY: So would you say 15 to 25

22 11 percent would be used as -

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MR. HOPKINSON: Probably.

MR. LEVY: -- transformers?

MR. HOPKINSON: Probably.

MR. LEVY: Okay.

MR. BALDUCCI: Any other questions or

comments? Randy.

MR. BARNES: Hi. I'm Randy Barnes, Oak

Ridge National Laboratory.

We included the smaller transformers in

our determination study for completeness. We

recognize that they contributed very little to the

overall kVA that was used in distribution

transformers.

One comment on the voltage levels. That's

always been a little confusing to me. In the lower

voltage class, transformer manufacturers rate those at

1.2 kV, which is really an insulation class, and then

the higher -- the medium voltages are rated as a

voltage class.

Where if you look at the IEEE standards,

the low voltage is really defined as less than 1,000

volts. So the transformer industry seems to mix an

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insulation class when they talk about low voltage, and

then they talk about operating voltage classes when

they go to medium voltage.

It's not an important issue, but it is

kind of a mixture, the way they look at things.

Do you want to comment on that?

MR. PATTERSON: I'll comment. Wes

Patterson, ABB.

Within the design industry of these

products, I don't think there's ever been a confusion

between a system class rating and its actual operating

voltage. So what we have delineated in the standards

are two distinct concepts: the operating voltage of

the system itself and its system class rating.

So I don't really believe there's any

confusion on that topic, and the 1.2 kV class

typically covered everything that was greater than 601

volt and less than 1,200 volt. So if you had a system

sitting out there that was a 1,100 volt system, the

actual grid itself, where another grid that was 1,000

volt system, we grouped them both together into 1.2 kV

class.

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Then we would size the lightning arresters

to support the 1.2 kV class, right? So all of the

standards were built around the system class, but the

actual specific voltage, operating voltage was

anywhere from the one class to the next class.

MR. BALDUCCI: Thank you.

I'd like to ask again if we have any

questions or comments or clarifications with regard to

this issue. Again, if you feel that your comments or

concerns aren't expressed, please do submit those in

writing, and again, we will determine the comment

period closure at the end of the workshop.

How's everyone feel? Are we ready to take

about a five or ten-minute break right now? It's

about 10:28. Why don't we try and be back here at

10:40?

(Whereupon, the foregoing matter went off

the record at 10:30 a.m. and went back on

the record at 10:44 a.m.)

MR. BALDUCCI: If everyone would like to

take their seat, we're going to get started here in

about 30 seconds.

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I hope everyone had a nice break and found

the coffee and doughnuts and everything else okay.

If we'd like to take our seats, we're

going to jump on to the next topic, which is the

sampling plan for units to be tested, which, Oskars,

I'm told you will lead that discussion.

Hold on one second.

MR. HOPKINSON: Anthony, unfinished

business. Could I mention something more on

fractional kVAs?

An area that occurred to me while I was in

the break was the question of the cost of testing of

small kVA products, and frankly, the testing cost for

fractional kVA transformers can take on higher than

the sales value of those products, and I think that,

therefore, both for the application, as well as the

difficulty in testing, that there is another rationale

for why those products should be excluded.

MR. BALDUCCI: Thank you, Phil.

MR. PETERSONS: Well, we are now at the

third topic, sampling, and Kathi sort of gave me

orders to start to carry the thing myself.

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(Laughter.)

MR. PETERSONS: Well, sampling really has

been the toughest topic for me to come to sort of any

closure, and as a result, even at this stage I'm

offering two plans for consideration.

Some of you NEMA people may recall that

about three years ago I mentioned a sampling plan, a

very tough one, where 95 percent of the population

should pass with a 95 percent confidence limit.

Then I got some informal feedback. The

next time, I guess, when I talked to Paul at a

Transformer Committee meeting in Vermont, then I said

the mean should pass, again, with an extremely high

confidence level.

Right now things are even more relaxed,

and maybe four years ago when I started this project

I was a brash, 62 year young man --

(Laughter.)

MR. PETERSONS: -- and now I'm a more

mature 66 year old.

(Laughter.)

MR. PETERSONS: So more realistic.

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Well, it has been obviously a learning

process for me, really what is desired under EPCA,

what has been done before. I was very much influenced

also by Canadian standard where there is no negative

tolerance, and, well, that's the result.

Well, on sampling I have assistance from

my colleague at the Electricity Division, Ken

Stricklett, who is here, and also we have help from a

person in Statistical Engineering Division, Mark

Vanjel. So some of the work and really the most

significant are due to these two gentlemen.

What I'm going to do, I'll present a

tutorial. What do these two sampling plans mean in

terms of probability, density curves, and some

abbreviated comments about them?

Well, we get to method one, which is

really the one which is used for consumer products,

was proposed also for motors. The sort of typical

wording, what you see in CFR, in the Part 430 is,

well, the first paragraph.

Really the test method seeks so-called

represented value which can be either the mean of the

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sample or lower confidence limit of the estimated

population divided by this factor, .999, and that is

based on six percent loss tolerance as in ANSI

standards, so to translate it into efficiency

tolerance.

Criteria for compliance is that

represented value as obtained here should be equal or

higher than the mandated value or really the value on

the minimum efficiency in the standard.

Now, statistical methods and sample size.

The wording is very general, really not specified. It

doesn't tell you what the sample size is, does not

tell whether you should use T test, Z test, and I

think by design it's left quite open since you know

your product and certain flexibility can be allowed.

Well, if you use T test, which is one of

the tests for determining confidence limits, you

select your sample size, measure losses, compute

efficiency or continue working with losses, and then

compute your statistical parameters, X bar, which is

mean standard deviation, which is in text denoted by

capital S; standard error of the sample, which in

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draft is -- we use the symbol, capital SE, and in

parentheses X, and then lower confidence limit.

And having done this test, the represented

value for compliance.

Now I shall go to just show some

distribution curves. Let's say your entire population

for the basic model is represented by this P zero, and

then the probability density for the mean of five

units. It's this curve here.

Well, the manufacturer is quite prudent.

Here is the mandated level, and he operates slightly

above the mandated level.

Well, the next chart is more busy with

vertical lines. Here we have taken specific sample of

five denoted by X bar. So samples taken here.

Now, already one of the things that we

need we already have, and then we compute the lower

confidence limit. This one here goes down, and then

divide this by this factor, .999, and come up again.

Well, for compliance we take the lower of

the two values, which is X bar here, and it must be

higher than mandated efficiency. In case the other

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one is lower, then that must be at or equal the

mandated efficiency.

Well, in both cases -- well, this one here

and this one here must be about the mandated

efficiency.

Now, let's look at possibility. You do

operate above the mandated efficiency level, but

suppose if you took the sample you were less lucky and

you ended up somewhere here. Well, obviously --

MR. BALDUCCI: Oskars, I'm just going to

change a term on you. You keep saying "mandate

efficiencies." That implies an energy efficiency

standard. We don't mean a mandated efficiency. We

mean a rated efficiency. So instead of "mandated,"

can we used "mandated" -- instead of "mandated" use

"rated efficiency" for this?

MR. PETERSONS: Okay.

MR. BALDUCCI: And that's what we're

talking about with the sampling plan. It's not a

mandated efficiency. It would be a rated efficiency.

Just that clarification with that term.

MR. PETERSONS: Thank you.

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MR. BALDUCCI: Thank you.

MR. PETERSONS: All right. Well, there is

a possibility even with this population, quite a high

probability or reasonable probability to fail, and if

you do operate exactly at the rated efficiency, the

best what you can achieve for demonstrating compliance

would be 50 percent.

So obviously if you do operate at the

rated efficiency, you will not risk failing your

production run, where you only have 50 percent of

probability of demonstrating your compliance. You

would try to move your production higher than this

rated efficiency.

Well, here is a chart, sort of family of

curves which are not available in your handout. The

reason they are not available in your handout, it is

very, very preliminary data, and for data like this,

we do need full editorial approval at NIST before we

can really publish.

I'm using these charts here just to

illustrate the operating characteristics, really the

trends of this sampling plan. It may not be the sort

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of final thing that will be used or final thing that

will be proposed.

Well, here on this scale here, we have

loss percent, and this is the normalized losses. A

hundred percent loss would be if the losses are for

the rated efficiency. If your efficiency is higher,

your losses go lower.

Another way around, they go higher in

other direction, and along this axis here we have

standard deviation of your manufacturing process.

So if you work exactly at the rated

efficiency here at the lower standard deviations you

have 50 percent probability for passing, but if you go

to higher standard deviations, this 50 percent curve

sort of swings away, and the reason for that is this

device which was used, this .999 for efficiency, for

losses, corresponding losses, it really should have

been 0.94 percent. If this were the case, then there

would be straight curve up to here and then would

start swinging away.

Well, I don't think a 50 percent

probability of passing would be good enough. You

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would probably move somewhere to 95 or 99 percent,

which would require moving or reducing your losses,

let's say, in this case by about four percent or so,

or three percent.

So you would have to absorb all this other

statistical uncertainty.

If you go to higher standard deviation,

obviously your over design would have to be larger,

well, around eight percent, but if this one is

correct, it's only about six percent.

So there is this type of penalty, and if

you were to operate a sample of two, a very small

sample, then, well, the sort of penalty would be even

higher.

Reading back in Federal Register when this

was originally proposed 20 years ago, I sort of have

the sense that industry, appliance industry, liked

this plan. It allowed using very small sample, sample

of two. The testing of appliances apparently is very

expensive, time consuming, and so on, and they were

not against also on this over design because the

rationale seemed to be that this would improve

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customer satisfaction.

But this was proposed also in NOPR for

motors, and there were some objections to this one.

Now we go to method two, which is based on

statistical T test. In addition to that, requirement

for minimum sample size.

Criteria for compliance, there are two,

namely, that mean of the sample should be higher than

rated efficiency minus this factor here, which was

used also in lower confidence level, and N should be

five or higher value depending on standard deviation

of the process.

Steps in implementation. This is very

simplified. It is not as formidable as it may look

from draft where there are ten or 11 steps. You,

again, go through determining the statistical

parameters, and then determine the adequacy of sample

size.

I should say the parameters for

determining sample size will be selected so that when

your standard deviation is really the industry norm,

you will not require more than five units, and then a

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1 test for compliance.

2 We are back again to these distribution

3 curves. Here is your X bar. You determine your lower

4 confidence limit. Here is your rated efficiency, and

5 you subtract from rated efficiency this distance here,

6 which brings this so-called lower control to this

7 po i nt.

8 And then for compliance your X bar should

9 be on this line or higher. You do notice that in the

10 first plan X bar could never be lower than this rated

11 efficiency, whereas for this plan it does allow so.

12 So superficially it looks like a great thing for

13 producer and not so great for consumer.

14 (Laughter.)

15 MR. PETERSONS: Maybe yes and maybe no,

16 depending how the levels are set.

17 And here we go again to operating

18 characteristics for that plan. Obviously if you work

19 exactly on the rated losses, 100 percent losses, you

20 have 90 percent probability of passing.

21 Well, I don't think 90 -- you would not

22 risk one in ten in failing your production, and you

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would probably move your operating point somewhere

here, maybe to .999, 99 percent, and if you recall,

well, this line here, you would have to decrease your

losses by two percent, whereas in previous case, you

had to decrease your losses by about four percent.

So this is more favorable for producer

comparison to other plan where producer had to absorb

all the risks due to statistical uncertainty. In this

plan, they would be sort of split between producer and

consumer.

How these plans are, well, set for final

document really depends from various factors: sample

size and what really is a standard deviation in

industry for typical process.

I'd like to sort of summarize the two

methods. The first one, very simple, allows you

flexibility also. Obviously high assurance of meeting

EPCA requirements, and of course, determination

assurance increases with the sample size.

One very important advantage for

transformer application, this method is consistent

with IEEE/ANSI standards where the loss tolerances are

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given.

The disadvantages, well, is higher burden

on producers. Statistical methods, well, the way you

do this adjustment by divisor factor, they are not

readily available, not unless you have these operating

points as shown before. It's really difficult to see

the result.

For method two, well, statistics is

rigorous and widely used. There is possibility of

sort of balancing producer and consumer risks just by

moving this fan shaped structure one way or other by

adjusting confidence of limits.

Disadvantages, well, it is a little more

complex, but if you deal with sample size of five in

first method, then it is not more complex.

I think one of the disadvantages could

also be, again, customer relations. Suppose a large

shipment of transformers is delivered and sample mean

is lower than the manufacturer specified. How would

you explain this to consumer? It sort of assumes that

everybody has had Statistics 101, as everybody has

good intentions, and so on.

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Well, that sort of concludes what I want

to say. No, no, no, it doesn't conclude. Sorry.

(Laughter.)

MR. PETERSONS: Some of the feedback we

would like to receive to really fine tune these things

and then make a final decision, well, please give us

general comments on the two plans as perceived by you.

We'd really like to know what is the

statistical significance of loss tolerance. Really

what we'd like to know, what is standard deviation of

typical transformer manufacturing process.

We have to adjust divisor in the first

method and key coefficient in second, and for that we

do need the statistical parameters. If you do have

some actual test data, I would really appreciate that

you do go through these analyses and see what you

come. This is in our case modeling. So, well, there

will always be bucks in computer program.

Well, we would like to get if you have

suggestions for any other sample plan.

Thank you.

Okay. Well, Kathi had a slide she wants

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to put up. No, I guess I begin by asking for comments

before DOE should proceed.

MR. BALDUCCI: Thank you, Oskars.

MR. HOPKINSON: Phil Hopkinson from Square

D, and representing NEMA at this point.

Oskars has made a very interesting

presentation, and we have as part of NEMA studied the

two proposals and have some comments today, and we

will follow up with written comments later on so that

we will have a more complete response at that time.

NEMA at this point believes that sampling

plan number one is not appropriate for distribution

transformers. Let me comment a little bit about

sampling plan number one.

It is based on a provision for a very

small number of samples to be taken, such as two, and

apparently that drew from appliances that are very

difficult to test, and Oskars mentioned something

about air conditioners, something about refrigerators

early on, where the testing is quite expensive and

where the numbers of samples taken for the testing are

very limited, and inherently it gives a wide standard

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deviation if you don't have very many samples in the

test.

The result is that it puts in unreasonable

restraint on the product and suggests that the product

has to be fundamentally designed to be much more

efficient for guaranteeing that the end result of that

whole population will meet the standard.

And it doesn't apply. Transformers are

tested more regularly, more routinely in production by

all manufacturers today, and therefore, sampling plan

number two becomes the preferred.

So going back and taking sampling plan

number two, NEMA prefers a modified sampling plan to

DOE's proposal number two as is now documented in

Draft 6 of TP-2. This plan differs from the DOE

proposal number two in the following.

First, the sample size is calculated in

TP-2 prior to establishing the lower control limit.

The second difference is that the

confidence limit is set at 95 percent both for use by

manufacturers and for any later audit of performance.

I think you'll see that in the presentation that was

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in the NIST write-up that the possibility was left for

several confidence levels to be explored and the

possibility that there may be a 90 percent, 95 percent

or 97 and a half percent.

At this point 95 percent would seem to be

the right number.

NEMA agrees also with the DOE proposal for

a general six percent total loss tolerance to be

assumed in the statistical calculations. However, to

the point that data has been requested, we are trying

to accumulate that data, and that may change our

assumptions, especially since in the TP-1 document, in

the TP-1 document of NEMA which establishes certain

efficiencies, those efficiencies are calculated at

less than full load, like 35 percent for low voltage

transformers and 50 percent for medium voltage

transformers.

The fact that those efficiencies are

calculated at a less than full load rating of the

transformer suggests that the load loss component will

be considerably reduced, and it tends to be the more

stable of the two components in computing standard

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efficiency of the losses.

The core loss or the no load loss is a

much more variable item both with product received

from the manufacturers of magnetic steel, as well as

to the manufacturing process variability in the

production of cores.

At the point of measurement, the no load

loss and the load loss would nominally be at about the

same level, so that the inherent variability is going

to be greater. We will get some data, and we will

respond to that issue in writing as we do, in fact, in

writing after this meeting.

So we at this point agree with the DOE

proposal for a general six percent loss tolerance to

be assumed in the statistical calculation.

Finally, addressing the frequency of

repeat testing, we do not support 180 days as the

standard requirement. Rather, we believe that the

manufacturer has a responsibility to insure compliance

and maintenance of his products by doing as much

testing as is necessary.

I have some cases, one through five, that

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might help in giving some better clarification. This

is -- I'd like to say it's real data, but it's not.

I just thought up some data, and it came about from

the assumption that we had a 75 kVA low voltage, dry

type transformer, and that transformer carried an

efficiency level from TP-1 of 98 percent.

So as it turned in the samples, we assumed

five samples were drawn. You can see the five right

here. So of this five samples, they had an average

performance level of 97.93 percent efficiency and a

standard deviation of 4.6 or 4.7 percent, a standard

error of two percent.

This K factor is really a T factor that

goes along with a 90 percent confidence level, and a

calculated number of samples based on what worked out

to be a low standard deviation of less than one.

So in this particular case, a lower

control limit was calculated of 97.967. If we compare

that number to the mean of the sample that we tested,

we see, oh, my gosh, it didn't pass, and as we move to

the right, in the next column, in the center column,

it's the same data, but now we are going with a 95

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percent confidence level. So the only thing that is

changed is the two numbers, the calculation of the N

and the calculation of the lower control limit.

And you can see that as the confidence

level rises, there is a requirement to test more

samples. There's also a lower control limit that is

more favorable to the manufacturer.

Well, we will sharpen those calculations

as we look at additional data, but the trend of this

is that as the confidence level rises, the lower

control limit to the manufacturer gets more favorable,

allowing a bigger population to pass.

Now, since in each of the three cases,

even at 97 and a half percent efficiency assumed, none

of them passed. So it required us to go back and

select another sample.

So we said that in this sample, it just

happened to be done on a different day, and the steel

that came in was a little better on this day so that

our core loss tested a little better, and the result

is now when we tested the five samples, they happened

to be above 98 percent.

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Well, from that we had a different

standard deviation. We have a different standard

error, the same T, but now in each of the three cases,

it still shows the trend that as the confidence level

rises, it allows a greater number of units -- thank

you -- a greater number of units to pass, and it says

that our lower control limit gets more favorable for

the manufacturer.

In this case though, the standard

deviation was a little higher. It required more

samples, and it would have required still more samples

had we gone with a 97 and a half percent confidence

level.

On the third case, we took another set of

samples. On this one we said, well, let's say that

they straddled the 98 percent efficiency level equally

all the way from 98.1 on the high side to 97.9 on the

low side, and the average worked out exactly at 98

percent.

Well, it still says that as the confidence

level rises, we allow more units to pass so that this

does look like a pretty interesting treatment. We

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will have to get specific standard deviations of

populations to sharpen that assumption of 95 percent

as the operating point, but in the case four, we took

the sum of the first two populations. Remember the

second one passed; the first one did not pass, and, lo

and behold, here's the average now at 97.97, and in

this case all three of the confidence levels allowed

the populations to be considered good.

So finally, when we took case five, case

five took all 15 samples and the standard deviation

was such that the number of samples required was

actually quite low.

So I think that when we get some hard,

fast data for different types of transformers, it will

sharpen our thinking on the confidence level. It

looks like 95 percent is the best place to operate at

this point. It looks like that we will support the

theme of a six percent base variability in the

statistics calculations.

Thank you.

MR. BALDUCCI: Questions or comments for

the discussion on this issue?

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MR. KLINE: I'm Don Kline of Southern

Transformer.

Some of us might be very confused here on

the situation where you have a model population of

one. We've not covered that yet, and this is one of

the major -- getting some comments --

(Laughter.)

MR. KLINE: How is the population of one

or two taken into account in this statistics here?

MR. PETERSONS: We tried to discuss this

in definition of basic model where we will combine

both transformers of the same nominal kVA rating into

one population, normally using efficiency as a measure

for normalized losses.

MR. BALDUCCI: Does that answer your

question with regards to that or clarifying -- this is

Anthony Balducci -- would a clarifying point to that?

If, for instance -- I learned this

yesterday -- is that there's a lot of specialty

transformers made, where you may make one of a certain

type. What DOE is looking to do is take that one that

you make. Is it possible at that size, whether it's

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a kVA rating or some other rating -- can it be lumped

with other types, one single units or maybe a group of

transformers so that you have this basic model is

basically all of these different model numbers, if you

will, that are all similar?

Then you would pull a sample from those.

So you may not test that one specialty unit per se,

but you may test something that's in that basic model,

or did I confuse you more?

MR. McCABE: This is Michael McCabe.

Let me follow it up with a question. What

Anthony has said as far as what we're trying to do

with the basic model is to take models that have

similar characteristics and put them together for the

purpose of testing in order to reduce testing burden,

but that doesn't eliminate the possibility that there

may be products out there which are one of a kind. It

may be a transformer that has specialty made

characteristics that are unique to that, not like

anything else the manufacturer manufactures.

I don't know if that's the situation that

exists. I don't believe in Oskars' that this sampling

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plan really addresses that because it talks about

sampling a lot, and so it assumes more than one unit

in the basic model.

I'd be interested in, one, knowing whether

or not the situation exists where there are individual

units, and, two, what is your practice in testing

those units?

MR. PATTERSON: Wes Patterson, ABB.

The first comment I had, I think it

pertains to everything we've been discussing.

The two methods that are proposed, there's

really a third method, and the third method is where

the manufacturer does 100 percent testing of every

product, and in our industry there are segments of the

industry where 100 percent of the product is tested.

If you're doing 100 percent testing, then

there's no criteria for sampling. Sampling only

implies that I'm not 100 percent testing.

So there needs to be a third method that

incorporated where I did 100 percent testing.

Now, if I have a model definition of one

and I test one, I did 100 percent testing. I'm

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immediately in compliance with method number three,

which is not in the document. Okay?

So the document has to incorporate some

methodology to handle 100 percent testing of the

product.

MR. KLINE: My question hasn't been

answered.

MR. STRICKLETT: I have a quick question

about the interpretation of the standards. I took

these standards, I believe -

MR. BALDUCCI: Ken Stricklett.

MR. STRICKLETT: Yeah. Sorry. Ken

Stricklett from NIST.

And I'm learning about the -- trying to

understand the industry practice. So if there could

be some comments to clarify this, I'd appreciate it.

The IEEE standards, both the 57.00 and

57.01, have the tolerance specified in those standards

for the losses, and that includes samples of -

discusses the case of sample of one, sample of two,

and samples larger than two.

Now, by putting a tolerance on the losses,

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that effectively provides a sampling plan, and has

that been discussed by NEMA as a control mechanism for

quality control, and is that IEEE tolerance protocol

followed by industry currently?

I guess those are my questions.

MR. BALDUCCI: Phil, before you answer

that question, I'm going to ask one other question,

and this goes back to Wes' comment about 100 percent

testing.

When you test -- for instance, you say you

test 100 percent of your transformers. If you've got,

say, ten transformers that are identical and you test

every single one of those, how do you rate those? Do

you rate those individually or do you rate those as a

family of ten?

That's mine.

MR. PATTERSON: The units in IEEE beyond

a certain class of ratings, you're require to test 100

percent of the products.

MR. BALDUCCI: Okay.

MR. PATTERSON: By standards. Those

products, if there were ten units being manufactured

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that were virtually identical, are still looked at as

though they were one unit.

MR. BALDUCCI: Okay.

MR. PATTERSON: Phil's going to address

this probability, this six percent/ten percent limit

and what it means to the industry. So I'll defer that

to him.

MS. EPPING: Kathy Epping.

Do I correctly understand you that you're

saying that each one gets an individual rating?

MR. PATTERSON: Each one gets an

individual rating. Now, the commercial issue of if a

unit is beyond the guaranteed losses, the guaranteed

losses, how that is handled commercially is where this

percentage comes into in the standards.

MR. HOPKINSON: Thank you, Wes.

I'm Phil Hopkinson from Square D.

The issues that Mr. Stricklett raised are

interesting ones, and we have addressed those in IEEE,

and it's a dynamic addressing issue as we talk about

it right now.

Going back over the years, the IEEE

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standards for six percent loss tolerance on total loss

and ten percent loss tolerance on no load loss were

set up as the presumptions for performance by a

manufacturer to guarantees of losses that were made to

a customer between a producer and a buyer of the

product.

If a transformer would exceed the no load

loss by more than ten percent, it didn't fundamentally

get thrown away, but it did require some financial

transaction between the manufacturer and the purchaser

of the equipment.

Well, then they raised the question of,

well, okay, what about the nominal requirement? Well,

it turned out that in the literal interpretation as

the standard was published and has been for years and

years, required that a shipment of transformers meet

the guarantee.

Well, what's a shipment? Well, that got

a lot of different interpretations. Some viewed it as

a truckload. Some viewed it as a month's production.

Some viewed it as a quarter's production. Some used

a whole year's production. After all, most of the

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transactions between manufacturers and utilities were

consummated over a blanket period or a year's period

typically.

So over that blanket of a year, it was

reasonable to consider that the whole year's

population was the shipment and, therefore, that any

financial transaction and any requirement for the mean

of the population should be done over that period.

Well, but then the purists came back and

said, "Well, wait a minute. This six percent, ten

percent, the so-called cutoff limits to the mean,

doesn't really have any statistical validity,

especially as it is being used and applied in the

industry today. It really needs to be rewritten

altogether."

And, in fact, that' s what's going on right

now. The requirements are being modified and will go

to a more statistically relevant sampling basis, much

as Oskars has prepared and we also have included in

the NEMA TP-1 document.

So I think that the original intent of the

loss tolerance was not as it has been used in recent

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times, but I do think that variability of ten percent,

plus and minus, on no load loss is something that was

reasonably representative of where the industry has

been performing in the past, and so that it gives us

some clue as to what the standard deviations are going

to work out for the different types of products that

we have in our arsenal of transformer products that

are considered distribution transformers today, and as

we sharpen up those numbers for the different types of

construction, then we'll have an ability to sharpen

what should be the statistical means and cutoff limits

and so on for the population.

MR. BALDUCCI: Thank you.

MR. PETERSONS: Could I just?

MR. BALDUCCI: Sure.

MR. PETERSONS: I'd like to respond to Mr.

Patterson's comment. On page 23, second paragraph or

first full paragraph does address what should be done

when all units are tested.

MR. BORST: John Borst, ABB.

Just to add a little clarification to what

Phil talked about on the ten percent/six percent

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tolerances, the basic IEEE standard that is out for

ballot right now retains the ten percent tolerance on

no load and six percent on total loss, but it only

applies to the individual unit. All reference to

multiple units, shipments, orders has been dropped.

The feeling was from the IEEE perspective,

was that those tolerances there were to deal with

manufacturing variability of a single unit, and that

any dialogue on groups of units were really commercial

considerations between the user and the producer, and

as Phil quite appropriately pointed out, the ten

percent/six percent limit is not an absolute limit.

It's a point of dialogue between the user and the

producer.

So that's where that standard is headed.

It's out for ballot currently, and if that is

retained, then the multi-unit requirements will be

dropped from the ANSI standard.

MR. BALDUCCI: Do we have any other

further questions or comments regarding this issue?

Clarifications?

Why don't we then press on to the next

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topic, which is the measure of energy consumption?

MS. EPPING: The established ANSI/IEEE

standards use losses as the rated measure of

performance, and NEMA TP-1 uses transformer efficiency

at specified loading levels as the measure of energy

consumption.

DOE at this time believes that this method

is preferable because it allows manufacturers to use

tradeoffs between load and no load losses and because

efficiency at appropriately selected levels provide a

better estimate of energy consumption.

For test procedures, this topic should

only be significant with respect to the calculations.

All measurements, corrections, conversion to reference

temperatures and processing of statistical analysis

will be performed using loss data.

So we'd like to know if there are any

strong reasons why efficiency should not be used, and

if any other measures of energy consumption should be

considered, such as loss power normalized, and whether

or not reporting efficiency losses at reduced loading

levels would be the way to go.

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So I'll let NEMA speak now.

MR. BORST: John Borst, ABB, representing

NEMA.

Since transformer losses include both

fixed and variable components, the use of efficiency

as the preferable measure of energy consumption is

considered appropriate by NEMA.

NEMA does not see a need for additional

measures of energy consumption, such as loss power

normalized relative to output kVA, and reporting

efficiency at reduced loading levels is considered

appropriate by NEMA.

MR. BALDUCCI: Thank you.

Is there any questions or comments with

regard to that? That's too -- oh, we've got one. I

was going to say that's too easy.

MR. BOHLK: Not in particular, but I have

a question.

MR. BALDUCCI: State your name, please.

MR. BOHLK: Jim Bohlk, RUS in Washington.

Not in particular to that, but the general

question of measurements of efficiency. I do believe

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that efficiencies are a very good number and very

useful number, especially for labeling.

However, I don't really see a practical

application as we like it to be used. RUS presently

advocates that their borrowers purchaser transformers

on a bid rate based on the A&B factor and the total

owning cost, if you will, as published and explained

very nicely in the October 22nd Federal Register

notice.

It is important then that manufacturers

and purchasers be aware of the load, no load, and

total losses and, of course, the first price, and this

is the basis of the purchase.

Again, I think this is very important.

RUS advocates the use of this methodology. We will

continue to advocate the use of this methodology, and

we don't really particularly see a useful application

for what we're looking at for publishing efficiencies.

MR. BALDUCCI: Other comments or questions

regarding the energy consumption measurement where DOE

is proposing using efficiency?

MR. HOPKINSON: Phil Hopkinson, Square D.

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Reporting at this time just to the issue

raised about A&B factors and no load and load loss, in

the considerations for the development of TP-1, we as

a NEMA organization addressed the question of whether

we would go for specific watt loss levels or try to

get something that was a more general term, like

efficiency.

Well, there were a lot of factors of

consideration. One of them was the fact that there

are many types of manufacturer of transformers. There

are transformers that are core type, which means two

coils, one core. There are transformers that are

shell type, which means one coil, two cores for single

phase.

There are transformers that use stacked

core. There are transformers that use wound core.

There are transformers that have various kinds of

windings, disk windings and layer windings and others.

And out of that, the concern that we had

was we wanted a parameter that would tell the end user

the performance that he would expect to get at the

nominal usage level of the transformer, but we wanted

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that to be not a discriminatory clause that would

unduly put certain types of manufacturers or types of

constructions under pressure, competitive pressure,

which would make them no longer salable in the

industry when, in fact, they are a very fine product.

So efficiency became the very best measure

that would do that because it does communicate what

the transformer would expect to be delivering in total

watts loss consumed at the nominal usage level.

And in determining efficiency, in the work

that we did in NEMA to develop TP-l, we also did very

careful consideration of how transformers are used,

what types of loads are on them, how variable they

are, and tried to get to an RMS equivalent loading

that would represent the lowest common denominator of

what the industry usage of those products are, so that

the TP-l document is a pretty good reflector of

efficiencies and, therefore, of end performance, and

I think that it does address the other kinds of

parameters for how one could establish a metric or a

measure of energy consumed.

Thank you.

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MR. BALDUCCI: Thank you very much, Phil.

MR. LEVY : This is Ed Levy from DOE again.

I wanted to ask the gentleman, I believe,

from the Department of Agriculture are you suggesting

that the department should use something other than

efficiency as a measure of energy consumption?

MR. BOHLK: No, not at all. I didn't mean

to imply that. I did not want to lose the option of

purchasers to be able to use the A&B formula, if you

will. So both would be fine with me. I just don't

want to lose the first.

PARTICIPANT: We agree with that.

MR. LEVY: Thank you.

MR. BALDUCCI: Thank you.

Any further questions, comments, regarding

the selection of measure of NG consumption?

(No response.)

MR. BALDUCCI: It is 20 of 12 right now.

How is everyone feeling regarding lunch? Do we need

to break now or do we want to press on?

(Laughter.)

MR. BALDUCCI: Or we can knock off the

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next one, which is the burden imposed by industry by

additional testing and data processing. Why don't we

try and go through that?

MS. EPPING: We've gotten from various

sources that there's some concern expressed over

significant burden to particularly small manufacturers

posed by the testing requirements. So we'd like to

know from you what anticipated difficulties you see,

and we'd like some suggestions on solutions to

addressing these difficulties.

And we'd also like to know what specific

requirements in the draft test procedure document are

causing these difficulties.

MR. GAUTHIER: John Gauthier from NEMA.

NEMA's position is basically compared to

current practices, the imposition of this mandatory

requirement contained in any DOE regulation will

result in increased burdens for manufacturers large

and small.

Additional equipment may be required to

comply with the mandates of this regulation. The

effort will be directed toward meeting the three

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percent test tolerance for loss measurements.

Approximately 200 distribution manufacturers, both

liquid and dry type, must up grade their testing

equipment.

New measuring equipment is available that

will meet the specification -- is available. It is

hoped that NIST will provide the small manufacturers

guidance on the changes necessary.

Our experience in other areas involving

mandatory regulation has been that reporting is

increased and record keeping poses an additional

burden.

Additionally , NEMA recognizes the need to

address the following burdens: need to meet both old

and new versions of standards, that is to say that DOE

test requirements identified in an old version of the

standard that has been superseded.

Two, labeling requirements.

Three, third party certification

accreditation.

MR. BALDUCCI: I do have -- this is

Anthony Balducci again -- I do have a specific

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question regarding -- and this goes back to an earlier

comment by Wes with regards to 100 percent testing.

You're talking these additional burdens.

With test equipment how would that be different than

what's being performed now by the manufacturers?

MR. PATTERSON: The requirements for the

accuracy of the equipment may result in additional

equipment having to be purchased and obsoleting

existing equipment. So we'll have to make a capital

change in the buildings. So that's a burden.

And for some of the manufacturers, some of

the larger manufacturers, it's maybe not as big a

burden as it is for a lot of smaller one. I think

that was the point that we were trying to get at.

MR. LEVY: This is Ed Levy again.

I have a question. In light of the fact

that DOE is discussing adoption of the existing

industry standards, how does the burden result?

MR. GAUTHIER: John Gauthier.

The key thing here is that when we issue

a standard as a voluntary -- on a voluntary basis, we

cannot deny an industry manufacturer -- we cannot

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write a standard that will deny anyone access to the

marketplace. A regulation issued by the government

can do that.

And that imposes -- when you issue a

requirement for certain levels of test, if it's not

available, it then poses an additional burden on the

manufacturer to have that.

Again, the key element here is market

force, the market placing demand on the manufacturer.

The manufacturers do what their customers want, but

when the government imposes a requirement, that is a

little different.

MR. LEVY: So let me just ask a follow-up

question.

MR. GAUTHIER: Sure.

MR. LEVY: So are you suggesting that

there are differences among manufacturers in the

amount of testing that they conduct and in the rigor

of their testing?

MR. GAUTHIER: Oh, absolutely, absolutely.

MR. PATTERSON: Oskars has had a problem

with the industry standards when he first came into

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this thing between the liquid standards and the dry

standards. The requirements for the accuracy of the

measurement between these two groups is fundamentally

different, and he's always had a problem with it.

So he wants to move everything to the

liquid. Well, the reason why there's a liquid and a

dry is they are different markets, right, servicing

different industries.

Now, sometimes they overlap, but by and

large they don't. So there were fundamental

differences in the commercial side of the system, but

we're trying to normalize that with the government

regulation.

So that's going to create just by itself

an increased burden on the dry manufacturers.

MR. LEVY: So to put it a little

differently are you saying that the different markets

demand different degrees of testing, different amounts

of testing?

MR. PATTERSON: The different markets --

some of the requirements for the markets, yeah,

they're different, yeah. They require different ways

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1 of looking at the game.

2 MR. MOREHART : Gene Morehart, Acme

3 Electric.

4 The answer to your question , right now 601

5 volt transformers below 500 kVA do not require any

6 loss measurements by industry standards. As a matter

7 of fact, if you read those standards real close, that

8 line of transformers is not even included in those

9 standards.

10 So that's another reason why it will be

11 necessary to put ST20 in there as a reference.

12 MS. EPPING : Kathi Epping.

13 I have a question to you. If we make

14 different requirements for both liquid and dry, and I

15 understand your reasoning on why we might want to do

16 that, is there a problem with treating the two

17 unfairly that you're preferring -- giving preferential

18 treatment to one or the other? Is that a concern?

19 PARTICIPANT : What's your question?

20 MS. EPPING : If we have different testing

21 requirements for both the liquid and the dry

22 transformers , would that create any sort of problem

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that people who manufacture liquid transformers or dry

transformers would think that we were -- there were

less stringent requirements on the other group?

Does that make sense?

MR. McCABE: This is Michael McCabe.

Let me just add to it. Assuming that they

are both -- the notice says where they are going

towards the same market. Would that give one a

competitive advantage over another?

PARTICIPANT: It might.

MR. PATTERSON: Potentially it might.

However, the two products are fundamentally different

products. When we look at just -- although it's not

part of this meeting, when we look at establishing the

limits, the criteria that the unit would have to meet,

you know, the very first simplistic pass is, well, if

it's a 1,000 kV unit, we'll just make it 99 percent

efficient whether it's a dry or a liquid. Who cares?

Well, they're fundamentally different

products, and if you were to make that move, you'd

just wipe out an entire market, plain and simple. Is

that the intent of the organization, to wipe out a

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market?

On this particular question, the question

was: are there burdens on the industry? Can we

identify burdens on the industry?

All we're trying to do is state there is

a distinct burden on the industry by the requirements

for the accuracy of the measurement which is now

different than what is out there in the marketplace

today. We're just trying to illustrate that it's

there.

MR. LEVY : Do you think that we should try

and replicate what's in the marketplace with regard to

the accuracy of measurement?

MR. PATTERSON: Again, if you're asking me

my opinion, my opinion is that the industry has been

quite good at policing itself in respect to efficiency

over the years. So I don't believe that the

government coming in and telling us what the industry

has been doing all along is buying us anything.

That's my own personal opinion. Okay?

MR. BALDUCCI: Hold on one second.

MR. PETERSONS: Could I respond on, well,

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my concern on accuracy situations in the measurement

of dry type transformers?

There was no accuracy requirement at all

for measuring losses of dry type transformers. If

there is no accuracy requirement, measurement by

itself is an undefined sort of operation. You can be

15 percent out. It would be very difficult to

enforce.

So I pushed very strongly in working

groups to introduce similar table also, accuracy

table, for dry types. My understanding is that the

next division this is or will be accepted nearly as

for liquids, except for temperature measurement, and

there is apparently one negative vote.

So primarily I was pushing that there is

some accuracy for dry type measurements. To me loss

measurements in dry or liquid type situation I don't

think is any more burdensome accuracy-wise.

MR. ROLLING: Dave Rolling from Cooper

Power Systems.

Two quick comments. First, I believe here

would be some concerns if you would make different

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testing requirements for different types of products,

which I believe could be more fully discussed in

individual manufacturer comments which follow this

meeting.

And, secondly, I don't believe it's a

discussion for this meeting, but I presume in the

future we will discuss differences in people's

conceptions between liquid immersed and dry type

transformers, but since this is just a test meeting,

I don't think that's a topic for today.

Thanks.

MR. BALDUCCI: Any other questions,

concerns or comments regarding the potential burden

imposed on industry?

I would encourage those who are reluctant

to speak now to submit comments in writing with

regards to that. The more data you give us that you

can cite, the better off we are and can be able to

answer those questions and concerns.

Seeing the time, how does everyone feel

about -- I'm sorry.

MR. LEVY : Also, I'd expand upon that just

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a little. It's not just a matter of reluctance to

speak, but people get ideas as a result of

contemplating what's said here. We'd like to hear

that, too, you know, responses or amplifications,

agreements, disagreements. You know, that's part of

the purpose of having the written comment, is to give

people an opportunity to follow up on what's said

here.

MR. BALDUCCI: Thank you very much.

Yeah, and I'd like to reiterate that.

That goes for all the topics, as well. If you get

home tonight and have a revelation about the way we

should do something a little bit different, feel free

to write us and tell us.

Again, as we discussed earlier, if you

agree or disagree, it's good to hear from both sides.

Any other questions or comments? How does

everyone feel about taking a one hour break for lunch

about now?

It's five of 12. Why don't we try and

meet back here at five of one?

Again, the cafeteria is in the West

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Building. If we can kind of work our way over there,

it's easier to go underneath than across, and also

there are restaurants up in L'Enfant Plaza, and for

those of you who are daring, we do have the street

vendors selling hotdogs, as well.

(Laughter.)

MR. BALDUCCI: See you in one hour.

(Whereupon, at 11:56 a.m., the workshop

was recessed for lunch, to reconvene at 1:00 p.m., the

same day.)

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A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

(1:01 P.M.)

MR. BALDUCCI: Welcome back, everyone. I

guess we can get back into it.

Before we go on to the next topic, there

was a request from the gentleman from Canada. Dave

wanted to talk about with regard to the measurement of

energy consumption and what they have found at CSA.

MR. WIEGAND: Thanks, Anthony.

Just a very few --

MR. BALDUCCI: Could you give for the

record your name?

MR. WIEGAND: Oh, Dave Wiegand. I'm from

London, Ontario in Canada. If you don't know where

London is, it's halfway between Toronto and Detroit.

(Laughter.)

MR. WIEGAND: So people there, some of

them are Tiger fans. Some of them are Blue Jay fans.

Okay. So I was actively involved in the

CSA C802 standard that got developed in Canada in 1994

on maximum losses for transformers, and I just wanted

to comment in general about what I'm finding here with

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studying the losses from the C802 standard, which are

maximum losses, and how they compare with NEMA losses

when they are put into a 50 percent loading situation.

I've done some spreadsheet calculations

more or less to get my mind in gear on this, but I

would be pleased to send copies to anyone interested,

but the relationship is very, very close both for

liquid filled transformers and dry type.

In fact, it makes me wonder, well, the

people that drew up the NEMA losses, were they looking

at our standard for maximum losses, but anyway, why

did we pick maximum losses instead of efficiency when

the pursuit in itself was for greater efficiency in

transformers?

It was largely related to the commercial

aspect of the transformer business that we were in.

We were dealing mainly with electric utilities when it

came to transformer losses, and so the electric

utilities were purchasing on the basis of total

ownership cost.

So it seemed rather natural since they

were all looking very closely at no load and load

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losses as part of the guarantee that that be

incorporated into some way of going toward higher

efficiency in transformers.

Another part about it was that we

recognized that transformers by their nature have

always been efficient, whether manufactured in 1910,

1940 or 1990, and so when we talk about improving the

efficiency of a transformer, it's like going from 98

and a half percent to 99 percent.

In other words, the changes aren't all

that dramatic at first sight, and on the other hand,

when we're looking at losses alone, the changes very

definitely are dramatic.

For example, a 100 kVA single phase

transformer in the 1960s had a no load loss of 340

watts, and now under the influence of loss evaluation

formulas and the like, that no load loss is more down

around 220 watts or thereabouts, and similarly when it

comes to load loss, there have been quite dramatic

changes.

So it was looking in a practical sense

22 11 that we opted for that, but that doesn't mean that

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1 it's cast in stone, and having done the analysis of

2 comparing these C802 losses converted into efficiency

3 at 50 percent load, comparing it with the NEMA

4 efficiencies, they're very, very close, especially if

5 I was to make some corrections to compare apples with

6 apples.

7 So I just wanted to indicate that I will

8 be going back to Canada and casting a vote in favor of

9 efficiency as the way of going. We're all interested

10 in harmony. So --

11 (Applause.)

12 MR. WIEGAND: Just so you would be aware

13 of it.

14 MR. BALDUCCI: Thank you very much, Dave.

15 MR. GAUTHIER: Dave, just a comment.

16 John Gauthier.

17 With regard to your interest in harmony,

18 we'd like to propose to begin talking about

19 standardization between Canada and the United States

20 and Mexico for a single tri-national standard on

21 energy efficiency. We'll be in touch with you.

22 MR. WIEGAND: Okay.

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MR. GAUTHIER: Is that okay, guys?

(Laughter.)

MR. BALDUCCI: Great. Harmony is

wonderful.

Now we're going to go into the toughest

part of the day because it's the afternoon session,

and hopefully everyone can remain awake for the next

three topics.

The next one is the reference

temperatures. As I know nothing of this -- I'm

thinking ambient temperatures, which I know is

completely incorrect -- I'm going to turn it over to

Kathi and let her talk about that.

Thank you.

MS. EPPING: The reference temperature

stated in the cited documents are somewhat

inconsistent with respect to reference temperature.

What we're considering is specifying -- that looks

better -- specifying a 20 degree temperature for no

load for both dry transformers and liquid immersed.

We're also at this point favoring using a

single reference temperature of 75 degrees for no load

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or, rather, load losses of liquid immersed or did I

say that wrong? For dry type, and then 55 degrees for

the liquid immersed.

So we would like your comments on these

reference temperatures, if you think that they're

reasonable or not.

MR. COULSON: Lake Coulson with NEMA.

NEMA's position on this, specifying a

reference temperature of 20 degrees Celsius for no

load losses, is considered appropriate by NEMA. It is

anticipated that C57.12 and C57.12.01 will be

harmonized to that value in the future.

NEMA is in agreement with reduced

reference temperatures for load loss, but has no

comment on the specific values proposed at this time.

MR. HOPKINSON: Phil Hopkinson, Square D.

Just following up on Lake's comments on

reference temperatures, for liquid and for dry as a

company position for Square D and not for NEMA, then

it is our belief that 75 degrees represents the load

loss reference temperature for medium voltage dry type

transformers.

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We believe that 55 degrees C. represents

the reference temperature for liquid filled

transformers. We believe that 55 degrees also

represents the reference temperature for a low voltage

dry transformers.

Just to give a little more background, the

low voltage dry type transformers, when we thought

back as to what happened and why we got to 75 degrees,

as the evolution of TP-1 came along, the fact is that

we had been using a higher loading assumption on low

voltage dry type transformers up to the point of

establishing the tables, and it was after we collected

some data showing the kinds of loads that exist on

those transformers that we realized at a later time in

the evolution of that standard that 50 percent load

was not appropriate for low voltage dries that a lower

-- loading presumption prevailed, and that 35 percent

load was most representative.

However, we failed to go back and change

the reference temperature for the document so that

that one actually sits up there a little high. Okay?

MR. ROLLING: Dave Rolling, Cooper Power

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Systems, in this case speaking for Cooper Power

Systems.

Prior to this meeting, I had gone and

looked at some of our thermal test data for liquid

immersed transformers as they would be running at 50

percent load, and based on that, an appropriate

reference temperature would be down below 55, down in

the area more of 45 for those types of transformers

that were meeting TP-1 type efficiencies or better.

MR. BALDUCCI: Any further questions or

comments regarding the reference temperatures for dry

and liquid immersed transformers? Clarifications?

So pretty much in agreement with the no

load. It's just the load that we need to investigate

a little bit more.

Seeing that, our next topic is the

measurement corrections. Kathi, again I'm going to

ask you to take that one.

MS. EPPING: The requirements in test

codes C57.12.90 and C57.12.91 differ with respect to

the corrections for measure losses due to the phase

angle of the test equipment and the correction that is

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required for liquid immersed transformers, but it's

not applied to the dry type.

DOE believes at this time that the

corrections should be applied to both types of

transformers using an algorithm and C57.12.90, as well

as the guidance describing when the correction should

be applied.

Similarly, the department is inclined at

this point to propose no load losses of dry type

transformers be corrected to a reference temperature

of 20 degrees if it's measured at a temperature

significantly different.

And we would like your comments on whether

these corrections are appropriate, and if it's

appropriate to apply the corrections used for the

liquid to the dry type transformers.

MR. HOPKINSON: Phil Hopkinson, Square D,

speaking for NEMA.

Corrections for low power factor

measurements may be necessary for both liquid filled

and dry type transformers. TP-2 provides a

methodology in Section 4.1.4. Generally speaking, the

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highest power ratings with the highest impedances will

have the lowest load loss power factors.

A TP-1 compliant 2,500 kVA dry type

transformer at eight percent impedance will have a

load loss power factor of about nine percent, as

measured, while a liquid filled transformer of the

same rating that also meeting TP-l will have a load

loss power factor of about 6.5 percent.

Dependent on test set error, a correction

may be needed for both types of transformers. For

both cases power factor corrections would be needed if

total test error exceeds one minute.

No corrections are necessary for no load

loss, for core loss, in other words, if temperature is

with ten degrees of the 20 degrees C. reference

temperature.

MR. BALDUCCI: Questions or comments

regarding the measurement corrections for -- Wes.

MR. PATTERSON: This is a thought I

haven't shared with NEMA before, but it just dawned on

me.

22 11 MR. BALDUCCI: That's fine.

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1 MR. PATTERSON: With respect to the no

2 load loss at 20 degrees C., when you say that the

3 temperature of the losses must be corrected to 20

4 degrees C. if the core is not 20 degrees C., the

5 implication there is you know what the temperature of

6 the core is. How are you going to establish

7 temperature of the core?

8 MS. EPPING: Oskars?

9 MR. PETERSONS: From history of ambient

10 conditions, I am fully aware that temperature

11 dependence of core losses is very small. If you put

12 these plus/minus ten degree limits, that's just -- you

13 ought to be able to know ambient temperature within

14 those limits, and if it is not significant, you don't.

15 If there is situation where your ambient

16 is perhaps above 30, between 30, 40 degrees, I think

17 crude correction would be reasonable.

18 MR. BORST: John Borst, ABB.

19 I think Oskars' point is right. The

20 degree of correction for no load losses, it's a very

21 weak function of temperature. So you're not making a

22 large correction, and the plus or minus ten degrees,

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I believe that's consistent with what's in the ANSI

standard, that basically if you test within a certain

range of ambient, then you're not required to make a

correction. There's a methodology for making a

correction. It ought to apply as well to liquid or

dry.

Wes' point is very clearly correct. In a

manufacturing process, you don't have a precise

measurement on the average core temperature, but I

think most of us at least in the high volume

operations have a pretty good feel at least in the

liquid world because we've introduced a liquid, and

we've introduced it at a certain temperature, and

we're testing within a certain period.

So I think we're pretty comfortable with

it in the liquid world.

MR. PATTERSON : In the dry world, there is

a process where the unit may be put through an oven

cycle, okay, and when the unit comes out of the oven

cycle, at some point in time you need to measure the

core loss, okay?

The problem with the no load loss

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measurement is as the temperature goes up, the losses

are higher, correct?

PARTICIPANTS: Are lower.

MR. PATTERSON: Are lower, are lower.

And when the unit comes out of this oven,

in order for it to stabilize back to an ambient, it

may be 24 hours; it may be 36 hours. So you're going

to take this potentially 40, $50,000 worth of

inventory and let it sit in your building for a day,

two days, trying to get it back to an ambient unless

you measure its temperature.

And then the question becomes where do you

measure the core's temperature at. Do you measure the

top temperature, the bottom temperature, side

temperature? Can you get underneath the coals? How

do you establish what its temperature is given this

process, or do you just let it sit in your building

and then absorb it?

And then if you do, that goes back to the

burdens on the manufacturers. That's going to

increase our carrying cost.

MR. BORST: John Borst, ABB.

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Wes' points are absolutely correct. The

standards process, we deliberately left that somewhat

ambiguous because, again, the correction is.small, and

we've left it to the manufacturer to determine for his

processes what type of temperature to expect, and I

believe what people have done is they've done some

statistical studies to, you know, measure multiple

points and get an average temperature and then have

some means of either monitoring a particular part on

the core or time or some other algorithm so that they

have an algorithm of knowing what the temperature is

at the time of test.

They don't wait. As you say it would be

very costly and inefficient to allow the unit to go to

ambient temperature. I mean, you always have that

option obviously, but most people have some sort of an

algorithm in place that allows them to estimate the

temperature at the time of test, and that may involve,

you know, one measurement at one point, and there's a

calibration to what the average is.

So, you know, if you don't have that in

place, you're going to have to develop some defensible

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1 algorithm.

2 MR. PATTERSON: This is just illustrating

3 the differences, again, between the dries and the

4 liquids. When the dry is operating, in the

5 operational mode even on an 80 degree C. rise

6 transformer, this transformer core is going to be

7 upwards of 120 degrees C. in operat i on.

8 Now, when we are testing, we are testing

9 the no load losses somewhere in the range of from 80

10 degrees C. to 20 degrees C., but in its operational

11 mode when it's installed, it's going to be running at

12 over 100 degrees C. So we are always on the safe

13 s i de.

14 Now, to require us to hold this thing in

15 inventory for no particular gain in the marketplace

16 doesn't make a lot of sense.

17 Now, John's comment about having

18 algorithms to establish what this core temperature is

19 is true in a high volume, repetitive type business,

20 but in a customized business where you're building one

21 and the variety is changing dramatically in scope from

22 one unit to the next, these algorithms don't hold up.

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This is just illustrating the differences

that we have in these processes, in this product

scope.

MR. BALDUCCI: Further questions or

clarifications?

Wes, in your comments, I would hope that

you would address not only this problem, but a

suggestion for a solution to how the department should

handle that.

MR. PATTERSON: My suggestion on handling

it is that the temperature rise for the core, the

reference temperature for the core should be

reflective of the installed condition. Okay?

Now, if the installed condition is going

to be 100 degrees C. on the core, that's where our

reference temperature for the core should be. It

should not be sitting at 20 degrees C. because the

core is never going to be at 20 degrees C. in that

environment anyhow.

MR. BALDUCCI: Okay.

MR. PATTERSON: It's an issue that needs

to be addressed.

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MR. BALDUCCI: Okay.

MR. HOPKINSON : Well, Phil Hopkinson from

Square D.

I certainly can agree that the core is

going to be operating pretty much as Wes indicated.

So if the intention all the way around is to get

losses as the transformer is to be used, then truly

the best place to get the losses is to take a higher

reference temperature than 20 degrees C. for core

loss.

And that will result in somewhere between

four and five percent lower losses of core at the

operating temperature than it would at the 20 degrees

C.

MR. BALDUCCI: I'm thoroughly confused,

and that probably means we've beaten this one pretty

good. Any other questions or comments with that?

Oskars.

MR. PETERSONS: Well, apparently for

liquid immersed transformers this has been a decade

long debate, what should be the reference temperature,

and I'm sure some of these arguments were voiced

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there, and they did agree to standardize it as ten to

20 degrees C., and if it is sort of left completely

open, then we again have possible measurement

uncertainty of, well, five, six percent of losses.

I mean how can you -- is it possible

really to standardize at this high a temperature? Do

we know the right temperature? Is it not possible

really to measure that ambient after it is wound? You

have to intimate and so on.

MR. BALDUCCI: Wes. Thank you.

MR. PATTERSON: For the purpose of this

meeting, I just think the point was to illustrate the

problems, not to come up with the solutions, and we

can have other dialogues to arrive at the solutions

that are needed.

MR. BALDUCCI: I have one question. This

may be out of sheer ignorance. You mentioned earlier,

Wes, that you never know the temperature of the core,

correct, if you're going to test an ambient? How

would you know then the temperature of the core at

operating temperature?

MR. PATTERSON: There's a manufacturing

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process that the units go through that are -- they're

controlled, but they're not reflective of the

installed condition.

MR. BALDUCCI: Okay.

MR. PATTERSON: Now, when I put the unit

in service, we know through calculation exactly what

those temperatures will be in service, and our

manufacturing processes are typically running these

things at a lower level. Okay?

So we are always producing a unit that is

on the safe side. Now, in my particular experience,

what has been happening is if we had a guarantee on

the no load loss and we measured the thing and it

didn't pass, we'd let it cool down. It was to our

economic advantage to tie it up in inventory. So we

would let it cool down. Okay?

But if it passed hot, okay.

PARTICIPANT: The other way around.

MR. PATTERSON: The other way around.

MR. BORST: If you would know the

temperature, you could do a precise correction, and

then you might get --

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MR. PATTERSON: And the temperature

measurement -- folks, the temperature measurement on

the dry historically has been top core temperature,

historically because you can get at it. You're using

that as your reference point.

Whereas in a liquid filled unit, you're

assuming that the unit is stabilized. So you're

looking at the oil temperature or the average

temperature of the unit coming down the line. It is

a fundamentally different process.

But in any case, the details of the

problem, this is a problem that is different between

the liquid and the dry, and it's one of those issues

that needs to be worked out.

MR. BALDUCCI: Thank you.

MR. BORST: John Borst, ABB.

One of the historical reasons that it's

different is because liquid filled transformers became

subject to loss evaluation sooner than dry type

transformers, and actually, you know, that's not real

prevalent in dry type transformers today, and before

the correction was put in, no load losses were

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measured at whatever temperature, and that was the

value.

But as the value of no load losses

increased to higher levels, some manufacturers were

astute enough to figure out that you could manipulate

-- a poor choice of words --

(Laughter.)

MR. BORST: -- you could come up -- you

could come up with a different end result if you were

to take into account temperature, and that forced the

industry to address a standard correction method and

a standard reference temperature, and so that's why it

evolved in liquid filled and has not evolved to that

point in dry type, because loss evaluation has not

been as prominent in dry type.

MR. PETERSONS: A hypothetical --

MR. BORST: Historical.

MR. PETERSONS: -- for 35 percent loaded

dry type transformer, who would prevent then operating

the transformer at full load for 24 hours and

measuring losses then? They would be lower, I mean,

if you don't specify.

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MR. BORST: That loophole exists, I

presume, since there's no specification of where

the -- currently there's no specification at what

temperature the no load loss test is done, and there's

no correction method theoretically currently.

So you're right.

MR. PETERSONS: My purpose is to --

MR. BORST: Establish --

MR. PETERSONS: -- significant loophole

that we really should try to close.

MR. BORST: Right, and I think Wes' only

point is -- well, one of his points is should it be

representative of operating conditions or not. I

think the IEEE position was it's such a weak function

of temperature. Let's leave it near ambient, and that

was primarily driven by power transformer influence

because most power transformers are tested when they

are near ambient temperature.

So let's don' t do a big correction, and

actually for liquid filled distribution transformers,

it' s probably a toss-up as to whether you're closer to

the 100 percent or the unloaded position.

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MR. BALDUCCI: Thank you.

Any other further questions or comments

regarding this temperature correction?

(No response.)

MR. BALDUCCI: Seeing none, we're on to

our last topic, which is quality assurance.

MS. EPPING: C57.12.00 provides the table

of measurement uncertainty tolerances, and it's my

understanding that C57.12.01, which is currently in --

has a revision that's in the process of being

reviewed, I understand, is considering using these

tolerances as well.

So at this time, DOE is considering using

these tolerances and make them applicable to both

types of transformers. I believe it's now done for

just the dry type transformers, and we're considering

doing them for the liquid as well.

So we'd like to know if you have any

concerns about applying these measurement accuracy

requirements to the dry type transformers as it's now

being done for the liquid, and we're also considering

including a clause from ISO 9001 for guidance to give

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people who might want to know how they implement the

requirements of 12.00. They could use the guidelines

in ISO 9001 to implement these procedures.

MR. KLINE: I'm Don Kline of Southern

Transformer Company. I'm giving the NEMA response to

the question on quality assurance and testing.

NEMA does not have any concerns about

applying the measurement accuracy requirement for dry

type transformers as is now done for liquid filled

transformers, nor does it include any concerns about

the application of the ISO 9001 measurement quality

assurance program.

As Kathi mentioned, IEEE is in the process

of revising C57.12.01 and C57.12.91 to include the

liquid test tolerances in the dry type transformer.

Now, Section -- okay. The proposed NEMA

standard, TP-2, standard test methods for the

measurement of energy efficient -- energy consumption

of distribution transformers, is written to establish

the test procedures for distribution transformers for

the measurement of losses. The standard will place a

large responsibility on the manufacturer to certify

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that the loss measurements meet the efficiency

requirements of any efficiency standard that might be

adopted, such as NEMA TP-1.

Section 7 of TP-2 includes the testing

quality control requirements, and this indicates that

the test -- this specifies the test methods and the

record keeping.

Loss measurement in TP-2 for both liquid

and dry type transformer specifies the loss

measurements shall be within three percent of the

total losses. At first blush, three percent sounds

like a wide margin.

However, this seems wide until you take

into account the lost test power factor, the power

factor of the actual test at the room temperature.

Take, for instance, a larger liquid filled transformer

or dry type transformer for higher impedance, just say

at 1,500 kVA at eight percent impedance. The losses

of load loss as measured by the test is only five

percent of the total kVA that the test set sees.

We're only measuring five percent of the total kVA.

So the three percent requirement now

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becomes not three percent, but .15 percent. The

accuracy of the overall test now must be .15 percent,

which is very, very tight.

Now, a distribution transformer, the

smaller distribution transformers have a loss

measurement, loss power factor of about 20 percent.

So in those applications, the test set will have to

have an accuracy of the three percent times .2, or .6

percent.

Now, that .6 percent is much broader than

the .15 percent for the larger distribution

transformers.

Now, this up to now, a limited range of

small general -- now, many distribution transformer

manufacturers do not have both liquid filled and dry

type, both, not just dry type, but liquid and dry; do

not have the test facilities to accurately measure the

losses for the low loss transformers as we are talking

about today.

Most of these manufacturers are looking

for ways of improving their test facilities just for

their own individual application, as well as for any

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future application for the DOE.

So what we are suggesting is that adequate

time be allowed for all manufacturers to update their

test equipment to meet requirements of NEMA TP-2 or

whatever standard that DOE adopts.

MR. BALDUCCI: Thank you.

Any questions or comments?

Clarifications?

(No response.)

MR. BALDUCCI: Everybody must have had a

really good lunch because everybody is starting to

doze off on us.

MR. KLINE: I have a personal response.

MR. BALDUCCI: Microphone, please.

MR. KLINE: I mentioned that there is a

need to update many of the -- the small transformer

manufacturers to update their equipment. In the past

two years, Oskars Petersons has given me some

suggestions on how a small transformer manufacturer

can do it, and I have done it for Southern Transformer

Company.

22 11 I trust and urge that DOE sees fit to have

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Oskars Petersons continue with his effort to aid all

transformer manufacturers in updating their equipment,

calibrating and updating their equipment to meet these

standards.

I'm putting in a plug for you, Oskars, and

also a personal thanks.

MR. BALDUCCI: Thank you.

Any other questions regarding the quality

assurance and testing?

(No response.)

MR. BALDUCCI: According to our agenda,

we're done with regards to topics. Is there anything

else anyone wanted to talk about with regards to the

proposed test procedures or any of the issues we've

talked about today or any other issue with regard to

test procedures for transformers?

MR. HOPKINSON: Phil Hopkinson, Square D.

It occurred to me this morning when the

issue came up of the six percent and ten percent

limits on core loss and of the ten percent on core

loss, the six percent on total loss, at the time we

were addressing from an efficiency standpoint those

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factors, but truly that isn't really what drove the

adoption of ten percent limits for core loss or six

percent for total loss.

The background on that I am absolutely

certain was relative to thermal considerations and the

impact on life and the ability of the transformer to

provide long life to the end consumers, so that the

ten percent was a good representative indication of

what kind of no load loss performance was in the

transformer, and the ten percent, since loss ratios

were in the range of four to one on typical

transformers, a no load loss represented around a

nominal consideration, around 20 percent of the total

losses for the transformer.

So a ten percent variation of the no load

loss didn't change the total loss of the transformer

by very much, and therefore, it didn't have a

deleterious effect on the thermal rating of the

transformer or its expected life in the field.

So I think that it was a background or a

lore of where those efficiencies came from that then

when, in the 1970s, loss evaluation techniques were

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started to be applied to liquid filled transformers,

then those same factors were continuing to be applied,

but applied now from an efficiency consideration, and

the question of acceptability from a loss performance,

did the manufacturer provide a transformer that met

the efficiency that the transformer was being

purchased to?

But really when those factors were

developed originally, it really was not anything to do

with efficiency. It was only the question of was the

transformer able to provide acceptable life.

MR. BALDUCCI: Any other questions or

concerns regarding transformer test procedures or

anything of the sort?

(No response.)

MR. BALDUCCI: As I mentioned earlier in

the workshop, we wanted to determine, based on issues

that were brought to light here, other issues that may

have sparked your interest or other issues you may

think may spark your interest, a comment period and

how long that comment period should be in relation to

what was discussed here and the material that was

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passed out.

Again, I'd like to reiterate with regard

to comments that will be submitted in writing, if you

had a strong point that you felt wasn't covered in

detail enough at the workshop, please submit it. If

you have some points that you felt were well covered

and want to reiterate them, please do. If you have

items that you come up with tonight or in the next

week or two, again, please submit it.

The more comments we receive, for and

against arguments, helps us out.

One thing I do ask with regards to the

comments. If you disagree with the way the department

has proposed something or is thinking of something in

their documents, please provide us with a solution and

rationale for that solution, as well. This way we can

defend any changes that we make.

If you just say, "Well, we think it should

be this because we think it should be this," that

doesn't really help us.

Now I guess would be an appropriate time

to discuss a comment period and how long that comment

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period would be.

I'm going to ask Kathi first off what she

was anticipating for a comment period.

MS. EPPING: Generally speaking, we would

have a comment period of 30 days, but I'm told that

that might not be long enough for the people in this

room, and I guess I need to get a sense from you.

Obviously the sooner I can get the

comments in, the sooner I can get working on putting

together the proposed rule. I would like to get them

no later than the end of March just so that I can try

to stay on my schedule, and I don't know if that's a

problem for you or not. So I'm looking for your

comments.

MR. BALDUCCI: Can we get some -- what I

just was squeaking and writing out here quickly was

the schedule of what we talked about earlier.

Right now the department - - and part of my

writing -- now I know why I wasn't a school teacher,

because I can't write well at this level -- the

department is looking at a notice of proposed

rulemaking this summer. In that will be a 75 day

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comment period and public hearing relating to the

notice of proposed rulemaking.

What Kathi is talking about with regard to

the comment period, she wants to have ample time to

evaluate all of those comments because they need to be

answered and talked about in the notice of proposed

rulemaking. So that's why we're asking what you would

feel as ample time to make comments.

Think about that for a second.

MR. ROLLING: Dave Rolling, speaking for

NEMA here.

We did discuss this yesterday when the

question came up, Kathi, and I think you said 30 days.

We said 60 days. Some follow-up conversation says we

could probably live with 45 days if you could live

with that, and again, I'm speaking for NEMA here. We

may have folks in the audience who feel differently

than that.

And secondly, we have a question that you

can address at some point here, is whether or not

there will be any additional workshops prior to the

notice, the preliminary ruling, the summer of '98.

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MS. EPPING: The proposed rulemaking.

MR. ROLLING: Proposed rulemaking. Thank

you.

MS. EPPING: At this time we don't have

any workshops anticipated. If there's a need to have

one, we would certainly consider having one.

Do you anticipate a need to have another

workshop?

MR. ROLLING: I guess, yes, it might come

out of your sense of how the comments come back to yo.

MS. EPPING: Right.

MR. ROLLING: If the comments come back to

you with lots of disagreements and you have to make

choices and then you put a proposed rule in, you can

count on the same disagreements existing.

MS. EPPING: Right.

MR. BALDUCCI: Dave, I'm going to

reiterate what Michael mentioned earlier in the

workshop. Hopefully this is not going to be the only

time that we talk. When I say "we," I mean DOE and

industry and other interested parties; that it would

be more interactive.

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I mean, if in the middle of this comment

period, if we say the comment period is going to close

some time in March, you have a question about exactly

what you're submitting or of what DOE is thinking,

call us. I mean, it's -- and that's one of the things

I want to stress here -- it's supposed to be very

interactive. We want to make sure that we're

addressing your concerns and we're understanding your

concerns that we do get it so that we don't run into

a situation where we have a notice for proposed

rulemaking out and then all of a sudden there's all

this contention about it and we're back to where we

started.

So a public workshop, we may or may not

have one, but again, as we mentioned earlier, feel

free to contact Oskars or Kathi, if you can't get hold

of those two, myself as well, with regards to concerns

with this.

So does that kind of help you out and

answer your question?

MR. PETERSONS: Question. I see for

several of the topics where some really extensive fine

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tuning will have to be done, although we probably

already at this point perceive that we can come to

agreement. It would really be very good if Kathi and

I could meet with somebody, especially those who

raised these arguments, that we could meet, say, with

a small group dedicated to a specific topic.

MR. ROLLING: Let me comment from a NEMA

standpoint on that, Oskars. I believe that the NEMA

organization would be certainly willing to do that,

and that meeting among NEMA members could be

coordinated through NEMA probably through Lake here,

and I think everybody would agree in NEMA that would

be appropriate.

MR. HOPKINSON: Phil Hopkinson, Square D.

Yes, I certainly reflect favorably on what

Dave just indicated on funneling through NEMA and

coordinating that way.

I also would raise issue on the NOPR for

the summer of '98, recognizing that there's a tough

period to get people together from the standpoint of

vacations, and so maybe some backward thinking as to

the plan and adequacy of time to respond that would

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coordinate around your time setting.

MS. EPPING: Right. Thank you.

MR. BALDUCCI: One other thing that I

would like to stress in regard to the schedule, and it

was brought up yesterday a little bit and just to

reiterate what NEMA stated today with regards to TP-2,

the quicker that gets finalized, it makes it a little

easier for Kathi when she writes the rule.

Summer '98 can go all the way through

August. So --

MS. EPPING: Through September 21st.

MR. BALDUCCI: Through September 21st

actually. Michael is shaking his head back there

because he's the one who's got to sign off on the

schedules.

So, yeah, we're sensitive to that. Again,

with regards to the NOPR, what will happen, once it's

published there will be a 75 day comment period.

Within that 75 day comment period the department will

hold a public hearing/workshop to discuss the NOPR and

decisions on why we're proposing certain things.

So 45 days is about?

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calculated.

as well.

167

MS. EPPING: It's the 27th of March I've

MR. BALDUCCI: That's what I figured out

MS. EPPING: And it's a Friday.

MR. BALDUCCI: Is that suitable for

everyone, 27 March? Do the ayes have it?

(No response.)

MR. BALDUCCI: Okay. We'll put it down.

Anyone have any questions or comments

before I pass out our evaluations? We have one from

the back.

MR. McCABE: Michael McCabe again.

I'd just like to thank everybody, but also

in talking about the comments and how we can work

together in the meantime is to point out that we're in

an informal process right now that's pre-rulemaking,

and I also look at Ed to make sure that I don't

overstep the bounds, but we are guided by the

Administrative Procedures Act in conducting the

rulemakings, and once we publish the NOPR, there are

a very different set of requirements that are on us

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then than beforehand.

But the spirit of the Administrative

Procedures Act should apply to us now as well. We're

trying to get the input from all parties in developing

this proposed rule. So while we may talk about

working informally with -- you know, sharing Oskars'

and Kathi' s time with you to answer questions and have

a dialogue during this period prior to the NOPR, that

they are also going to be tasked to working with some

other parties. They're not going to be able to say,

"This is what DOE's going to propose."

They're going to look to get as much

information. In some of those discussions, they'll be

looking to come up with what would seem to be a

resolution, taking into consideration issues that an

individual, be it the manufacture, an efficiency

advocate, representative of another government, you

know, what they're trying to resolve, but they're

still going to be bringing that information back to

DOE that we still have to answer to Dan Reicher and

his staff as to what the policy is going to be.

But we have a lot more flexibility prior

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to publishing the NOPR about being able to sit down

with parties, and it is to all of our benefit to

identify issues, talk about specific language. That's

one reason why Oskars' work was shared, so that you

had a sense rather than having a vague outline, that

we wanted to have something specific.

Now, if you can complete TP-2 in a very

timely fashion and we look at it and get input from

others and we decide that we want to go and

incorporate it, we're going to have to deal with a

number of issues that haven't even come up explicitly

today, and that's do we incorporate it by reference

entirely, do we incorporate sections of it, and we're

going to be having to deal with that.

So we will try to have as much

communication as we can, but we also have to -- I have

to answer in certain respect to Ed Levy's guidance to

what I can and cannot say, what Kathi can and cannot

say, same way with Oskars, but we will try to share as

much as we can, but we had better do it sooner rather

than later.

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MR. BALDUCCI: Thank you, Michael.

One thing I do ask of everyone before you

go is we have an evaluation form for today's workshop

that I will pass out now.

So I would like to thank everyone for

their time today. I know a lot of people have very

busy schedules, and I thank everyone for attending

today's workshop.

Again, we do appreciate your comments,

both verbal and written.

If you've got extras, I'll come back

around and grab them.

(Pause in proceedings.)

MR. BALDUCCI: We stand adjourned.

MR. ROLLING: Before we do that, I,

speaking for NEMA here, and I'm sure the rest of the

folks who attended the workshop, want to thank all the

folks from DOE, Michael McCabe, Anthony Balducci,

Kathi Epping, Mr. Levy, and Oskars, as well, for all

of the help that you've given us, and I do think the

meeting was well run, professionally run, and we

certainly appreciate participation.

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Thank you.

MR. BALDUCCI: Thank you very much, Dave.

Why doesn't everyone give themselves a

round of applause for a meeting well done today?

Thank you.

We stand adjourned now.

(Whereupon, at 1:55 p.m., the workshop was

concluded.)

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EE-DET-97-550 COMMENT 01D
C E R T I F I C A T E

This is to certify that the foregoing transcript in

the matter of: WORKSHOP ON TEST PROCEDURES FOR

DISTRIBUTION TRANSFORMERS

Before: DEPARTMENT OF ENERGY

Date: FEBRUARY 10, 1998

Place: WASHINGTON, D.C.

172

represents the full and complete proceedings of the

aforementioned matter, as reported and reduced to

typewriting.

SAG, CORP.

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