1

UNITED STATES OF AMERICA DEPARTMENT OF ENERGY

+ + + WORKSHOP ON TEST PROCEDURES FOR DISTRIBUTION TRANSFORMERS

+ + + Tuesday, February 10, 1998

+ + +



### 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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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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### 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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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 

### s meeting.

today 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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### 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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### 18 19 20 21 22 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.



### 202/797-2525 MR. SIQUEIROS: Carlos Siqueiros, Cutler 

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### 18 19 20 21 22 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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### 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 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 overallprocess 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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### 13 14 15 16 17 18 19 20 21 22 (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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### 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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### 6 7 8 

### 9 10 11 12 13 14 15 16 17 18 19 20 21 22 

### 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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### 16 17 18 19 20 21 22 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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### 9 10 11 12 13 14 15 16 17 18 19 20 21 22 

### 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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### 16 17 18 19 20 21 22 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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### 16 17 18 19 20 21 22 

### 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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### 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 believethe 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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### I would expect it should be printed within 30 days

f ll h 2 

### u y.

ope 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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### 19 20 21 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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### 12 13 14 15 16 17 18 19 20 21 22 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 Iguess 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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### 18 19 20 21 22 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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### 22 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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### 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 f d 5 or ry.

it was with the .25 kVA 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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### 16 17 18 19 20 21 22 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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### 19 20 21 22 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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### 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

i 7 

### nt.

po 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 sogreat 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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### 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 22 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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### 19 20 21 22 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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### 19 20 21 22 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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### 19 20 21 22 

### 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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### 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 

### 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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### of looking at the game. 2 MR. MOREHART: Gene Morehart, Acme 

### 3 Electric. 4 

### The answer toyourquestion, 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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### 10 11 12 13 14 15 16 17 18 19 20 21 22 

### 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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### 8 9 

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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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### 9 10 11 12 13 14 15 16 17 18 19 20 21 22 

### 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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### 16 17 18 19 20 21 22 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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### 13 14 15 16 17 18 19 20 21 

### 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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### 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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### 18 19 20 21 22 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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### 9 10 11 12 13 14 15 

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### 20 21 22 

### 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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### 19 20 21 22 

### 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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### 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 i 7 

### upwards of 120 degrees C. in operat 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

i 13 s 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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### 20 21 22 

### 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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### 16 17 18 19 20 21 22 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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### 19 20 21 22 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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### 20 21 

### 22 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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### 13 14 15 16 17 18 19 20 21 22 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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### 19 20 21 22 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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### 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 16 17 18 19 20 21 22 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 whywe'reasking 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. 22 11 Thank you. 

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### 18 19 20 21 22 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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### 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. 4218 LENORE LANE, NW WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS