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



### SAG CORP. 202/797-2525 Washington, D.C. Fax:'202/797-2525 1 

### UNITED STATES OF AMERICA DEPARTMENT OF ENERGY
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### WORKSHOP ON rEST PROCEDURES FOR PISTRIBUTION TRANSFORMERS + + + 

### Tuesday, ,February 10, 1998 + + +


### The workshop was held in Room lE-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:

2021797-2525 RANDY 

### BARNES ,JAMES BOHLK SAG CORP. Washington.D.C.- Fax:'2021797-2525

## I 2 ALSO PRESENT (Continued):

JOHN BORST LAKE COULSON JOHN GAUTHIER PHIL HOPKINSON DON KLINE GENE MOREHART .WES PATTERSON DAVID ROLLING KEN STRICKLETT DAVE WIEGAND ALAN WILKS



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### ALSO PRESENT (Continued):

202/797-2525 

### 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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PAGE Opening Remarks and Introductions 6 Overview of Rulemaking Process, Michael McCabe 18 Overview from NEMA 35 Discussion of Adoption of Consensus Standards 40 NEMA Position on Consensus Standards .' 42 Discussion of the Basic Model 51 NEMA Position on Basic Model, 54 Discussion of Coverage of Transformers 60 Discussion of Sampling. Plan .80 NEMA Position on Sampling Plan 94 Discussion of the Measure of Energy Consumption 112 NEMA Position on Measure of Energy Consumption 113 Discussion of Burden Imposed on Industry by

Additional Testing and Data Processing 118- NEMA Position on Additional Testing and . Data Processing .118 Discussion of Reference Temperatures 134 NEMA Position on Reference Temperature 135 Discussion of Measurement Corrections 137 NEMA Position on Measurement Corrections 138 Discussion of Quality Assurance 152 

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### C-'O-N-T-E-N-T-S' Opening Remarks and Introductions 6 Overview of Rulemaking Process, Michael McCabe 18 Overview 'from NEMA 35 Discussion of Adoption of.Consensus Standards 40 NEMA Pos'it'ion on Consensus Standards 42 Discussion of the Basic Model 51 NEMA Position on Basic Model, 54 Discussion'of Coverage of Transformers 60 Di'scussion o·f Sampling Plan 80 NEMA Position on Sampling Plan 94 Discussion of the Measure of Energy**Co~sumption** 

### 112 NEMA Position on,Measure of Energy Consumption 113 Discussion of Burden Imposed on**Indu~try** 

### 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 QualityAssurance 152

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C-O-N-T-E-N-T-S (Continued) 4

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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### C-O-N-T-E-N-T-S (Continued) NEMA Position on QualityAssurance

- Discussion of Length of Comment Period NEMA Position on Proposed Comment Period

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10 11 12 13 14 15 16 17 18 19 20 21. (9:01 a.m.) MR. BALDUCCI: Good morning, everyone. My name is Anthony Balducci, and I'll be facilitating today's meeting.

The following people are with the Office of Codes and. Standards., as well as myself: Kathi Epping and Michael McCabe, who's behind Sandra, and Brenda and Sandy.

One thing I wanted to just remind everyone, if you have not signed in already or left a business card, please do at the table..

Ed Levy with our General. Counsel should be here soon, and we also have Oscars -Petersons with' 'NIST,.who most of you already know.

Onbehalf of the Department of Energy, I would like to thank all of you for taking the time to participate in this workshop. The purpose of the workshop is to discuss the draft test procedure for distribution transformers and the issues surrounding it. 22 11 The department will consider the views 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 202/797-2525 5 1 P-R-O-C-E-E-D-I-N-G-S 2 (9:01 a.m.) 3 'MR. BALDUCCI: Goodmorning, everyone'. My 4 name is Mthony Balducci, and Ii11 be'facilitating 5 .today's meeting. 6 The following**p~ople** 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**everyon~,** if you have not signed in already or left a 12 business card, please do at the table,. 13 EdLevywithourGeneral Counsel shouldbe 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 it. 22

2021797-2525 The department will consider the views 

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4 5 6. 7 8 9 10 11 12 13 14 •15 . 16 17 18 19 20 21 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 

### S A G CORP. . Washington, D.C. Fax: 202/797-2525 202/797-2525 6 1 presented in the comments submitted in formulating a 2 proposed rule for tef;lt procedures for distribution 3 transformers. We ,seek, the,depar.tment, to gather 4 additional information on dat,a on certain questions 5 and issues being considered by the department in 

### its 6 ' developr(lent' of this proposed rulemaking. 7 We do'not expect to resolve all of the 8 questions, but do expect to gather datato guide us on 9 that. That1s a very important point here. One of the 10 things we want to do today is identify issues. We 11 don1t expect to answer all of those issues today.**1~** It1s going to be more of a data' collection. 13 The department on 9'anuary 12th sent a' 14 letter to interestedparties announcing this workshop ·15 and provided a draft agenda, an issues paper, a draft

16 test procedure prepared by NIST for transformers. 17 Sincethetestproceduredocument was sent 18 out, NIST has made some changes to it. The changes, 19 I believe, are in the documents that,were passed out 20 this, morningI, as well, as the agenda for today's 21 meeting. 22

2021797-2525 A public notice of the workshop was SA

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7 8 9 10 11 12 13 14 15 16' 17 18 19 20 21 22 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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### 1 published in the.Federal Register on January 20th of 2 this year, and anyone attending today's workshop or 3 anyone who submitted comments will be added to our 4 mailing iist. We're revising our mailing list·now. 5 What· we're going to do is if you're attending the 6 

### workshop oryou do submit comments, you will be added 7 

### to our mailing list for future mailings regarding 8 

### distribution transformers. 9 

### The comments received here today and 10 received. at today's workshop will assist the 11 department in developing the proposed rule for 12 transformers. 13 

### Again, I'll just restate that I'm the 14 presiding officer and will facilitate the workshop. 15 I'·11 

### set the guidelines for conducting the workshop, 16. as. well, as we go through this'and provide other 17 

### pertinent information. 18 

### In approximately two weeks. a complete 19 transcript .will be available for inspection and 20 copying at the department's Freedom of Information 21 Room. It's right down the hall. It's lE190. 22

2021797-2525 

### Anyone wishing to purchase a copy of the 

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1 2 3 4 

### 5 6 7

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

202/797-2525 

### SAG CORP. . Washington,, D.C. Fax: 202/797-2525 8 1 transcript can see the court recorder at the end of 2 the workshop. 3 The purpose, 

### again, of the workshop·

### is to 4 discuss the draft test procedure for distribution 5 transformers and the issues surrounding 

### it. The 6 objective 

### is to gatl:"ler views· and·information on the 7 draft test procedure for transformers before the 8 department

-- before, that's.important

-- before the 9 , department issues a notice of,proposed rulemaking, 10 We will not be se'eking to reach consensus lIonthe issues. We'll be trying to identifythe issues 12 and gather information on them. 13 To provide the department with as much 14 pertinent information and as many views as can be 15 reasonably obtainedand enable**int~rested** parties to 16 ,.express theirviews, the workshopwill be conductedin 17, accordance with the following procedures. 18 'Kathi Epping will introduce and lead the 19 discussion on all the topics.,NEMAhas requested that 20 a five minutepresentationbe

### givenbefore each topic, 21 which we haVE;!,granted. Also NEMA has requested a' five 22 minute overview**b~fore** we get into each topic, which

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7' 8 9 10,

12 13 14 15 16 17 18 19. .20 21 22 we have granted as well. If there's anyone else who would like the opportunity to speak, please see me , and we'll work you in with regards to each topic .and all are invited to participate in the discussions.

.We'll begin with introductions after I finish my opening comments. Then we'll have a presentation by Michael McCabe.. It'll be an overview presentation of the process. NEMA will give a brief, brief process. Dave who will be representing NEMA will do that.

Then we'll go with an agenda review and then proceed right into the discussion on each topic.

At the end of the workshop we'll have closing remarks. One of the other things we also will do is set- a date for the comment period. We do not have. a date that the comment period closes yet. At the end of the workshop, depending on how many issues we get through and how much, information we will need, we'll try and set a ''date for that.

And prior to adjournment, we do ask that you f ill out an evaluation sheet, which will be passed 

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### 1 we have granted as well. 2 If**ther~'s** 

### anyone else who would like the 3 opportunity to speak, please see me, and we'll work 4 you inwithregards to each topic**~',**

### ,and all are imTited 5 to participate in the discussions. 6 'we'll begin with introductions ,after I finish my opening comments. Then we'll have a 8 presentationbyMichael McCabe., It'llbe an overview 9 pre,sentation 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 thenproceed right into the discussion on each topic. 14 At the end of the workshop we'll 

### have 15 closingremarks. One of the other things we alsowill 16 do is set' a date for**~he** 

### 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.**info~mation** 

### we will need, '20 we'll try and set a'date for that. 21 Apd prior to adjournment, we do ask that 22 you fill**~ut** 

### Cin evaluation sheet, whichwill bepassed

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7 8 9 10 11 12 1 13 . 14 15 16 17 18 19 '20 21 22 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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### 1 eut later in the werkshep. 2 We'll take an heurbreak fer lunch areund 3 a cenvenient'time near neen, which is en**yeu~** 

### ewn. 4 ·There's a snack fleer ene fleer belew us - - snack bar 5. ene fleer belew us.! which seme ef yeu'already went to. .6 'fer ceffee. The cafeteria is en the secend fleer ef, 7 the.West Building. If yeu need directiens fer that, 8 we can kind ef set up a little train, and everybody 9 can'held,hands and werk their way ever there. 10 

### Up the street there are also. seme 11 

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

, . 

### 12 .little bit mere time. Ifyeu do elect to. de that, 13 please remember that we want to. take en ho.ur. 14 We will expediate the werkshep te.be sure 15 ef ebta.ining**~ach**

### participant'sviews,and,ifeveryene 16 waits to. be recegnized, yeu will have a chance to. 17 speak. 18 

### Please remember, and this is very' 19 impertant'fer the ceurt recerder and fer the fermal 20 transcript, when yeu de speak, 'intreduce yourself" 21 yeur name" yeur cempany" and also'yeu must speak into. 22 the micrephenes so.**w~** 

### can.get it·all en the recerd.

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5 6 7 8

.10 11 12 13. 14 15 16 17 18 19 20 21 22 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 andLdata submissions will be available for public inspection at the DOE

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### 1 Side,conversations should be kept to a 2 

### minimum to avoid interrupting the presenter, whoever 3 

### is speaking.' If you do.need a private discussion, 4 

### please do take it outside the room. 5 

### Also, I apologize now'. I may cut off some 6 

### debates if we get off on a tangent and we need to get 7 

### back on the agenda to cover some relevant topics. We 8 

### may cut them off. If we have time at the end, we can 9 

### come back 'to,those discussions. 10 

### I encourage everyone to participate as 11 

### much as they can so that the department may get a full 12 spectrum of opinions on these topics. 13 

### We're scheduled to endby 4:30 

### today. We 14 

### do have the room till five o'clock if we need. 15 

### Topics 

### which have not been completely 16 

### discussed by five, if you feel there's more input you 17 

### need, we may ask questions; you may have questions of 18 19 20 

### 21 ' 22 us. That's for the comment period. Feel free to submit your comments by the end of the close of the comment pe'riod, which we will discuss 

## at the end. All writtencomments and'data submissions will be available for public**in~pection** 

### at the DOE

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9 10 11 12 13 14 15 16 17 18 :19 20 21 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, arerequested . 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.. 22 11 document that you feel you've got a paragraph or two 

### S A G CORP. - 202/797-2525 Washington, D.C. Fax: 202/797-2525 12 1 Freedom of Information Room, which is down' the hall. 2 The phone number for that room 

### is (202) 586-6020. The 3 comments should be addressed to Sandy' Beall at the 4 Department of Energy', as noted in

-- I'm getting 5 signals. I'm sorry. It shouldbe addressed to Brenda 6 Edwards-Jones as'indicated in the notice' that was 7 published in January. 8 .Ten copies of comments or data, are' 9 requested. If you" re submitting data, please submit 

## 10 ten copies. 11 The other thing we do request is if you 12 can submit those**comment~** electronically as well,' it 13 makes it 'easier for us to put in our files. We're 14 using Word Perfect 6.1. 15 No fax comments will be accepted because 16 it's tough for us to scan them. 17 AnypersonSUbmittinginformationwhichhe 18 or she believes'to be'confidential an exempt by law 19 frompublic'disclosure should submit one'complete copy 20 and ten copies from which information claimed to be 21 confident'ial has been deleted. So'if you've got a' 22 document that y:ou feel you've got a paragraph or two

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4 5

7 8 9 .10 . 11 12 13 14 15 16 17 18 19 20 21 22 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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### 13 1 confidential to your corporation or company, submit 2 ten full copies without that one, and then one copy 3 .with·the confidential marked "confidential. ri 4 

### In accordance 'with the procedures set 5 forth in 10 CFR 1004.11, the Department of Energy**~ill** 

### 6 make. 

### its .own determinations. as to whether the 7 information shall be kept from public disclosure. 8 In keeping,with the regulations for these 9**facilit;~es,** 

### there 

### is no 

### smoking allowed in this room .10 or building. The restrooms are at each end of the 11 halls, if you need those. Phones are' located in the 12 main lobby area. 13 Again, we appreciateyour time and effort 14 you have taken inpreparing for this workshop and are 15 pleased to receive your comments and opinion. 16 I would like.to reiterate the purpose of 17 the workshop 

### is to discuss the draft test procedure 18 for transformers andthe issues surroup.dingit, not to 19 reach consensus necessarily on all those issues. 20 If you have not signed in, again, please 

## 21 do, and at this time I would like to go around the 22 room for introductions. Why don't we".start at the

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9 10 11 12 13 14 15 16 17 18 19 20 21 22' 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 getup 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, ABB, South Boston, Virginia..

MR. BORST: John Borst, ABB, Power T&D. MR. HENRY: George Henry, Central Moloney Transformer.

202/797-2525 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 14 1 head table? 2 MR. LEVY: Ed LevyI Office of General 3 Counsel, DOE. 4 CHAIRPERSON EPPING: Kathi Epping. I am 5 the, Program Manager in the Office of Codes and 

### • 6 Standards on distribution transformers. 7 MR. PETERSONS:. OskarsPetersons, National 8 Institute of Standards and Technology. / 9 MR. BALDUCCI: This is where it'sgoing'to

10 ge.t a little difficult. I would like if everyone 11 could getup and speak into the mic. It's going to 12 take a little time, but it's worthwhile. 13 MR. COULSON: ,Lake Coulson, National 14 Electrical Manufacturers Association. 15 MR. ROLLING: David Rolling, Cooper Power 16 Systems. ..' 17 MR. PATT:$RSON: West, Patterson, ABB. 18 MR. BOSIGER: John Bosiger, ABB,' South 19 Boston, Virginia. ' 20 MR. BORST: John Borst, ABB, Power T&D. 21 MR. HENRY: George Henry, Central Moloney 22 Transformer.

" 

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8 9 10 11 '12 13 14 15 1F 17 18 19 20 21 22 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. 'GUILE: 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. 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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### 15 1 

### MR. GAUTHIER: John Gauthier, NEMA. 2 

### MR. WILLIAMS: Matt Williams, NEMA. 3 

### MR. STAHARA: Ron Stahara, Central 4 Moloney, Pine Bluff Arkansas. 5 

### MS. JENSEN: Barbara Jensen, EHV Wideman. ,6 

### MR. 'GUICE: Dennis Guice, Southern 7 Transformer Company. 8 

### MR. KLINE: Don Kline, Southern 9 Transformer Company. 10 

### MR. WILKS: Alan Wilks, ERMCO. 11 MR. HARTFIELD: Tony Hartfield, ERMCO. '12 MR. MILLIMAN: Dennis Milliman, Niagara 13 Transformer. 14 

### MR. MOREHART: Gene Morehart, Acme

, 

### 15 Elect;.ric. 16 MR. PELTZ: 'JohnPeltz, AtlanticDivision, 17 Navy. 18 

### MR. GLENN: Peyton**GI~nn,** 

### Atlantic 19 Division, Navy. 20 

### 21 Institute. 22

2021797-2525 

### MR. HALV: Ken Hall, the Edison Electric

MR. SIQUEIROS: Carlos Siqueiros, ,Cutler SAG CORP. WaShington, D.C. Fax:202/797-25252 3 4 5

7

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

Company.

Company. 16

MR. HASTINGS: Chuck Hastings, Square D

MR. HOPKINSON: Phil Hopkinson,,Square D

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. 

### SAG CARP '202/797-2525 Washington, D.C.. Fax: 202/797-2525 16
1 Hammer. 2 MR. HASTINGS: Chuck Hastings, Square D 3 Company. 4 MR. HOPKINSON: -Phil Hopkinson', ,Square D 5 Company. 6 MR. SCHWARTZ: "Wes Schwartz, Square D 7 Company, Osh Kosh, Wisconsin. 8 MR. HODGE: Gerzy Hodge, Howard 9 Industries. 10 MR. EPPING': Patrick Epping, Techtran. 11 MR. HOLLOMON: Brad Hollomon, 'Pacific 12 Northwest Laboratory. 

### 13 MR. BRUSH: Ned Brush, consultant to the 14 Copper Development Association., 15 MS. WHELAN:' Valerie Whelan, Natural



# . 16 Resources, Canada. 17 MR. WIEGAND: Dave Wiegand, Transformer 18 Engineering Services, from London, Ontario. 19 MR. VON HOLLE: Tony Von Holle, ARMCO. 20 MR. SHUGARS: John 'Shugars, Lawrence 21 Berkeley National Labs, here for the Federal Energy 22 Management Program Office.

'2021797-2525 

### SAG CORP. Washington, D.C., 

### Fax:2021797-252517

3 4

6 7 8

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 

### SAG CORP 202/797-2525 Washington, D.C. Fax: 202/797-2525 

### 17 1 

### MR. LINK: Dick Link, General Electric. 2 

### MR. BOHLK: Jim Bohlk, United States 3 

### Department of Agriculture, Rural Utilities Service. 4 

### MR. AGUDO: Mike Agudo, RUS. 5 

### MR. SMITH: Henry Smith, PEMCO 6 

### Corporation., 7 

### MR. BUSH: Carl Bush, PEMCO Corporation. 8 

### MR. HYLAND: Mike Hyland, American Public 9 

### Power Association. 10 

### MR. STRICKLETT: Ken Stricklett from 11 

### National Institute of Standards and Technology. 12 

### MR. RABA: JimRaba, Department ofEnergy, 13 

### Office of Codes and Standards. 14 

### MR. ADAMS: Carl Adams, Office of 'Codes 15 

### and Standards, DOE. 16 

### MR.' KUMAR: 

### B.J. Kumar, Energetics. 17 MR. NASSERI: CyrusNasseri, Departmentof 18 

### Energy, Office,of Codes and Standards. 19 

### MR. BARNES: Randy Barnes, Oak Ridge 20 National Laboratory, Oak Ridge, Tennessee. 21 22 

### McCabe.

2021797-2525 

### MR. McCABE: Good morning. Michael I'm Direct of the Office of Codes and SAG 

### CORP. Washington, D.C. Fax:2021797-252518

1 2 3

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20. 21 22 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. 6 , 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

2021797-2525 

### S A G CORP. Washington, D.C. Fax: 2021797-2525 

### 18 1 Standards. 2 MR. BALDUCCI: Thank you'very much,. 3 everyone" for: themusical chairsexercisewe justwent 4' through. 5 One other thing,before Michael gives his 6 presentation. We do have some extra copies of the', • 7**repor~s** 

### that were distributed. One is the process 8 rule, the issue paper'that was mailed out, the NIST 9 draft NOPR,as well as the determination of the NOPR. 10 At this time I'd like to ,turn it over to 11 Michael McCabe. He's going to give a short 12 presentation on the overview process. 13 

### MR. McCABE: Thank you, Anthony. 14 

### Good morning. 15 

### PARTICIPANTS: Good morning. 16 

### MR. McCABE: Welcome toWashinsrton. It's 17 a little bit drier here now than what it has been, 18 something which I can certainappreciate since I've 19 been in the middle of a six and a half weekprocess to 20 get a new roof, but I've been rather dry. 21 But the process which we're embarking on 22 is one that,we've had

- - I've been undergoing within '

2021797·2525 SA

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.Washington, D.C. Fax:2021797-2525

### I 19

2

4 5 6

10 11' 12 13 14 

### is 16' 17 18 19 2'0 21 22 the Department of Energy for some 25 years with what

started as the appliance standards program.

But the 1992 legislation, which many of you were a part of, directed the department to review a number of products, including electric distribution transformers, to determine whether or not the department should proceed with a rulemaking program.

As -many of you are aware, October this .past year we issued a determination that standards appear -- and I will stress that it's "appear" -- to be technically feasible, economically justified, and would result in a significant conservation of energy. This is the first step in a process that we don't know how long it's going to last. .in stressing "appear," that is to try to stress that, that once the process has been-kicked off as it has been now, the next step is to go into a rulemaking process for test procedures.

I will spend a little. bit of time talking about the standards and our overall process because of the many questions which I, Kathi, and Oskars and others have received on the standards issue, but I'd

202/797-2525 

### SAG CORP. Washington, D.C. Fax: 2021797-2525 

### 19 1 the Department of Energy for some 25**ye~rs** 

### 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,ofproducts, 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 wil,l 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 14hbw long it's going,to last. 15 ,So in s'tressing "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 andouroverallprocessbecause of 21 the many questions which I, Ka1;hi, and Oskars and 22 others have received on the standards issue, but I'd

2021797-2525, 

### SAG CORP. Washington, D.C. Fax:2021797-2525 .,20

2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 .20 21 22 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 

### S A G CORP 202/797-2525 - Washington, D.C. Fax: 202/797-2525. 20 1 ' like to reiterate that this is not a standards 2 rulemaking. • 3 If somebody were to ask me whether or not 4 DOE, in fact, will issue a final rule on standards or 5 when the department will issue a final rule on 6 standards, I'm going to have to say I don't know when 7 or i:B we would do that because the results of the test 8 procedure. rulemaking and any subsequent standards 9 ", rulemakingwill determine whether and if there"willbe 10 a standards rulemaking. 11 But I'd like to deviate bri"efly from the 12 topic of today's'workshop and address some of the 13 pofnts on standards that'have been raised. I would 14 like also to entertain any questions at the end of my 15 presentation. If'there's something that 

### is confusirig' 16 that I may make a**r~mark** in the middle, please feel 17 free to raise your hand and ask me to clarify the 18 statement that I've made. 19 The department has gone through a process "20 which la!?ted approximately a year to develop a new

21 process for.conducting standardsrulemakings. We will 22 apply that process to transformers. This 

### is part ·of

2021797-2525 SAG CORP. Washington, D.C. Fax: 2021797-2525.21

4 5 6

8 9 l0 11 12 13 14 15 16 17 18 19 20 21 22 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



### SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 21 1 that process in many respects. 2 The key element to the process, in my 3 view, is to share information early and ,often with 4 interested and affected parties so as to.ma:ke S1,lre 5 that, one! we have the correct information; two, we're 6 interpreting it correctly; and, three, for us to get 7 some direction as to where to go in the next step and 8 for you to know where we're headed. 9 Sothis wb:t:kshop, much ofwhat we're doing 

### io throughout the entireprocess, whether ornot it's ,the'

\ 11 test procedure, labeling, or even a standards 12 rulemaking such as what we have a workshop next month 13 on, the 'standards analysis for**st~ndards** for 14**,resident~al** clothes washers. So a major element to 15, the new process is this exchange. 16 Kathi and Oskars, for example, are 17 available to all. We have encouraged' the NEMA staff 18 touse Oskars and Kathi as a resource, for example I in 19 the development of TP-2, and some of the feedback that 20 I have**gott~n** is that that has worked well, but it's 21 also raised some questions. 22

2021797-2525 Oskars, for example, 'is not a DOE staff SAG CORP. Washington, D.C. Fax:2021797-252522

1 2' 3

7 8 9 10 11 12 13 14 15 16 17. 18 19 20 21 22 person. Kathi is not the Assistant Secretary for

Energy Efficiency and Renewable Energy. So often Oskars, Kathi, and 1 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 

### S A G CORP. 202/797-2525 Washington, D.C. Fax: 2021797-2525 .22 1 person. Kathi is not the Assistant S.ecretary for 2' Energy Efficiency and Renewable Energy. So often' 3 Oskars, Kathi, and 

## t will make statements about what 4 we expect mayor will happen. Those are staff 5 opinions. They're not the ·final DOE opinion. 6 More oftenthannot they're ontarget, but 7 if there are questions, remember that we're staff. We 8 don't make policy. We just do the analysis, and we 9 make recommendations and provide information to the 10 policy makers. 11 But',.again, we're**go~ng** to strive to have 12 as much dialogue with you as 

# we can throughout the 13 process so that there are not**anysu~prises.** 14 Again, standards rulemaking, if there is 15 one, will be initiated·after the test procedure 16 rulemaking. One of the elements to the process 17improvement.is that we recognize that we**nee~** to have 18 the metric in·place for measuring efficie.ncy, whether 19 or. not 

### it's how you measure the' efficiency of.a 20 clothes washer, central air conditioner, or 21 transformer. You cannot set a standard, a minimum. 22**efficie~cy** standard; unless you know what the test



### 2021797-2525 

### SAGCORP. Washington,.D.C. 

### Fax:2021797-252523 1 2

4 5 6

8

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

### S A Q CORP. 202/797

-2525 Washington, D.C. Fax:202/797-2525 23 1 procedure 

### is, what the metric 

### is, and how to measure 2 .that efficiency. 3**~** can remember back in the early days of 4 the programwhen we were working.with two legislative 5 deadlines to establish energy efficiency targets for 6 residential equipment, and at the same time we were to 7 set testprocedures for thoseproducts. The deadlines 8 inthe legislationwere the same, and we endedupjust . 9 blowing

-- the whole process just blew up in our face 10 because as manufacturers were trying to give us 11 information on how efficient a product is for a 12 central air conditioner, if you're talking about

i 13 'steady state· efficiency,' are you talking about an 14 outdoor temperature of 9:2 degrees, 88, 85, 95 degrees? 15 All of it gives you if you test at different 16 temperatures, you're going to get different results. 17 Sowe have.committedthat inorder to hav:e 18 an effective, valid standards rulemaking for any' 19 product, that we will get the testprocedures inplace 20 before we go into the standards rulemaking. 21 

### And once the test procedures are 22 developed, the standards rulemakings for any product

2021797-2525 SA

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1 2

4 5 6

10 11 12 13 14 1.5 16 17 18 19 20 21 22. 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. 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 

### S A i CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 24 '. 1 are kicked off through the prioritization process, 2 where we,. the department, will i'dentify through an 3 open process what the priorities are. 4 That process invites public input, where 5 we will share preliminary information prior to 6 establishing the**pr~cess.** In that preliminary 7 inf.ormation, "we will have 'staff recommend what the 8 staff. opinion is as to what the priorities .should be. . 9 We're 

### going to be seeking ppblic comment 10 on· that. We've gone through two priority setting 11 processes already, and this is an !annual process. In 12 both cases· we

### receiv~**comment'o~** the priorities that 13 resulted in .us changing or the department came.out 14 with a - - the fina:;!.·priorities were different t,han 1.5 what the staff initial recommendation was. 16 It 

### is important· in the priority setting 17 process that if you ,agree with the staff 18 recommendation you.say so. If you**dis~gree** with it, 19 say so as well because there are parties who have 20 different agendas, and if we only get comments from 21 one side say;i.ng, "This is·what we'd like to see. We'd 22. like to see you change the priorities for this reason

2021797-2525 

### SAG CORP. Washington, D.C.. Fax:2021797-252525

3

5 6 7 8 9 10 11 12 13 14 15 116 17 18 19 a 20 21 22 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 plumbing degree, I kind of like this image -

202/797-2525 

### S A Gi CORP. Washington, D.C.. Fax: 202/797-2525 

### 25 1 orthe other," andeverybody else is silent, you know, 2 we respond to where the noise is in many cases. 3 The priority process, the prioritization 4 is based primarily on the,potential energy savings. 5 ' We· also look at other factors that we deve'lop, suoh as 6 the economic and the environmental impacts of such 7 standards. 8 We may look at a particular level of,

, 

### 9 efficiency as far as what its potential savings is, \ 10 

### but generally we will look at a range because, you 11 know, there are certainlyfor some products where you 12 can go with a maximum**standa~d,** 

### very stringent 13 standard, but for economic reasons, impact on 14 oonsumers a;nd the like, that level would not be 15 reasonable. 16 ,Sb 

### we wl.ll look principaily at energy 17 savings, but we will try to balance it with other 18 factors. 19 

### If a product is a priority product for 20 standards andwe go intorulemaking, havinga chemical 21 engineering background, 'which is, just an advanced 22 plumbing degree, I kind of like this image

. 2021797-2525 SA Gi CORP. Washington.D.C.. Fax:2021797-252526

2

6

9. 10 11 12 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 SAG CORP. 202/797-2525 Washington, D.G. Fax: 202/797-2525 26 1 (Laughter.) 2 MR. ,McCABE:

- - because to me it just ,3 looks**li~e** a whirlpool. Otherwise some of the water 4 hydraulics. It just looks like a toilet. 5 But .the process is

- - and some of the 6 graphics really don't show up here

-- and that's the 7 standardsettingprocess" andwe've tried to set itup 8 such as with a, -- like each level' is a finer mesh 9, screen. 10 .So we'll go through a process to get

. , 11 stakeholder input in order to develop the regulatory 12 agenda, which will be published

- - the priorities 13 which will be published in the regulatory agenda. 14 We will then go through a screening 15 ' process for the standards rulemakirig where we will

. , 16, screen out efficiency designs which have health, 17 safety, utility impacts tha't do 

### not warrant 18 consideration in the standards rulemaking in order to

,·19 narrow the range of options that are being considered

20 for standards such that when we" come out with an 21 advanced notice of proposed rulemaking, with the 22 .analysis that accompanies 

### it, that it's our hope that

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1 2 3 4

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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I 27 1 with the engineering and economic analysis that 2 accompanies an,advanced notice that the parties s-qch / 3 ,as yourself and manufacturers, efficiency advocates, 4 states, utilities, and the whole host of those who are 5 interested in the rulemakings'whether or not it's for 6 motors,' tran,sformers, clothes washers, dishwashersI ' 7**cen~ral** air conditioners; anyof theproducts that are 8 covered by this program, that they could take a look 9 at this preliminary analysis and eesentially take 10 control of the, process from there on and come to an 11 agreement as to whether ornota standard is warranted 12 at a particular level and make.that recommendation to 13 the department beforewe go out with the proposedrule 14 and then the final rule. 15 16 17 18 19 20 21 22 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, 'thequestion I had is on the economic impact

--

202/797-2525 CHAIRPERSON EPPING: SA

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### Fax:2021797-252528
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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.

202/797-2525 

### S A G CORP! Washington, D.C. Fax: 202/797-2525 28 1**micropho~e,** please. 2 MR. HOPKINSON: I'msorry. PhiI Hopkinson 3 from Square D. 4 Michael, I'm sorry, but the economic 5 impact, couldyou comment? I don't see anyplace else 6 inthepresentationthat youhave what measures you're 7 using to reflect the economics. Can you comment on a 8 period, likefive-yearreturns, three-yearreturn, and 9 so on? 10 MR. McCABE: Inthe standards analysis, as

. . 11 part of the advancednotice ofproposedrulemaking,. at 12 that point 'we expect to have a - - our preliminary 13 analysis will include preliminary energy savings 14 forecast, preliminary life cycle cost analysis, and 15 price efficiency curves for the various products. 16 What we will strive to do before that 17, point, before we,do the analysis for the proposed 18 rule, is to sit down with all the**part~es** to define, 19 what are the appropriate metrics to examine in the

" 20 economic analysis, in the engineering analysis, so 21 that it will give you an**opportuni~y** to help to 22 structure the analysis.

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2

4 5

7 8

10 11 12 13 14 15 16 17 18 19 20 21 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 priorityproduct, 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 MR. McCAEE:, Les, you're a good straight 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 202/797-2525 ,29 1 But we're 'looking at both impact on the 2 customers, the impact on the nation,' the impact on 3 manufacturers I and the specifics as to what those' 4 impacts are, and we're going to look toyou,to help us 5 to find those, and the' "you" 

### isyou, the'manufacturers 6' ofaresidentialproductorinthis,case transformers. 7 If we go into the priority setting and 8 transformers ends up**bei~g** a prioritypro9uct, 'we will 9 then come back and look to those who are involvedwith 10 this product to he,lp us structure the analysis. 11 So there are many other questions as far 12 as specifically what are we going to do, how 

### is it 13 

### going to be structured that I can't answer right now 14 because it depends upon, one, whether or not it's a 15 priority product, and then we're going to work 16 together to try to structure that analysis. 17 MR. PATTERSON:' Wes Patterson, ABB. 18 Where in that chart are we right now'? 19 MR. McCABE:' We're not even on this chart 20 now. 21 (Laughter.) 22 'MR. McCABE:, Les, you're a good straight

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I 2 3 4

6. 7.

9 10 11 12 13 14 15 16 17 18 '19 20 21 22 man because you're setting up. The, purpose of today's workshop is not standards. (Laughter.)

PARTICIPANT: That was plain. MR. McCABE: Yeah, he was expensive. It cost me. The purpose of today's workshop is test procedures. We're looking for your comment, your input on the issues that have been identified and.the material that has been sent out.

We're also interested in your suggestions as to other test procedures. For example, Oskars -- I think I had mentioned that Oskars has been working with NEMA's staff and NEMA members to,support their activities. We recognize, I recognize the activities that you have underway in TP-2.

It is our position, our goal in the department and this program, but it's also the administration's goal, is to use public standards, consensus based standards, wherever possible.

We have for our program a number of



### S A G CORP 202/797-2525 Washington, D.C. Fax: 2021797-2525 30 

### 1 man because you're settin-g 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 interestedin.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**act~vities.** 

### 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 pro.gram, but it's also. the 20 administration's goal, is to use public standards, " . 

### 21 consensus based standards, wherever possible. 22

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5 6 7 8

10 1± 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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### consensus standards that we have adopted. Some we 2 have incorporated entirely by reference in 

### our 3 regulations.._We look to do that wherever possible. 4 Recognize thatyou'reworkingonTP-2. We 5 look to support that activity, and we will adopt any 6 consensus standard that meets our needs and 7 

### objectives. Where it does not completely meet our 8 needs,' we will adopt that portion that does'and'then , 9 supplement'with thebalance from oUrwork, but we will 10 try to .share that information with you early so that 11 you know the direction that we're headed and what our 12 needs are so that we can work together and'hopefully 13 incorporate any consensus standar,d.in its 

### entirety -14 

### with a minimum amount of input from us.

15 Again, the**p~ocess** 

### that we're looking at 16 and the three**~rincipal** 

### blocks in this**program~** 

### the 17, .determinationnoticehasbeencompleted, andwe'renow 18 in the middle block in test J?roc'edures**~** 

### 19 Questions about the standards analysis, 20 how we're going to structure ·it, 

### I don't know. You 21 probably**hav~** 

### a better idea than I do. I can recite 22 what we're doing for the residential products. I can

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1

4 recite what we're doing for the legislation. When we start getting down^to the specifics as to what would be appropriate for one product or another, that's where we have to work together.

The test procedures are, used for rating 6 7 .8 9 10 , 11 12 13 14 15 16 17 18 19 20 21 22. appliances, and.I will apologize that we often. use

appliances as a catch-all to cover everything. The title of the program is actually the Consumer Products Program - Energy Conservation Program .for Consumer Products Other-Than Automobiles, and I would not try to, describe an electric motor; a ballast, transformer as a consumer product.. Now, maybe - .a toilet is,. but that's one of our covered products, as well. But if I use "appliances" or anybody uses "appliances," we're using it' generically to cover the products that are covered. .

Products that are covered, for example, the residential products, we have test procedures in place. Ratings that are used in print media, wherever, those ratings for efficiency must be based on the test procedure.

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### S A i CORP. Washington, D.C. Fax: 202/797-2525 32 1 recite what we're doing for the legislat.ion. 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**~s** a catch-all to cover everything. The .8 title of theprogram is ac:::tuallytheConsumer Products 9 Program - - .Energy Conservation Program for Consumer

, . 10. Products Other Than Automobiles, and I would not try 11 to' describe an electric motori a ballast, a 12 transformer as a consumer product.' . Now, maybe·.a 13 toil.et;: is, but .that's one of our cove:red products, as 14 well. 15 But if I use "appliances" or anybody uses 16 "appliances,"**w~'**re using, it·genericallyto cover the 17 products that are covered. 18 Products that are covered, for example, 19 the residential products, we have te·st procedures in 20 place. Ratings that are used in print media, 21 wherever, those ratings por efficiency must be based 22 on the test procedure.

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6 7

10 11 12 13 14 15 16 17 18 19 20 21 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. Iraise 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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### The test procedure is also the basis for 2 

### labeling. The Federal Trade Commission labelsmost of 3 the residential products. 'We are in the process of 4 

### developing labeling rules for a number of the 5 

### commercial products. 6 

### The testproa:edures are alsothebasis for 

### 7 standards.**Irai~e** 

### thilll now**b~cause** 

### it's important 8 

### that when we're developing test procedures, where 9 

### there is some appreciation for standards and where. 10 

### there' is a link, it is the fact. that the. test 11 

### procedures are the 'foundation for any standards. You 12 

### have to have a.well structured, well thought out test 13 

### procedure. 14 

### So that if the test.procedure.is flawed, 15 

### the standard is going to be flawed as well. The 16 labeling is' going to be flawed. Any representations 17 are going to be flawed. 18 So it's important to do the homework, and 19 .that's why we're foc":lsingJ on test procedures first, 20 and then we'll look and deal with other issues that 21 

### follow. 22 We touched on the first two bullets, that

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6 .7 8 9 10 11 12. 13 14 15 16 17 .18 19 20 21 22 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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### going to be. working with all parties, the 2 manufacturers, colleagues north of the border, though 3 I'd have to say that the U.S. women's hockey team is 4 

### going to kick butt, Valerie. 5 . (Laughter.) 6 MR. McCABE: Our goal is 

### to· have a ,7 proposed rule on.test procedures by this summer. 8 Given where you are, and I expect some comments onTP9 2, Kathi and Oskars will be available to work' 10 together. 11 I'm particularly concerned about this. 

### 12 

### since we're already beginning to develop ideas.about 13 the test procedure. That's.the document that was 14 shared with you,**~nd** from a legal perspective,.ifyou 15 don't have TP-2 in place, for example**-~** and I'm kind 16 of dancing a little bit and Ed will help me if I have 17 if you don't have TP-2 in place by the· time we .18 issue ourproposed.rule, we're not goingtopropose to· 19 incorporate TP-2·because'it just isn't there. It 20 doesn't exist. 21 So any proposed rule that we come out 22 with, it has tobe based on either something that's

--

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9 10' 11 12 13 14 15 16 17 18 19 20 21 22 if we're proposing to adopt something, it ' s there. So

its 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 final 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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### 1 ifwe I

### reproposingto aqopt something, it'sthere. So :2 it's important that if you want us to consider TP-:2 3 and have that included in the'proposed rule, then ·4 there'.s an awful'lot of work that heeds to be done, 5 'and we would be willing to help you wherever we'can. 6 ' We expect a final rule in the summer of 7 '99, and with that I think I've gone well beyond my '8 time, answered some'que-stions, and I hope that, t;here 9,' aren't any further questions. If there are, I will 10' try to answer them., 11 I also expect to be here much of the day 12 so that I'll be available, and I wish everybody the 13 best, and I appreciate your participation. 14 Thank you. 15 

### MR. SALDUCCI: Thank you, Michael. 16 Now we'll have'a brief overview of NEMA's 17 comments from Dave Rolling. 18 Dave,do you need the

-- 19 MR. ROLLING: Yeah, I'll go over to where ,20 Mike· was standing.

21 MR. BALDUCCI: I don't know if you need, 22 the projector or nqt.

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10. 11 12 13 14 

### i5 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, Iwant to thank you for the opportunity-to participatein 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 transfoitmer 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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### 1 MR. ROLLING: No. 2 

### These are going.to'be brief. My name is '3 David Rolling, and I'm the Chairman of the NEMA '4 Transformer Sectioh.of our Equipment Division within

5 NEMA. 6 

### And on benalf 6f the largest trade 7 association in the Unit:ed States, representing the 8 interests of the elect,ric industrymanufacturers, the 9 National Electric Manufacturers Association, NEMA, I 10. want to thank you for the opportunity·to participate. 11 in these important discu$3sions. 12 NEMA's Tran!Sformer Products Section, 13 consisting of 22 member**~ompanies,** 

### is but one of the 14 many sections that addre$s generation, transmission, is 

### distribution, control, and end use of electrical 16 products manufactured by over 575 member companies.

. 17 

### NEMA's**Tra~sformer** 

### Products Section

18 represents about 65 perfcEmt of the domestic u.S. 19 shipments in'the**transfo~mer** 

### industry. 20 NEMA members have reviewed both the Oak 21 Ridge report and thepositive determination notice of 

## 22 October 22nd. We wan:t to**compl~ment** 

### the DOE and Oak

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3 4 5

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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### 1 Ridge for assembling very.competent folks in putting 2 together those reports, and we want to compliment the 3 quality of those reports. 4 We note, however, that this does not mean 5 we're in full agreement with everything, .with all .6 

### aspects of those statel1!lents. For example,. in the

7 determination notice, the definition of distribution 8 transformers was**expande~** 

### down to a quarter of akVA. 9 We disagree with that, and there are other points we 10 disagree with. 11 Also, we would like to reaffirm NEMA's 12 basic .principles**reg~rding** 

### energy efficiency 13 

### standards. We**bel~eve** 

### that energy efficiency is a 14 national concern and should be driven· by 'market 15 forces;' IndustrYshouldbe proactive in establishing 16 voluntaryefficiencystanqards,performancestandards, 17 test procedures, and**mea~urement** 

### tolerances. 18 

### Manufacturers should provide consumers 19 with accurate and**stan~ardized** 

### information about 20 energy efficiency perfolfmance that 

### is based upon 21 voluntary.consensus**stan~ards.** 

### 22 We look forward to participating in

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2 3 4

5 6

8 9 10 11 12 13 14 15 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 r-ulemaking .process,. we're right here right now.. With regards to topics, the first topic we'll, be



### SA 0; 'CORP 202/797-2525 Washiigton, D.C. Fax: 202/797-2525 - 38 1 today's workshop and for the mutual exchange of 2 dialogue between all stakeholders. For, many of the 3 items listed 

### in today's**work~hop** notice or**agenda~** a 4 representative from. the 'Transformer 

### Section of NEMA 5 will,offer a NEMA response. 6 In some case$'we willnot have an industry 7 position or" response and will be seeking-. further 8 clarification or seeking definition of terms on a 9 particulartopic. For e;ample, there were some terms 10 used in DOE's proposed $ampling plans, such as SFE, 11 that were not clear to**u~.** 12 Intho'se instiances, itwillbe helpful for 13 DOE to define those tierms to facilitate better 14 understanding among**work~hop** participants. 15 Thank you.

.16 MR. BALDUCCI::'-'Thank you, Dave.

17 Before we begin, I just want to do a quick 18 agenda reviewjust to kind of get**every~ne** up to speed

-19 of where.we are and**wher~** we're going.

20 We've ,alread,ly. had our opening remarks 0 21 Our rulemaki.ng,process,we're right here right ,now.. 22 with regards to topi.cs, the first topic we'l1. be

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2 3 4 .5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22. 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, weIll have an evaluation and then an adjournment.

With what, any questions, additions or deletions from the agenda.?

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### S A CORP. Washington, D.C. Fax: 202/797-2525 39 1, di$cussing, and Kathi, as I said before, will be .2 leadingthe discussionon these, the issue of adopting 3 consensus standards. 4 The next tOlPic would be on basic models, 5 and sampling plan, the measure of energy consumption, 6 then the possible potential burden on industry. We 7 had a little technical problem with.the pen right 8 there. 9 Reference temperatures'" measurement 10 corrections, and qualityassurance. That's all inthe 11 final agenda that was pa$sed out today, .if you follow 1.2 the numbers. 13 Then.at the**~nd,** again,'like I said, we'll 14 have some next steps·, whal,t we expect.from you andwhat 15 you should expect from us, some closing remarks, 'and 16 in those closing remarks, we',ll be discussing a date 17 for the close of the comment period. So try and keep 18 that in mind as we go thtough this. 19 Finally, we'

### 11haveanevaluationandthen 20 an adjournment. 21 With what, any questions, additions or 22 deletions from**theagend~?**

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5 6 7 8

10 .11 12 13 14 15 16 17. 18 19 20 21 22 (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 respoct, to test procedures, measurement procedures, and reference conditions, there are some differencels that exist that.might cause ambiguities, and'DOE woiltld like to eliminate those ambiguities and differences as much as possible when 

### S A q CORP 202/797-2525 Washington, D.C. Fax: 202/797-2525 40 1 (No response.) 2 MR. BALDUCCI: Seeingnone, I will turn it 3 .OVer to Kathi I and we'll j.ump right.into the'topicsI 4 which the first one is the question of adopting 5 consensus standards. 6 CHAIRPERSON EPPING: Hi. I'm Kathi 7 Epping, and I'd like to, talk a little bit about the 8 consensus standards. 9 DOE wouldlike toincorporatethe existing 10 national consensus stanqards to the extent possible.

.11 However, the consensus stfandardsdonot address issues

12 that are normally included, topics that are normally 13 included in DOE**·testpr~cedures,** .such as the concept 14 of a basicmodel and the 13electionof a samplingplan, 15 and I·know that those two issues are going. to be 16 discussed at length**late~** today. .17 While the**e~isting** standards are quite

18 harmonized with resp$ct· to test procedures, 19 measurement procedures, and reference c'onditions, 20 there are some diff.erence[s that exist thatmight cause 21 ambiguities, and'DOE w0'!lld like to eliminate those 22 ambiguities and differences as much as possible when

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9 10 11 12 13 14 15 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 al$o like to know if the

SAG'CORP. 2021797-2525 Washin4ton, D.C. Fax: 202/797-2525 I 41 1 we issue our test procedures. 2 Therearefourprimaryconsensus standards 3 that we're looking at, aZ1ld the first two are ANSI IEEE 4 standards, and the secon<1l two listed

- - these are also 5, listed**o~** your agenda**sh~et** if some of you 

### in the back 6 can't read this far up here

-- the se'cond two are 7 requirement standards.' 8 In addition', we'd also be looking at the 9 TP-1guide and the ISO standard 9001. 10 And 

### in addition, we'd also like to 11 consider the NEMA TP-2 dr:aft and the pe57.153 or 123. 12 'We know that these are nFlaring,completion, and once 13 they are approved by the.i4r sponsoring organizationsI 14 and preferably if we**c~n** get· this" if they get 15 approval by ANSI, we'd like to consider them 

### in our 16 test procedures. 'We would, be able to refer to them if 17 they were an official document. 18 So what we'd like to know 

### is are these 19 standards, appropriate folf us to be referencing and, 20 would we want to do a**clau~e-by-clause** referencing or 21 would we want to re'ferenc, appropriate chapters. 22

2021797-2525 And**we'dal~o** like to know if the SA Gi, CORP.

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2 3 4 5

7

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 knew 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.

Manufacturer$ from the Transformer Products Section have been working on TP-2, a testing procedure standard fo;r 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; C57.12.9., 1995; C57.12.00, 1993; and C57.12.01, 1989, and components from NEMA's TP-1.1996 

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### 42 1 standards that are in·the preparation stages, the 2 PCS7.12:3and the TP-2,if.we should reference them, 3 andwe'd also like to knq,w fro,m youwhat your'schedule 4 

### is regarding getting thqse documents out. SSonow I'd**l~ke** 

### some discussion to start. 6 You've seen some of the questions that we have. 7 

### MR. BALDUCqI: Before we start the' 8 discussion, as we ment:ij.oned earlier, NEMA will be 9 .giving a brief position'on each topic. Lake, is it 10 going to be you? 11 CHAIRPERSON$PPING: I'm sorry. I forgot. 12 MR. 

### BALDUCCI:: That's okay: 13 MR. COULSON: Lake Coulson, National 14 .Electrical Manufacturers!

### Associatioh. 15, Manufact':lrer$ from the Tr.ansformer 16 Products Section have**be~n** 

### working on TP-2, a testing 17 procedure s,!:andard for measuring .the energy. 18 consumption of distribution transformers. NEMA has 19 incorporatedintoTp-2**th~** 

### testingcomponents fromthe 20 standards prepared by !EEE and approved by ANSI 21 CS7.12.90, 1993; CS7.12.9+, 1995; C57.12.00, 1993; and 22 CS7.12.01, 1989, and comp(:mentsfromNEMA's TP-1 .1996

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6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 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 issie 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=i2 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, givgn that the. relevant. portions of the ANSI standard are .ncluded'in TP-2, we believe that for easier use TP-2 should be the referenced document., MR. BALDUCCI: We'd like to open it up how 

### S A CORP. 202/797-2525 Washington, D.C. Fax: 2021797-2525 I 

### 43 1 and ISO 9001, 1993.'. 2 Additionally, 'we have included into TP-2 3, additional, relevant**s~andards** 

### that are in the 4 preparatl.on and approval stages, such as IEEE 5" PCS7.1233. 6 In topics to be covered during today'S 

### 7 workshop, N;EMA's responl$e will include the relevant 8 section from TP-2. 9' ,The DOE issljle paper indicates that DOE 10 intends to use uniforffi!**~est** 

### requirements in the 11 proposed test procedures·for both the liquid immersed 12 and dry type transforme*s. NEMA requests that the 13 department consider TP":i2 as its single reference 14 standard for**testingpro~edures.** 15 

### NEMA**believ~s** 

### that the six consensus 16 standards are appropriatle as'reference for the DOE 17 required test procedure. 18 However,**giv~n** 

### that the relevant.portions 19 of the ANSI standard are**~ncluded** 

### in TP-2, we believe 20 that for. easier use TP-!2 should be the referenced 21 document. 22 MR. BALDUCCI:: We'dlike toopen ituphow

2021797-2525 

### SA**~** 

### CORP.**Washi~gton,** D.C. Fax:2021797·252544

2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 . 20 21 22 for discussion on. this issue, if we have any

-questions. Again, plea0e remember to state your name for the microphone and he court reporter.

MR. HOPKINSOT': 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 redly IEEE PC57.123, Draft 11. I think that's what's out there.

MR: EALDUCCI: 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 • standard or a test standard without it in place. Thelone thing, and I want to put this out to industry, specifically NEMA: is there a timetable? You saw our schedule for when we 

### S A CARP 202/797-2525 Washi gton, D.C. Fax: 202/797-2525 44**~** for discussion on**th~s** 

### issue, if we have any 2 questions. 3 Again,**plea~e** remember to state your name 4 for the microphone and**~he** court reporter', 5 MR. HOPKINSOiN: philHopkinsonfromSquare 6 D•. ' 7, Just to**co~rect** what' I see also as . 8 missing, NEMA ST20 is**ar~f'erence** document that 'should



### 9 be added.**~o** Also, I**~elieve** . in Mr. Coulson's 11 'presentation that you'll!find that the draft document 12 that he referredto 

### is really IEEE PCS7.123, Draft 11. 13 I think that's what's**ou~** there. 14 MR.; BALDUCCI

### i: .Any questions or comments 15 regarding that? 16 One thing I wpuld like to askwithregards 17 toTP-2, andthis questiol\1Michaelbroughtup

## ~ariier, 18 waS DOE cannot**reference.~** standardora test standard 19 without it inplace. TheIone thing, 

### and I want to put"

, ..' < , 20 this out to industry, sp,cifically NEMA: is there a 21 timetable? 22 You saw**o~r** schedule for when we

2021797-2525 , SA

## $ CORP.**Washi~gton.**

### D.C. Fax:2021797-252545 1

3

6

8' 9 10 11 12 13 14 15 16 17 18 19 20 21 22 anticipate a notice of proposed rulemaking for test

procedures. We were curious when NEMA anticipated that TP-2. being finalized.

MR. GAUTHIE*: 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.

from DOE.

domain? MR. LEVY: $ have a question. Ed Levy

Is this TP-^ going to be in the public

'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. 

### S A t CORP. 2021797-2525 Washi gton, D.C. Fax: 202/797-2525 45 . 1 anticipate a notice ·of ':proposeq rulemaking for test

2 procedures. We were c'jlrious when 'NEMA anticipated 3 that TP-2.bE:dng finaliz$d. MR.**GAUTHIE~:** John Gauthier from NEMA. .5**We'~e** looki4g to have

-- the document is

6 currently under review by the section. The ballot 

### 7 closes on the 28th of F¢bruary. I would expect the 8 ¢!.ocument.tobe prepared. There maybe some additional 9 editorial comments we haJve to make. I'would believe 10 the document shouldbe afprovedby at the latest mid11 March of this year. 12 MR. LEVY:**~** have a question. Ed Levy 13 from DOE. 14 Is this**TP-~** going to be in the public 15 domain? 16 'MR..**GAUTHIER~** Absolutely. 17 MR. LEVY: Wllat would its availabilitybe I 18 if somebody wanted to 19 MR. GAUTHIER;: ,As a matter of fact, DOE 20 has a copy of the draft,: and as soon as we have it 21 app!oved, itwill be put**~n** for publication and would 22 be available to the**publ~c** as soon as it's printed.

2021797-2525 SA**~** CORP.**Washi~gton,** D.C. Fax:2021797-252546 1 I would expect it should be printed within 30 days 2 hopefully. 3 MR. LEVY.: - What would be the cost of 4 obtaining it? Would it,be available for free or - MR. GAUTHIEI: Oh, no, no, no. It would 6 be a cost. Probably somewhere in the vicinity of 7 about $25 per copy. MR. LEVY: Okay. CHAIRPERSON (EPPING: Kathi Epping, DOE. 10 Could you tel us a little more about the 11 ST20? 12 MR. GAUTHIERI: 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. 

### S A CORP. 202/797-2525 Washi gton, D.C. Fax: 202/797-2525 

### 46 1 I would expect i t**shou~d** 

### be printed within 30 days 2 hopefully. . 3 MR. LEVY.: " What would be the cost of

4 obtaining it? .Would it,be available for free or -- . 5 

### MR.**GAUTHIE~:** 

### Oh, no, no, no. It would 6 

### be'a cost. Probably spmewhere in the vicinity of 7 

### about $25 per copy. 8 

### MR. LEVY: Olcay. 9 

### CHAIRPERSON**~PPING:** 

### Kathi Epping, DOE. 10 Could you**te~l** 11S 

### a little more about the 11 ST20? 12 MR. GAUTHIERI: 

### John Gauthier.again. 13 Let me just handle that. ST20 is one of 14 the two documents that**,N~MA** 

### has been publishing for a 15 number of.years. :r:t relates to special,ty. 16 transformers, dry'type**~pecialty** 

### transformers, and 17 

### it's an appropriate**docum~nt** 

### - - it shouldbe ...- that's '18 part of the general refe#ences. It will be.included

19 inTP-2. It was just anqversight on ourpart, andwe 20

### 'b~lieve' in the

### informatip~ that we gave you that it 21 probablywas equally**the~ame** 

### thing. It's available. 22

2021797-2525 

### MR. LEVY:**T~is** 

### is Ed Levy again. SAC; CORP.**Washi~gton.**'D.C. 

### Fax:2021797-252547 1 So it contains testing protocols for those kinds of transformers?

.MR. GAUTHIER: That's correct. It deals with the specialty transformer product essentially 5 with dry types, as well.; 6 CHAIRPERSON; EPPING: Is this document 7 going to have ANSI approv MR. GAUTHIERal? Do you know?

: S'T20 is one of the 9 documents approved in the C89 series. 10 CHAIRPERSON ^PPING: Okay. 11 PARTICIPANT: John, you might address TP-2 12 as a correction. 13 MR. GAUTHIER;: Well, with regard -- the 14 comment was with regard to the broader consensus 15 approval. TP-2, as I've indicated, will be approved. 16. by the NEMA group, which is the industry product 17 t d d

s an ar . .18 We have. submitted it. as a draft copy to 19 the key individuals in he ANSI process, C57. We 20 expect as soon as it's approved as a NEMA standard. and 21 received comments back from their review, we'll adjust 22 the document and then submit it to ANSI for approval 

### S A G CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 i 47 1 Soitcontaifns testingprotocols for those 2 . kinds of transformers.? 3 ·MR.**GAUTHIE~:** That's correct. It deals 4 with the specialty tra*sformer product essential'ly 5 with dry types, as well., 6 CHAIRPERSON iEPPING: Is this document . I 7 going to have ANSI apprqval? 

## Po you know?

. ! 8. MR•**GAUTHIE~**: ST20 is one of the 9 documents approved

# in**th~** C89 series; 10 CHAIRPERSON**~PPING:** Okay.
" 11 PARTICIPANT:! John, youmight addressTP-2 12 as a correction. 13 MR. GAUTHIER!: Well, with regard

-- the 14 comment

### ~as with regar4 to the broader consensus 15 approval. TP-2, as I'veIindicated, will be approved. 16 by the NEMA group, whicj:h is the industry product 17 standard.

.18 We have. sUbmftted it.as a draft copy to

19 the key individuals .in**'~he** ANSI process, .CS7. We 20 expect as soon as it's**ap~roved** as a NEMA standard.and ! 21 receivedcommentsback frctm theirreview, we'll adjust 22 the document and then**su~mit** it to ANSI for approval

202/797-2525. 

### SA**~** CORP.**Washi~gton,** D.C,. 

### Fax:2021797-252548

2 3 4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 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 aftet 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 aniANSI 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 transformero, and, Kathi, would you -- I'm sorry. MR. McCABE: I This is Michael McCabe. 

### SA

# 0 CORP. 202/797-2525 Washi lgton, D.C. Fax: 202/797-2525 48 '1 as an.**America~ nationa~**  standard, and that process 2 should-- I would**believ~** -- will beginprobably mid-

. 

### , 3 March if not sooner,**19~8.** 4 And of'courS!;e I with regard to - - just by. 5 way, Mr. Levy, of**indi~ating** the processf. I'm the 6 secretary for C57, and tj:he ballot is about a 4S-day 7 ballot. So 45 days afterI issue it,I'11 give Kathi 8 a heads-up. After that**w~** will have the ballot closed 9 and would expect that**th~** document woulc;l be**publish~d** 10 shortly thereafter as an!ANSI standard. 11 CHAIRPERSON $PPING: Thank you. 12 MR.. BALDUCCI!: Any other questions or 13 comments with regards tio the consensus standards? 14 . Kathi.,**Oskars~** anyone in:the audience? 15 (No response+ ) 16 MR. BALDUCCI**~** Seeing'none, it put us way 17 ahead of schedule now. :We're not going to take a 18 break nowbecause it's not 10:20. What we. will do now' 19 

### is talk about the defitlition of basic model for 20 distribution transformenj;, and, Kathi, would you -- 21 I'm sorry. 22

2021797-2525 I MR. McCABE': IThis is Michael McCabe. 

### SAG CORP.

### ~aShi~gton.D.C. Fax:2021797-252549

1

4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 Let me ask'NEMA whether or not there's

anything 'in developing •CI'P-2 that you would need any input from DOE, DOE staff, contractors, and second, ask Kathi or Oskars, particularly Oskars since he'sbeen involved, is, you know, what have you seen, in the development of TP-2 thatl you might feel that' would be .useful to provide.

So it's actually two questions, one for NEMA as far as any as4istance' you may need, and, Oskars, anything that you would like to offer as far as thoughts on what you' ve seen so far.

MR. GAUTHIEF.: John Gauthier from NEMA again., Mike; with r^gard to your first question, we have provided a copy 4o your office, to Kathi and, I think, Anthony, just; the other day. We would certainly appreciate yours review and some input as to what we need to be-- whit we've missed.

And I might say with regard to your question with regard tpOskars, we've been very privileged to have Oskars; involved in our process from almost the get-go.

202/797-2525 

### S A.9 CORP. Washi gton, D.C. Fax: 202/797-2525 49

I I' Let me ask'jNEMA whether or not thereIs 

### '. 2 anything 'in developing**.~P-2** that 

### you would need any**3inpu~** from DOE', ,DOE sta!ff, contractors, and second, 4 ,ask Kathi or Oskars, pairticularly Oskars since hets 5 been involved, 

### is, youkl\low, what have

### you seenin the 6 development of TP-2 thatlyou might feel that would be 

### 7 useful to provide. 8 So it's act$ally two questions, one for i 9 NEMA as far as any**as~istance** you may need, and, 10 Oskars, anything that

# Y9U would like to o,ffer as far 11. as thoughts on what you',!ve seen so far.' 12 MR•**GAUTHIE~:** John Gauthier from NEMA 13 again.. 14 Mike, with r,gard to your first question,
, 15 we have provided

# a: copy

## ~o YOur office, to Kathi and, 16 I think, Anthony, just f the other day. We would 17 certainly appreciate youf review and some input as to 18 what we need to be--**wh~t** we've missed. 19 And I**migh~** say wit;.h regard to your 20 question with regard tp' Oskars, we've been very 21. priv'ilegedto ha";-'e Oskarsiinvolvedin ourprocess from 22 almost the get-go.

202/797-2525 

### SA

# cj;**CORP~** washipgton,D.C. Fax:2021797-252550 1 2 3

5 6 7 '8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Oskars has been a very vocal and very

.insightful,par^icipant On our task force, which is sort of the developing gioup, and I think.perhaps only in the area of , the sampling formulae is' there ' . any modem of difference, butj I think that's a matter for discussion here.

Do you agree,, Oskars? V 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 --i well,, as I participated originally, this was, I elieve, the intent was fora private sector standard.

I did see sonie'opportunity to have single standard also for future„ really having -- rather than carrying around six.doc^ments, 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 w"

', which I also voiced and

202/797-2525 

### S A CORP Washi gton, D.C. ' Fax: 202/797-2525 50 1 Oskars has Ibeen a very vocal and very ! . 2 .insightful**.part:icipa~t ~nour**  task**force~** which is 3 sort of the developing**g~oup** I and I'thinkperhaps only

, , . 4 

### in the area of the samfling formulae'

### is.there'.any 5 modem of difference, but! I think thatts a matter for , 6 discussion here. 7 Do you agreel" Oskars? '8 .'MR.**PETERSON~:** .Well, if I can offer some ! : . . 9 thoughts, 'I .had opportuflity to review TP-2 draftf?, 10 participated in a·couplelof the meetings. I tried to, 11 convey the message 

## --I well, as I participated 12 originally, this was, I**~elieve,** the intent was for.a

, i 13 private sector standard'i 14 I did see**so~e** opportunity to have single 15**sta~dard** also for future I

## ireallyhaving

- - rather than
, 16 carrying around six

### doc~ments, having 'that in one i' .' 17 document. 18 convenience. So that's icertainly advantage, user 

### : 151 Also,i'f in

## f~ture there is a DOE standard 20 tracking the pri:vate

### se~tor document with DOE te·st 21 procedures would be muchleasier. ! 22 My concern wfs, which I also voiced and

2021797-2525 

### SAC; CORP.**was~i~gton,**D.C.. 

### Fax:2021797-252551
1 2 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18' 19, 20 21 22 TP-2 people followed up on it, I'd really like to see

that TP-2 is harmonized;as much as possible with the existing primary IEEE/ANSI standards, and this has been done also.

So really I,have been quite pleased what the progress has been, and there are obviously some fine points where I may;not agree immediately, but I guess if the directive from DOE is to work towards TP2 as a single document , well, then I think I see that as a green light.

MR. BALDUCC$: Great. Thank you very much,. Oskars. .

Any further questions , comments, or discussions with regardlto consensus standards for distribution transformer test procedures?

(No responses.) . CHAIRPERSON PPING: 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.

### S A CORP. 202/797-2525 Washington, D.C. Fax: 2021797-2525 

### 51 1 TP-2 people followed up:on it, I'd really like to see 2 that TP-2is harmonized:as much as possible.with the 3 existing primary**IEEE/~SI** 

### standards, and this has 4 .been done also. 5 

### So really I.have been quite pleased what 6 the progress has been, find there are obviously. some 

### 7 fine points where I**m~y;not** 

### agree immediately, but 

### I 8 

### guess if the directive ftom DOE is to work towards TP9 

### 2as a single document,**~ell,** 

### then I think I see that 10 as a green light. 11 

### MR. BALDucci: Great. Thank .you very , 

### 12 much, Oskars. 13 

### Any furtheIt I 

### questions, comments, .or 14 discussions with regardi to consensus standards for 15 distribution transforlll:errtest procedures? 16 (No response!.) 17 

### CHAIRPERSON**~PPING:** 

### Okay. The next item lS· 

### for discussion is the baric model.

### 19~EPCA**product~** are generally grouped into

, I i 

### 20 basicmodelspartlytorefuce the testing**requiremen~s** 

### 21 .for the

### manufactu'rersl~nd basic models are ,used in 22 the sampling process.

2021797-2525 SA

# ~ CORP. Washlrgton, D.C. Fax:2021797-252552 1 In the issues paper, you saw this draft 2 definition of a basic model. 3 Based on our discussions with NEMA, for 4 instance , yesterday,. tijis definition, although. it would work for an appliance, say, like a dishwasher, 6 it might not be appropriate for transformers because 7 your product is more unique. 8 So we would( like your help- on how we should define basic modeliIs so we don't over burden you 10 with testing requirements, but we can meet our 11 objectives, as well. 12 So we've already heard that there are some 13 problems with this definition of basic model. That 14 would be the first quest .on. 15' We'd also 1^ke to know if it would be 16 possible to combine a number of models into families 17 or groups, if we could group models that have the'same' 18 nominal kVA rating. 19 And this question was not on your 20 original agenda, and we'4 like to know if they could 21 be grouped by nominal! kVA rating according to 22'. normalized loss-data.

202/797-2525 

### S A C CORP Washington, D.C. Fax: 202/797-2525 52 

### 1 In the issuts paper, you saw this draft 2 definition of a basic mqdel. 3 Based on**outdisc~ssions** 

### withNEMA, for 4 

### instance, yesterday,**t~is** 

### definition, although. it 5 would work for an**ap~liarce,** 

### say, like a dishwasher, 6 it might not.be

### appropri~te for transformers because 7 

### your product is more**uni~e.·** 8 

### So we WOUld\ like your help· on how we 9 

### shoulddefinebasicmodells sowe don't ov.erburdenyou I 

### 10 with testing requireme*ts, but we can meet our 

### l 11 objectives, as well. 12 Sowe'vealreladyheardthatthere are some ; 

### 13 problems with this defin!ition of basic model. That ; . 14 

### would be the first questton. ; 15' 

### We'd**~lso l~ke**  

### to know if it would be I 

### 16 possible 

### to combine a

## nu~er of models into

## fami~ies 17 .

# 0:: groups, ifwe couldgr9uPmodels that have the'same 18 nominal kVA rating. 19 

### And this**quJ,estio~** 

### was not on your 20 original agenda, and we'4 like to know if they could 21 be grouped ,by nominal i 

### kVA rating according to 22' normalized loss' data.

2021797-2525 i ' 

### SA

# q CORP.**Washi~gton,**D.C. Fax:2021797-252553 1 And Oskars is going to talk about this 2 proposed equation and how it could be done. MR. BALDUCC^: Oskars. This is Anthony Balducci. 5 Before you. g.ve your presentation, I just 6 wanted to recognize Debo^ah Miller from the Assistant Secretary's Office. Sie's here. representing Dan Reicher. I just wanted to recognize her. 9 Thank you. 10 MR. PETERSONS: Well, just a very, very 11' brief comment. I have ben aware since day one when 12 I started on this project that for some manufacturers, 13 each transformer is prac ically its own -- 14 MR. BALDUCCI: Use one of the microphones, 15 either one. 16 MR.;PETERSONq ^: -- is its own basic model, 17 but I believe using such a normalized approach in 18 representing either losses -- efficiency is already 19 normalized -- one can really combine all transformers, 20 let's say, for which the same minimum efficiency 21 standard applies into one! basic model. 22 As I see what ;is done, for example, in TP

### S A C CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 53 i 1 And,Oskars iis going to talk about this 2 proposed equation and how it could be done. 3 MR.**BALDUCC~:** Oskars. I 4 This 'i,s

## 'Ant~ony Balducci. 5 Before you**g~ve** yourpresentation, I just 6 wanted to recognize DebofahMiller from the Assistant I 7 Secre,t:ary's Office. Sre's here, representing Dan 8 Reicher. I just wanted**~o** recognize her. l 9 Thank you. 10 MR. PETERSONf: WeI!, j.ust a very, very II' brief comment. I have

### b~eri aware since day one when 12 I startedonthisprojectjthat for some ma'nufacturers, 13 each transformer is practically its own --

, , j 14 MR. BALDUCCI:\ Use one of themicrophones) 15 either one. 16 MR.,

### PETERSON~: -- is its ownbasicmodel, 17 but I believe**usingsuc~** a normalized approach in i 18 representing either lossts

-- efficiency is already
I I ' 19 normalized

-- one canreal!lycombine all transformers,

, ! 20 let's say, for which

### t~e same minimum efficiency

I 21 standard .applies into one\ basic model. ! 22 As I see whatlis done, for example, inTP2021797-2525 SA

## ~ CORP.,'**Washi~gton,** D.C. 

### Fax:2021797-2525 

# l54 1 2 3

6 7

9 10 11. 12 13 14 15 16 17 18 19 20 21 22 1 and in Canadian standard, there were minimum

efficiencies or maximum losses applied to standard kVA ratings, and I believe all transformers in that

' •i 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 figured where 100 will be for -- 100 percent will be for loos that would correspond to mandated; efficiency woHHld be. sort of mandated loss level. If you go to higier efficiency, this will go in negative direction, and if you have lower efficiency, you have a h^gher losses.

So using thel 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 basicjmodel.

MR. COULSON:I With regard to NEMA's position. on the definitioi of basic model, we support the following definitionifor basic model. 

### S A CORP.. 2021797-2525 Washi gton, D.C. Fax: 202/797-2525 S4 1 1 

### and in Canadian strndard, there were minimum 2 efticienciesormaximum

### ~osses appliedto standardkVA 3 ratingsI 

### and I**belie~1** 

### all transformers in that ·i 4 

### nominal kVA rating can**b~** 

### combined in one basic model S either using efficienpy or normalized losses, 6 

### normalized in this manneir.

. ! 7 

### This is**act~al** 

### lossI 

### and you subtract 8 

### mandated loss and dividt and then add one, and you i 9 

### will endup with a figurel where 100 

### will be for

-- 100 10 

### percent will be for**lo~s** 

### that would correspond to i 11 

### mandated; efficiency W04ld be, sort of mandated loss' 12 

### level. If you go to

## higr~r efficiency, this will go 13 

### in negative direction,l and· if you have lower
, I 14' 

### efficiency, you have a

### h~gher losses. 15 So 

### using the!normalized approach, either ! 16 

### normalizing losses

# or**no~~lizi~g** - - well, .efficiency ! 17 

### by itself is normalized. I 

### cannot see**anyr~ason** 

### why 18 

### all transformers for**the~amenominal** 

### kVA group can't 19 

### be combined as one basic**modei~** 20 

### MR. COULSON:1 . i 

### With .regard to NEtJIA's 21 

### position.on the

### definitio~ of basic model, we support 22 the following definitionlfor basic model.

2021797-2525 SA

# GCORP.**WaShi~gton,** D.C. Fax:2021797-252555

1

3 4 5 6

8 9 10 11 12 13 14 15. 16 17. 18 19 20 21 22 Basic model would be defined by output

power, kVArating, '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,

202/797-2525 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 I 55 1 Basic model would be defined by output 2 powerI kVA 'ratingI 'su'ch as one of those tabulated in 3 NEMA TP-1, Tables 4.1 and 4.2, which include nominal 4 power, kVA +"atingi insulationtype; liquidimmersedor 5 dry type; number of phases, single or three; and the 6 voltage rating range, medium voltage and low voltage ,7 for dry type transformers. 8 NEMA believes that if the cr'iteria for 9 basic model, is met or o,ur proposed'definition is 10 accepted, grouping many aqtual production models of 11 the same nominal kVA rating,inone family of models is 12 acceptable. 13 With regard to the presentation that 14 Oskars just made, NEMA would like some additional 15 time. We don't at this point have a response to what 16 was presented before us, but we would like the 17, opportunity to review or even if any of our members 18 want .to comment'onwhat we've just,seen, we could open 19 it up at this point. I don't have a -- NEMA at this 20 point does not have a position. 21 22

2021797-2525 MR. PATTERSON: Wes Patterson, ABB. Oskars, onthe formula thatyoujustgave, SAG CORP. Washington, D.C. Fax:202/797-252556

4

6 7 8 9 10 11 12 13 14 15 16 17 18 1'9 20 21 22 would that be measured in your mind over a basic

modal, 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 4.n. 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. I



### S A G CORP. 202/797

-2525 Washington, D.C. Fax:.202/797-2525. S6 1 would that be measured in your mind over a basic 2 modsl, a kVA 'insulation phase kV rating for 180 days, 3 for 360 days? I mean it's not measured ov:er one unit. "

# . 4 'So it must be'measured over a population of something. 5 

### MR. PETERSONS: 'It is measured over a 6 population, and I think I mentioned**~n** my proposal 7 over'180 days. Well, that is flexible. Whatever is 8 reasonable. 9 

### MR. PATTERSON: So your concept is then 10 that this normalizedloss wouldbe overthe definition 11 of the basic'model for some defined period? 12 

### MR. PETERSONS: Right. 13 

### MR. PATTERSON: Okay.' Thank you. 14 MR. PETERSONS: Hopefully in" future the .15 population will not change that much. 16 MR. PATTERSON: 'Thank you. 17 MR. HOPKINSON: Phil Hopkinson, Square D. 18 In addition to the basic model definition 1'9 that Lake' Coulson just presented, I think that there 20 shouidbe, at least from a·Square Dposition and I may 21 represent**m~re** than a Square D position, a list of 22 exclusions for the basic model.

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### CORP. Washington, D:C. Fax:.2021797-2525'57

2 3

5 6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 I would propose that the exclusions should

include what is listed in the scope section, 1.1 of NEMA's TP-1, 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 is or what you were describing there were transformers 

### SAG 'CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 57 1 I wouldpropose thatthe exclusions should 2' include what is listed in the scope section, 1.1 of 3 NEMA's TP-1, and would include then liquid filled 4- transf.ormers.below ten kVA, dry type transformers 5 below 15 kVA, drive transformers,. both AC and DC, all 6 rectifier transformel;'s, and transformers designed for 7**h~gh** harmonics, all auto transformers. It .would 8 include

### non-distrl.buti~n transformers,. such as those 9 ·for uninterruptible power supplies. It would inciude 10 .speciaJ,. impedance, regulation in harmonics 11 transformers, regulating'**t~ansformers,** sealed and 12 nonventilated transformers, retrofit, transformers, 13 machine tool transformers, welding**transform~rs,** 14 transformers with tap ranges greater than 15 percent, 15 transformers with frequency other than 60 hertz, 16 grounding transformers; and testing transformers. 17 Inaddition, I wouldalso addtransformers 18 for unusual**te~perature** rises 19 MR. LEVY: This isEdLevyfromDepartment 20 of Energy. 21 I take it what you're talking about here 22 is orwhat you were describingthere were transformers

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.1

3 

### 5 6

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

202/797-2525 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 58 

### 1 that would be excluded from coverage of the test 2 procedures? 3 

### MR. HOPKINSON: These transformers would 4 not be part of the basic model. 5 

### MR. LEVY: 

### WeLL when you say "the basic 6 model," .the purpose for

-- there .would be presumably 7·. 

### several basic models ofanymanufacturer depending on 8 .what was produced. The purpose of .the concept oia 9 basic model 

### is to group different models of 

### io transformers that a givenmanufacturer.produces'so as

.11 to limit the testing burden.

12 I inferred from what you were saying that 13 the exclusions that you described would be equipment 14 that would not evenbe subject tothe standards', would 

### is not be subject to the testing at all. Is that your 16 intention? 17 

### MR. HOPKINSON: Yes, that's correct. 18 

### MR. LEVY': 

### Okay. Which I see is something 19 we certainlyneed·to deal with as part of this entire

, . 

### 20 effort, but it's a different question from grouping

. . 

### 21 those transformers**~hich** 

### are coveredintogroups so.as 22 to eliminate or not**'el~minate,** 

### but reduce**theamou~t**

'2021797-2525 

### SAG CORP. Washington, D.C. Fax:2021797-252559 1

3 4

6

8 9 10 11 12 13 14 15 16 17 .18 19 20 21 22 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. MR. BALDUCCI: Michael has just 'made a 

### S A G CORP. 202/797-2525. .. Washington, D.C. Fax: 202/797-2525 59 

### 10ftesting that's required. 2 

### MR. HOPKINSON: Yes, we agree with that. 3 I think those transformers that are includedwould fit 4 the definition that Mr. Coulson presented from NEMA, 5 those transformers that are not included,**~nd** 

### should 6 

### include some list, and the list that we propose is the 7 

### one.that I 

### just mentioned. 8 

### MR. PATTERSON: Wes Patterson, ·ABB. 9 

### Edward,. the list of exclusions that Phil 10 just ran off pertains to in the proposed test 11 procedure draft, there's a definition of distribution 12 transformer which included all of those products. So 13 if there's a defini-tion in 

### the test,procedures, you 14 also have to have an exclusion clause. 15 Thank you. 16 MR. 

### GAUTHIER: John Gauthier. 17 

### Just by way of reference, TP-1 and TP-2 .18 scope identifies these listsof equipmen.ts,asexcluded 19 from both coverages. So this 

### is not new, but really 20 

### it.'s by way of just verifying it. We've .already 21 covered 

### it. 22

2021797-2525. MR. 

### BALDUCCI: Michael 'has just ·made a 

### SAG 

### CORP. Washington.D.C. 

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4

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

2021797-2525 

### S A G CORP. Washington, D.C. Fax: 2021797-2525 60 1 good suggestion. One of the things that we're going 2 to add on the agenda would be coverage of the test 3 standard and which transformers would be covered·by .4 the test·standard.

5 Before we move to that, ·do we have any 6 other questions or comments or concerns regarding 7 basicmodel either from the panel up here or anyone in 8 the audience? 9 MR. WILKS: .Alan Wilks, ARMCO, 10 I understand that the normalized formula 11 given wouldbe an accumulation of an average of all of 12 the units that go in to make up that model, and s.ince 13 it is an average, I would assume also that anyone 14 unit or units could .exceed ·the minimum efficiency. 25 However, the average would be necessary to be below; 16 is that correct? 17 MR. PETERSONS: Yes.. 18 MR. BALDUCCI: Further**ques~ions·** or 19 comments regarding basic model? 20 (No response.). 21 MR. ·BALDUCCI: If not,I would suggest we 22 move·in to have a short discussion on coverage of

202n97 -2525 

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2 3 4

6

8. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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, onset cohorts upon 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

202/797-2525 SAG CORP. Washington, D.C. Fax: 202/797-2525 61 1 transformers. We heard some comments .of what's 2 covered and what's not covered. 3 Michael, did you have any comments to 4 start that off with or no, not to put you on the spot 5 at all? 'Because I think there's a little bit of 6 confusion of" where we are, what the test standard 7 would cover I' and I think we need to clarify that 8. before we press on. '9 MR. McCABE: Yeah,. this 

### 'is Mike McCabe. 10 Building on what Ed Levy has said, the 11 basic model, the concept for that has historically 12 been to recognize that while. a manufacturer may have 13 a number of individual models and that. some of them 14 may Ol1ly' be differentiated from others based on 15 geometry or features that do not affect efficiency, 16 that we have had to try'-.,. we've come up with the 17 concept of basic model in order to bin, cluster, 18 group, or'set cohorts up..on the basis of efficiency. 19 So that if you have features that do not 20 affect.. efficiency, that there's no reason to, one, 21 .subject all of those differentmodels to**t~stingi** that 22 you can just take and clump them into one cohort and

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4

7 8 9 10 11 12 13 14

19 20 21 22 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, II 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 

### S A G CORP. 202/797

-2525 Washington, D.C. • Fax: 202/797-2525 

### 62 1 test tnem.for the.purposes of this program for making

\ 

### 2 ratings on efficiency. 3 That,doesn't necessarily mean that those 4**ar~** 

### all ,the same models as.you would consider them 5 because you're**mark~ting** 

### products to a very diverse, ·6 very specia.lized application, and you know, I don't 7 

### understand that market. I'll attempt to understand 8 that market as well as you do. ' That',s your market, 9 and you're the experts there.

- 

### 10 But we're looking for a way'to reduce the 11 burden. Similarly, we're looking to understand and 12 .appreciate your comments with respect to coverage. 13 The comment that Lake made at the outset 14' about the size limit that we've gone'down too small, 15 the quarter'kV transformer, that it/s too small and 16 shouldn't be covered, I'd be interested in hearing

, " 

### 17 ,your comments as to why the proposed coverage that's' 18 in the test procedure,' why that should be adjusted, 19 what shouldbe eliminatedandwhy, inorder,toprovide 20 that rationale because when we come out with the 21 proposedrule, there willbe a debate as towhether or 22 not a quarter kV transformer should or shouldn't be 'SAG 

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11 2 3 4

7 8

10 11

16 17 18 19 20 21 22 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

202/797-2525 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 63 

### 1, covered. ·2 If'we're going to take·a position and say 3 they should not, it's not going to be because Lake· 4 said so, because Valerie., representing Natural 5 Reso.urces, Canada, mayhave

# avery**diff~rent** 

### position. 6 .So we'd like to have an open discussion 7 and the rationale in order so that we can make a 8 reasonable decision andput that into the language in, 9 the proposed rule.. 10 

### MR. ROLLING: Dave Rolling from Cooper**~1** 

### Power Systems.

121can address parts of the exclusion, not 13 all of it. Generally speaking, eachof the items that 14 

### was identified for exclusion has some particular 15 characteristic about it as a product that makes it 16' 

### difficult to let energy efficiency be the overriding 17 need. 18 

### For instance, when you're designing a 19 rectifier transformer, many times there are -- it has 20 voltage in a kVA, but it also has a certain set.of 21 load characteristics based on the load it's driving 22 that has to be designed to, .wherein if you don't do

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4 5

7 8

10, 11 12 13 14 15 16 ±7. 18 19' .20 21 22 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 

### S A G' CORP 2021797-2525 • Washington, D.C. Fax: 2021797-2525 64 

### 1 that, the product won't work properly. 2 So efficiency, while you could try to get 3 

### it, it cannot be your overriding consideration. 4 

### Another situation would be if you're 5 tryingtoretrofit a transformer intoa building, into 6 a particularbasement area orsomething likethat, you 7 have dimensional constraints, and so the overriding 8 constraint in that transformer design doesn't become 9 efficiency. You may riot have room to work with in the 10, 

### location you're trying to put the transformer to 

### hit 11 the type of efficiency that the minimum efficiency 12 standard would want you to make. 13 And you**cou~d** 

### go**do~n** 

### that whole list of 14 transformers and come upwith the fundamental reasons 15 that each of them. has some other overriding design 16 constraint. 

### iT MR. LEVY: Let me raise a question with 18 you, Dave. 19 This is Ed Levy again. 20 

### MR. ROLLING: Yes. 21**MR~LEVY:** 

### The question here is whether 22 or not a particular transformer is'appropriately'

2021797-2525 

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.Washington, D.C. Fax:2021797-252565 1 2 3 4

6

10 11 12- 13 14 15 16 17' 18 19 20 -21 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. 22 11 MR. McCABE: How's that? 

### SAC CORP. Washington, D.C. Fax: 202/797-2525 202/797-2525 65 

### J. described as a distripution transformer. That's what 2 

### the department 

### is charged withregulating or at least 3 examining the 

### issue of regulation. 4 And .if it's a distri.bution transformer, 5 

### then it wouid be covered. Now, that does· not mean 6 that thepointsyou're raisingare not appropriate for' 7 consideration. Those points may affect the precise 8. test procedure for that kind of transformer or the 9 standard level for that kind of transformer. J.O So the question here 

### is not so much what J.J. distinction should be made among transformers, but J.2 rather at a sort of broader level..What should be 13 properly classified as a distribution**transfor~er** 

### and J.4 what should be classified as not being a distribution 1S 

### transformer? 16 

### I don't know if your comments really 17 address that question. 18 

### MR. McCABE: Mike McCabe. 19 

### Excuse me for interrupting here. Let me 20 

### add one other point.

22

202/797-2525 

### MR. BALDUCCI: Michael, leave it on. MR. McCABE: How's that? 

### SAG 

### CORP. Washington, D.C. Fax:2021797-252566

J. 2

4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 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'pa.ckaged 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 

### 'S A G CORP

. 202/797-2525 Washington, D.C. Fax: 202/797-2525 66 1 Many of us**a~e** much like myself in being 2 task oriented and look very specific in using some 3 examples, and so to add to what Ed has said, we can 4 deal with many of those issues you 'raised in the test. 5 procedures by establishing different categories of 6 products. 7 The first question now that we have is 8 whether or not .:!-t ap'propriately is a covered product 9 and whether or not it is a transformer. 10 So, for example, one of the first tasks I 11 had to do with this program was to define whether or 12 not 

### a 'packaged terminal air conditioner was a covered 13 product for this program. At that time', the program. 14 was strictly dealing with residential products. 15 A packaged terminal air conditioner, as 16 you mayor may not be familiar with them, are through 17**th~** wall air conditioning products that are used in 18 commercial erivironments, typically in**~otels.** It" s a 19 commercial product, not a'residential product. It· 20 looks like a through the'wall room air conditioner, 21 but it is not covered by the program, but we had to 22 come up and define it in our regulations as what a

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8 9 10 11 12 13. 14 15 16 17 18 19 20 21 22 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 maybe 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.

202/797-2525 

### SAG CORP. Washington, D.C. Fax: 2021797-2525 67 1 . .PTAC was in order to exclude it from the program 2 because the programat thatpoint in time was intended 3 for residentialproducts, not for commercialproducts. 4 Sothat.one questionwe'd be looking to is 5 is this a transformer. Is this a product that was 6 intended to be covered by the legislation when the 7 legislation directed DOE to issue a determination? 8 Secondly, there maybe products that are, 9 in fact, covered products, but they can't be tested. 10 The test procedure physically cannot be able to cover 11 those products. 12 Another example"is with respect to water 13· heaters. The test procedures that,we've established 14 for water heaters are limited in their ability to 15 evaluate certain sizes of waterheaters. So while for 16 the purpose of the program a water·heater 

### a 17 residential water heater is a residential water 18 heater, it has a very broad definition. 19 Then in the test procedure we have a 20 definition as to waterheaters that are coveredbythe 21 test procedure, which is a smaller set than what is 22 covered by**th~** program.

2021797-2525 SAG CORP. Washington, D.C. Fax:2021797-252568

2

4 5

8 . 9 10 11 12 13 14 15 16 17 18 19. 20 21 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, 22 11 • which those classes recognize some of those 

### S A CORP. Washington, D.C. Fax: 202/797-2525 2021797-2525 68 , 1 So by defining the definition of water \ 2 heaters for' coverage under test proceduresI we 3 eliminatedproducts, some of whichyou're ge,tting to, 4 that physically couldn't. test, and there will be 5 others ,that -..., maybe other issues as'to why it can't 6 be tested or why they shouldn't be covered. Theyire 7. not distribution transformer, and. I'm not -- I have a 8 hard time in**t~is** industry since a chemical engineer 9 ·canunderstandwater flowing" but why current goes one 10 way and electrons go the other, that's beyond me. 11 (Laughter.) 12 MR. McCABE: But I'm looking for you to 13 give us direction'. So instead of going like that. 14 (indicating), to say thi's is the reason why. This is 

### 15 what makes sense. 16 Granted there are +easons why you cannot 17 design any more, efficiency into 

## a: product because of 18 space lim;i.tations, but·that hasbeen addressed inmany 19, instances before,. and Chuck Hastings when he was 20 working with some of thE;! residential products can 21 'appreciate that we can**es~ablish** classes, and·we have, 22 which those classes recognize

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3 4

6 7

10 11 12 13 14 15 16 17 .18 19 20 21' .22 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 

### S A G CORP. , 2021797-2525 Washington, D.C. Fax: 202/797-2525 

### 69 1 limitations, and through the process of establishing 2 classes, that if it gets intoa'standards venue,**thos~** 

### 3 classes mayor may not be subject to standards. 4 So what we're looking for in coverage is: 5 is this a transformer? Is this a product that should 6 be 

### covered by this program? Is it a product that's 7 covered by TP-2? .Is it a product that's covered by 8 the ANSI standards? Is it a product that we should 9 consider,for test procedures? 10 

### But then when it gets into standards, 11 there's a.whole different set of questions that we're 12 going to have to address. 13 

### MR. ROLLING: Unfortunately the choice of 14 words, "distribution trans.formers,":that was in the 15 original legislation is very ambiguous terminology, 16 and I think if you had the folks in this room define 17 that terminology, you'd come up with at least 20 .18 different definitions probably within this room. 19 

### So we start from that rather broad 20 categoriza:tion in the original legislation, and that

. . 

### 21 doesmake this difficult, 'not overlydifficult,but·it

., , 

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

2021797-2525 

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### CORP. Washington, D.C. Fax:202/797-252570

1'

7

10 11 12 13 14 15 16 17 18 19 20 21 22 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 the draft document, test proccdures,'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 SAG.CORP. 202/797-2525 Washington, D.C. Fax:202/797-2525 ,

## . 70 

### l' definition of distribution transformer first. 2 MR. McCABE: This is Mike McCabe. 3 

### That',s key. Everyproduct that we cover, 4 the first thing that we have to do is define what that 5 product is so that we then know what is covered and 6 what we're talking about. 7 

### MR. PATTERSON: Wes Patterson with ABB. If you go to page 16 of the draft 9 document, testprocedures,'there's a definitionbythe 10 DOE of what a distribution transformer is. In this 11 definition, theyhavetakenwhathasbeenhistoricall,y 12 

# a definition ,_in'the industry and broadened it to, 13 include things that the industry typically. did'not 14 include as distribution transformers, point one. 15 

### Point two says that distribution 16 transformer means a transformer for transferring 17 energy fromprimarycircuit to secondarydistribution 18 circuit, or customer service circuit or between 19 circuits on the customer's premises. ,20 

### A very strong case can be made that a

21 quarter kVA transformer'never meets that paragraph; 22 never, and almost every product that**~hil** 

### mentioned

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### SAG'CORP. Washington, D.C. Fax:2021797-252571

2 3

5 6

9 10

'12 13 14 15 16 17 18 19 20. 21 22 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 --

2021797-2525 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 

### 71 1 never meets that paragraph. 2 So all that wasI 

### all that Phil was trying 3 to do was to elaborate**o~** 

### the specific instances of 4 ' that paragraph which do not pertain, but people 'can 5 t'ranslate fromthe followingparagraphtobe included: 6 So we have a confusion between,these two 7, sentences 

### in. this paragraph,**~nd** 

### all we're trying to B 

### do is clarify either that' or maybe in your test 9 procedure' you can just remove the definition of 10 distribution transformer and pick it up over in the 11 energy efficiency standard later on.down the road and 12 not trY to establish'definitions in this document. 13 Just establishhow we're 

### going to test them,.which is 14 also what's normally done 

### in the standards'industry. 15 

### MR. LEVY: But we do need to establish a 16 definition, and I think that the'comments that we're 17 getting here on this issue are entirelypertinent and 18 helpful, but I would ask you also how is the second 19 sentence too broad. You said at the outset of your 20· comment h,ere that the'second sentence 21 22

2021797-2525 

### MR. PATTERSON: For instance MR. LEVY:

-- doesn't incorporate SAG CORP. Washington, D.C. Fax:2021797-252572^ 1 2 3 4 5 6

8

10 11 12 .13 14 15 16 17 18 19 20 21 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

202/797-2525 

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### 1 MR. PATTERSON: For instance 2 

### MR. 'LEVY: things that would be 3 

### considered distribution transformers. 4 

### MR. PATTERSON: It says, "For the purpose 5 

### of this .DOE test procedureI 

### transformers of the 6 

### following,ratingare included: primaryvoltage of 480 7 

### to 35 

### kV." Okay? 8 

### MR. LEVY: Yes. MR. PATTERSON: Starting off with a 10 primary voltage c;>f 480 and contending that that 

### is a 11 distribution class voltage is counter to what the 12 entire industry has done for the past 100 years. 13**D~stribution** 

### is usually rated much higher than 480. 14 

### MR. LEVY: Where would you set the floor 15 on that? 16 

### MR. PATTERSON: Personally I would set it 17 

### at 1.2 kV and above. You can sample all of the 18 manufacturers here and see where they would'put it, 19 but most of them probably will not' put 480 volt 20 because that's usually an application vc;:>ltage, not a 21 ,distribution class voltage. 22 

### okay.

2021797-2525 

### The next thing is that' between SAG CORP. Washington, D.C. Fax:2021797-252573 1 2.

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 .22 liquid and dry there are two definitions. Is that

right? Rated liquid from ten kVA to 2,500 dry, from ten kVA. No, it's a -- but I thought that was changed 'someplace,'that there was'now a definition.. I guess it was with the .25 kVA for dry.

We're trying to come up with a definition for distribution different between liquid,and dry when we extended it to .25 kVA. That's not justifiable by any sense. MR. LEVY: Which is not. justifiable?

MR. PATTERSON: Trying to say -that transformer because of its insulation class determines whether or not it's distribution. The insulation class has nothing to do with distribution. It's the application of the product that has to do with whether or not it's"distribution.

The most-correct statement in this whole paragraph is 'sentence one. All the rest of it is you have problems with it. So you have to get more explicit if you're going to put that definition in this document.

And all Phil was trying to do was. to

2021797-2525 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 73 1 liquid and dry there are two definitions.' Is that 2. right? Rated liquid from ten kVA to 2,500 dry, from 3 ten kVA. No, it's a -- but I thought that was**c~anged** 4 'someplace, that there was now a definition.. I guess 5 it was with the .25 kVAfor dry. 6 We're trying to come up with a definition 7 fordistributiondifferent between liquid,anddrywhen 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 t'o say-that a 12 transformerbecauseof its insulationclassdetermines 13 whether or .not it's distribution. The insulation 14 class has nothing to do with**distri~ution.** It's the 15 application of the product that has todo withwhether 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**docume~t**.

.22 And' all Phil was tryirig to do was. to

2021797-2525 SAG CORP. Washington, D.C. Fax:2021797-252574

5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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.

2021797-2525 

### SAG CORP. Washington, D.C. Fax:2021797-2525 74 

### 1 become more explicit. When you look at his specialty 2 

### transformers, they are not being deployed in 3 distribution class service. They are being deployed 4 

### in end use service. They've being hooked up to a 5 piece of equipment like the transformer that's inside 6 that light box, and that, shouldn't be considered 7 distribution. 8 

### MR. LEVY: Well, we need to get that on 9 the table now. So I think 10 

### MR. PATTERSON: Thank you. 11 

### MR. LEVY:

-- that's very helpful. 12 MR. BALDUCCI: 

# no we have any other 13 

### comments orquestions or**clarificat~ons** 

### onthatpoint? 14 

### Oskars, you look like you were ready to 15 

### say something or no? 16 

### MR. PETERSONS: 'Well, the way I arrived at 17**that,def~nition,** 

### I believe, was the first part comes 18 

### from IEEE dictionary and inclusion or exclusion,I 19 

### think, carne from data in a determination of this, the 20 

### voltage ratings,'but that can be**modif~ed.** 21 

### MR. HOPKINSON: -This is Phil Hopkinson 22 

### from Square D. 'SAG 

### CORP. 2021797-2525 Washington. D.C. Fax:2021797-2525.75 1 2 3- 4

7 8 9 10 11 12 13 14 15 16 17 18 1.9 20 21 22 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

202/797-2525 

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### 7S 1 

### I was just reading from the Federal 2 Register on October 22nd of 1997. It says, "The Oak 3· Ridge National Lab analysis," which we presumed is a 4 .forerunner for this·meeting today, "did not con,sider 5 

### transformers**wh~ch** 

### are not continuously connected to 6' 

### a power' distribution system, such as distribution 7 transformer..For example, transformers that are part 8 

### of machinery which are switched off from electrical

, 9 

### power were considered by the study as a component of I 

### 10 the .machinery circuit and not part of the power 11 distribution circuit.' Also special purpose control 12 and signal transformers," whichthese quarterkVAs, by 13 the way, would**represent~** 

### "as well as bulk power 14 transformers were excluded frbm considerationbecause' 15 theyarenot classifiedasdistributiontransformers." 16 

### So that our position would be that 17 transformers 

### like control power transformers, which 18 

### the fractional kVA transformers represent, are not 19 

### distribution transformers. 20 MR. LEVY: 

### Just to follow on to that, if 21 you go on in the next paragraph, it articulates the 22 definition' in terms of primary voltages and

2021797-2525 SAG 

### CORP. Washington, D.C. 

### Fax:2021797-252576

1 2 3

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 percent would be used as 

### S A G CORP Washington, D.C. Fax: 202/797-2525 76 

### 1 capacities,**statin~** 

### that. the language that you just 2 described would be accepted.from that. 3 

### Are you saying that in some of these 4 capacity ranges, for example, that there are.no 5 transformers that don't fall within these accepted 6 areas of distribution? 7 

### MR. HOPKINSON: I would say that I would 8 agree with the definition that primary distribution 9 transformers are above 1.2 kV class'primary, and 10 secondary distribution transformers are those below 11 1.2 kV class primary, but that fractional kVA up arid 12 below ten kVA would be considered as excludedbecause 13 they arepredominantlynot distribution transformers. 14 

### MR. LEVY: 

### Now, when YOll 

### say 15 "predominantly," I mean, how predominant? 16 

### MR. HOPKINSON: Well, as anexample, 75 to 1 7 80percent of those transformerswouldbemachine tool 18 control type transformers. They'dbe part of another 19 .piece of equipment. Theywouldn't be used separately 20 as a power transformer. MR. LEVY: 

### So would you say 15 'to 25 22 percent would be used as**~-**

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### SA

### G CORP. Washington, D.C. Fax:2021797-252577 1 2 3 4 5 6 7 8 9 10 it 12 13 14 15 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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# ., 77 

### 1 MR. HOPKINSON: Probably. 2**MR~** 

### LEVY: --transformers? 3 

### MR. HOPKINSON: Probably. 4 MR. 

### LEVY: Okay. 5 MR. 

### BALDUCCI: Any other questions or 6 

### comments? Randy. 7 

### MR. BARNES: Hi. I'm Randy Barnes, Oak 8 

### Ridge National Laboratory. 9 

### We included the smaller transformers in 10 

### our determination study' for 'completeness. We 11 recognize that they contributed very little to the 12 overall kVA that was used 

### in distribution 13 transformers.

, 14 

### One,comment on thevoltage levels. That f

### s 15 always been a little confusing to me. In the lower 16 voltageclass, transformermanufacturersratethose at 17 1.2 kV, which is really an insulation class, and then 18 the higher

-- the medium voltages are rated as a 19 voltage class. 20 ' Where if you look at the IEEE standards, 

### 21 the low voltage is 

### really defined as less than 1,000 

### 22 volts. So the transformer industry seems to mix an

2021797-2525 SAG CORP. Washington, D.C. F=ax:2021797-2525• 78 1 2 3 4. 5 6 7 8

.10 11 12 13 14 15 16 17 18 19 20 21. 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, T 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 22 II class.

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### SAC CORP. , Washington, D.C. Fax: 202/797-2525 . 78 1 insulationclass when theytalk about lowvoltage,'and 2 then they talk about operating voltage cl·asses when 3 they go to medium voltage. 4 It's not an important issue, but it is

J 5 kind of a mixture, the way they look at things. 

### 6 Do you want to comment on that? 7 

### MR. PATTERSON: I'll' comment. Wes 8 Patterson, ABB. 9 Within'. the design industry of these .10 products, I don't think.there's everbeen

## a confusion 11 . betweena system class rating and its actual operating 12 .voltage. So what we have delineated in the standards 13 are·two distinct concepts: the**ope~<:tting** voltage of 14 the system itself and its system class rating. 15 So I don't really believe there's any 16 confusion on that· topic, .and the 1.2·kV class 17 typicallycoveredeverythingthatwas greaterthan 601 18 volt and less than 1,200 volt. So if you had a system 

### 19 sitting out there that was a 1,100 volt**sy~tem,** the 20 actual grid itself, where another grid t:qat was 1,000 21 volt system, we grouped**t~em** both**·togeth~r** into 1.2 kV 22 class.

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### CORP.· Washington,D.C. 

### Fax:2021797-252579 1 2-

5 6

8

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

202/797-2525 

### S A C CORP Washington, D.C. Fax: 202/797-2525 79 1 Thenwe would sizethe lightningarresters 2 to support the 1.2 kV class, right? So all of the 3 standards were built around the system class, but the .4 a.ctual specific voltage, operating voltage was

5 anywhere from the one class to the next class. 6 MR. BALDUCCI: Thank you. 7 I'd like to ask again if we have any 8 questions orcomments or clarificationswithregardto 9 this issue. Again, if you feel-that your comments or 10 concerns aren't expressed, please·do submit those in 11 writing, and again, we will determine. the comment 12 period closure at the end of the workshop.. 13 How's everyone feel?· Are we ready to take 14 about a··five or ten-minute break right now? It's 15 about 10:28. Why don't we try and be back here at 16 10:407



# . 17 (Whereupon, the foregoing matterwent off 18 the record at 10:30 a.m. and went back on 19 the record at 10:44 a.m.) 20 MR. BALDUCCI: If everyone would like.to 21 take their seat,**w~'re** going to get started .here in 22 about 30 seconds.

202/797-2525 SAG CORP. Washington, D.C. 

### Fax:202/797-252580 1 2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 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 22 II orders to start to carry the thing myself. 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 2021797-2525 80 

### 1 I hope everyonehada nicebreakand found 2 the coffee and doughnuts and everything else okay. 3 

### If we'd like 

### to take our seats, we're 4 going to jump onto, the next topfc, which is the 5 sampling plan for units to be tested, which, Oskars, 6 I'm told you will lead that discussion: 7 Hold on one second. 8 

### MR. HOPKINSON:" Anthony, unfinished 9 business.· ·Could I mention something more on 10 fractional kVAs? 11 An 

### area that occurredtome while I was in 12 the break was,the**ques~ion** 

### of the cost of testing of 13**sm~ll** 

### kVA products,'and frankly, the testing cost for 14 fractional kVA transformers can take on higher than 15 the sales value of those products, and I think that, 16 therefore, both for the application, as well ,as the 1:] 

### difficultyintesting, that there isanotherrationale 18 for why those'products should be excluqed. 

### 19 MR. BALDUCCI: Thank you, Phil. 20 

### MR. PETERSONS:' Well, we are now at the 21 third topic,. sampling, and kathi sort of gave me 22 orders to start to carry the thing myself.

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1

3 4-

8 9 10 11 12 13 14 15 16 17 18 (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.

202f797-2525. 

### S A G CORP. Washington, D.C. Fax: 202/797-2525 81 1 

### (Laughter.) .2 

### MR. PETERSONS: Well, sampling reallyhas

3 been the toughest topic for me to come to sort of any 4 closure, .and as 

# a result, even at·this stage I'm 5 offering two plans for consideration. 6 Some of you NEMApeople may recall that 7 ..about three years ago I mentioned a sampling plan, a 8 very tough one,·wher.e 95 percent of the population 9 should pass with a 95 percent confidence limit. 10 

### Then I got some informal feedback. The 11 next time, I guess, when I talked to Paul at a 12 Transformer Commit;tee meeting inVermont, .then I said. 13 the mean.should pass, again, with an extremely high 14 confidence level. 15 Right now things are even more relaxed, 16 and maybe four years ago when I started this project 17 I was a brash, 62 year young man -- 18 (La:ughter**~**

### ) 19 

### MR. PETERSONS: -- and now I'm a more 20 mature 66 year old. 21 (Laughter.) 22 

### MR. PETERSONS: So more realistic.

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### SAG 

### CORP. Washington, D.C. Fax:2021797-252582

2 3

7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 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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### S A G. CORP. Washington, D.C. Fax: 202/797-2525 82 1 Well, it has been obviously a learning 2 process for me, really what is de'sired under EPCA, 3 ,what has'been done before. I was verymuch influenced . 4 also by Canadian standard where ,there 

### is no negative'

5 tolerance,and, well, th,at's the result. 6 Well, on sampling I have assistance from 7 my colleague at the Electricity Division, Ken 8Stricklett, who is here, and also we have help from a 9 person 

### in Statistical Engineering Division, Mark 10 Vanjel. So some of the work and really,the mos't 11 signific.ant are due to these two gentlemen. 12 What I'm going to do, 'I'll present a 13 tutorial. What, do these two sampling plans mean in 14 terms of probability, density**cu~ves,** and some 15 abbreviated comments about them?, 16 Well, we get to method one, which is 17 really the, one which is used for consumer products, 18 WqS proposed also for motors. The sort of typical 19 wording, what you see in CFR, in the Part 430,is, . 20 well, the first paragraph. 21 Really,the test method·seeks so-called 22 repres'e'nted**val~e** which can'be either the mean of the

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2 3

5 6

8

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

### S A G CORP 202/797-2525 Washington, D.C. Fax: 202/797-2525 83 1 sample or lower confidence limit of the estimated 2 population divided by this factor, .999, and that·is' 3 based on six percent loss tolerance as in ANSI 4 'standards, so to, translate it into efficiency 5 tolerance. 6 Criteria fOl:; compliance is that 7 represented valueas obtainedhere should be equal or

. \ 8 higher than the mandated value or really the value on 9 the minimum efficiency in the standard. 10 NOW, statistical methods and sample size. 11 The wording isverygeneral, reallynot specified. It 12 doesnIt tell you what the sample size is, does not 13 tell whether you should use T test', Z test, and I 14 think'by design it's left quite open since 'you know 15 your product anq certain 'flexibility can be allowed. 16 Well, if you use T tes,t, which is one of 17 the tests for determining confidence limits, you 18 select your sample size, measure losses/compute 19 efficiency or continue working with losses, and then 20 compute your statistical parameters, X bar, which is 21 mean standard deviation, which is in text denoted by 22 capital S; ,standard error of the sample, which in

,202/797-2525 

### SAG 

### CORP. Washington, D.C. Fax:2021797-252584 1 2 draft is -- we use the symbol, capital SE, and in

.parentheses X, and then lower confidence limit.

And having done this test, the represented

5

8

10 11 12 13 14 15 16 17 18 19 20- 21 22 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 mandatedlevel, 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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1 84 1 draft is

- - we use the symbol, capital SE, and in 2**,parenth~ses** X, and then lower confidence limit. 3 'Andhavingdone this test, therepresented ' 4 , value for cO,mpliance. 5 Now I shall go to just show some 6 distributioncurves. Let's,sayyourentirepopulation 7 for the basic model'is representedby this P zero, and 8 then the probability density for the mean of five 9 units. It's this curve here. 10 Well, the manufacturer is guiteprudent. 11 Here is the mandated'level, and he operates slightly 12 above the mandated,'level. 13 Well, the next chart is more busy with 14 vertical lines. Here we have taken specific**sa~ple** of 15 five denoted by X bar. So sampies taken here. 16 Now,**~already** one of the things that we 17 need we already have, and then'we compute the lower 18 confidence limit. This one here goes down, and then 19 divide this by this factor, .999, and come up again,. 20 Well, for compliance we take the lower 0,£, 21 the two values, which is X bar here, and it must be

,22 higher than mandated efficiency. In,case the other,

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



### SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 85 

### 1 one is lower, then that must,be at or equal the 2 mandated efficiency. . 3 Well, inbothcases - - well, this one here

4 and this one here· must be about the mandated 5**efficiency~** 6 

### Now, let's look at possibility. You do 7 operate above .the mandated efficiency level, but 8 suppose if,you took the sampleyou were less luckyand 9 you ended up somewhere here. Well, obviously**~-** 10 

### MR. BALDUCCI: Oskars, I'm just go{ng to 11 change a term on you. You keep saying "mandate 12 

### efficiencies." That implies an energy efficiency 13 st'andard. We don't mean a mandated efficiency. We 14 mean a rated efficiency. So instead of "mandated,1I 15 can we used "mandated"

-- instead of "mandated" use 16 "rated efficiencyll for this? 17 

### MR. PETERSONS: Okay. 18 

### MR..BALDUCCI: And that's what weIre 19 

### talking about with the,sampling plan. It's not a 20 mandated efficiency. It**~ould** 

### be a rated efficiency. 21 

### 22

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### Just that clarification with that term. MR. PETERSONS: Thank you. 

### SAG CORP. Washington,D.C. .Fax:2021797-252586 1

3

8

10 11 12 13 14 15 16 17 18 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 

### SAG CORP. 202/797-2525 . Washington, D.C. . Fax: 202897-2525 86 1 

### MR. BALDUCCI: Thank you. 

# '. 2 

### MR.,PETERSONS: All right. Well, there is 3 

### a possibility even with this population, quite

# ahigh 4 

### probabilityorreasonable probability to fail, and if 

### 5 you do operate exactly at the rated efficiency, the 6 

### bestwhatyou canachieve fordemonstratingcompliance 

### 7 would be 50 

### percent. 8 

### So obviously if you do operate at the, 9 

### rated efficiency, you will'not risk failing your 10 

### production run, where you only have 50 

### percent of 11 

### probability of demonstrating your compliance. You 12 would,try to move your production higher than this 13 rated efficiency. 14 'Well, here is a chart, sort of family of 15 curves which are not available in your handout. The 16 ,reason they are not available 'in your handout, it is 17 very, very preliminarY data, and for data, like this,' 18 we do need full editorial approval at NIST before we 19 can really publish. 20 ' 

### , I'm using these charts, here just to 21 illustrate the operating characteristics, really the 22 trends of this sampling plan. It may not be the" sort

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4 5

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

202/797-2525 

### S A G CORP. Washington, D.C. fax: 202/797-2525 87 1 of ,final thing that will be used or final thing that " 2 'wi.ll be proposed.

3 Well, here on this scale here, we have 4**lo~s** percent I and this is the normalfzed losses. A 5 hundred percent loss would be. if the losses are for 6 the rated efficiency. If your efficiency is higher, 7 your losses go lower.. 8' Another way around, they go higher in 9 other direction, and along this axis here we have 10 standard deviation of your manufacturing process. 11 So.' if you work exactly at the rated 12 efficiency here at the lower staridard deviations you 13 have 50 percent probabilityfor passi:n9', but if you go 14 to higher standard deviations, this 50 percent curve 15 sort of swings away, and the reason for that is this 16 device which was used, this .999 for efficiency, for 17**los~es,** corresponding losses, it really should have 18 been 0.94 percent. If this were the**ca~e,** then there 19 would be straight. curve up 

## to here and' then wouid 20 start swinging away. 21 22 Well, I don't think a 50 percent probability of passing would be·good enough. You

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7

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

### SAG CORP. 202/797-2525 . Washington; D.C. Fax: 202/797-2525. / 

### 88 1 would probably move somewhere to 95 or 99 percent, 2 which would require moving or reducing your losses, 3 let's say,· in this case by about four percent or so, 4 .or three percent. 5 Soyouwouldhave to absorb all this other**~** 

### statistical uncertainty. 7 If you go to higher standard deviation, 8 obviously your over design would have to be larger, 9 well,·around ei!;Jhtpercent, but if this one is 10 correct, it's only about six·percent. 11 So there is this type of penalty, and if 12 you were to**operat~** 

### a sample of two, .a very small 13· sample, then, well, the sort ofpenal.tywouldbe even

.14 

### higher. 15. .**Rea~ingback** 

### inFederalRegisterwhenthis 16 was originaily proposed 20 years ago, I sort of have 17 

### tI;.e sense that industry, appliance industry, liked 18 this.plan. It allowedus:Lng very small sample, sample 19 of two. The testing of appliances apparently is very 20 .expensive, time consuming, and so on, and they were 21 not against also on this over design because the 22 rationale seemed to be that this would·improve

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7

10 11 12 13 14 15 16 17 18 19 20 21 22 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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### I 89 1 customer satisfaction. 2 But this was proposed also 

### in NOPR for 3 motors, and there were some objections to this one. 4 Now we go to'method two, which 

### is basedon



### ..5 statistical T test.. In addition to that, requirement

6 for 

### minimum sample size. 7 Criteria for compliance, there are two, 8 namely, that mean of the sample should be higher than 9 rated efficiency 

### minus this factor here, which was 10 used also in lower'confidence level, and N'should be 11 five or higher value depending on standard deviation ,22 of the process. 13 Steps 

### in implementation. This 

### is very 14 ,simplified. It 

### is not as formidable as it may look

. . 15 from draft where there are ten or 11 steps. You, 16 

### again, go through determining the statistical 17 parameters, and then determine the adequacy of sample 18 size. 19 I should say the parameters for 20 determining sample size will be.selected so that when 21 your standard·deviation is really**t~e** industry norm, 22 you will not require more than five units, and then a

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5 6

8 9 10 11 12 .13 14 15 16 17 18 19 20- 21 22 test for compliance. We are back again to these distribution curves. Here is your X bar. You determine your lower confidence limit.. Here is your rated efficiency; and you subtract from rated efficiency this distance here, which brings this so-called lower control to this point. And then for compliance your X bar should be on this line or higher. You do notice that in .the first plan X bar could, never be lower than this, rated efficiency, whereas for this plan it does allow so. So superficially it looks like a great thing for producer and not so great for consumer..

(Laughter.) MR..PETERSONS: Maybe yes and maybe no, depending how the levels are set.

And --here. we go again. to operating characteristics for that plan. Obviously if you work exactly on the rated losses, 100 percent losses, you have 90 percent probability of passing.

Well, I don't think 90 - - you would not risk one in ten in failing your production, and you

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### S A 0 CORP. Washington, D.C. Fax: 202/797-2525 90 1 test for compliance.

. . 2 We are back again to these distribution 3 curves. Here is yourXbar. YOll determine your lower 4' confidence limit.. Here is your rated effie:iency; and 5 you subtract from ratedefficiencytllis distance here, 6 which brings tllis so-called lower control to this 7 point. 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 Xbar could'never be lower than**t~is.** rated II efficiency, whereas for this plan it does allow so.

.12 So superficially it looks like a great thing for , .13 produce:!? and not so great for consumer. 14 (Laughter.) 15 MR.PETERSONS: Maybe yes and maybe no, 16 depending how the levels are set. 17 And .here. we go again. to operating 18. characteristics for that plan. Obviously if you work 19 exactly on the rated losses, ,100 percent losses; you 20 have 90 percent probability of passing. 21 Well, I don't think 90 .-- you would not 22 risk one in ten in failing your production, and you

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

### SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 91 1 would probably move your operating point somewhere 2 here, maybe to .999, 99 percent, and i,fyou recall, 3 well, this line here, you would have to decrease your 4 losses by two percent, whereas in previous case, you 5 had to decrease your losses by about four percent. 6 So this is more favorable for producer 7 comparison to other plan where producer had to absorb.. 8 all the risks due to statisticaluncertainty. In this 9 plan,:theywouldbe sort of splitbetweenproducer and. 10 consumer. 11 How these plans are, well, set for final 12 document 'really depends from various factors: sample 13 size and what really is a standard deviation in 14 industry for typical process. 15 I'd like· to sort of summarize the two 16 methods. The f;i.rst one, very simple, allows you 17 flexibilityalso. Obviouslyhigh assurance.of·meeting 18 EPCA requirements, and of course, determination 19 assurance increases with the sample size. 20 One very important advantage for 21 transformer application, this method is consistent 22 with IEEE/ANSI standardswhere the loss tolerances are

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1 2

5 6 7 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

10 11 12 13 .14 15 16 17 18 19 20 21. 22 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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### 92 1 given. 2 The**disadvantage~,** 

### well, is higherburden 3 onproducers. Statistical methods, well, the wayyou 4 do thi'sadjustmentby divisor factor, they are not' 5 readily**availab~e,** 

### notunlessYOll have theseoperating 6 points as shown,before. It's realiy difficult to see 7 the result. 8 

### For method two, well, statistics is 9 

### ,rigorous and**wid~ly** 

### used. There is possibility,of 10, sort of,balancingproducer and consumer risks justby 11 moving this fan shaped structure one way or other by 12 adjusting,confidence of limits. 13 Disadvantages, well, it is 

### a little more 14 complex, but**~f** 

### you deal with sample size of five in 15 first method, then it is not more complex. , 16 I think one of the disadvantages could 17 also be, again, customer relations. Suppose 

## a large 18 shipme'nt of transformers is 

### delivered and sample mean, 19 is 

### lower than the manufacturer specified. How would 20 you explainthis to consumer? It sort of assumes that 21· everybody has had Statistics 101, as everybody has 22 good intentions, and so on.

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3 4 5 6 . 7

9 10 11 12 13 14 15

20 21 22 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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1 93 

### 1 .Well, that sort 

### Of concludes what I 

### want 2 'to say.. No, no, no,' 

### it doesn't conclude. Sorry. 3 

### (Laughter.) 4 

### MR. PETERSONS: Some of the feedback we 5 would like to receive to reallyfine tune these things 6 and then make a final decision, well, please give us 7 :general comments onthe twoplans asperceivedbyyou. . 8 We'd really'like to know what is'the

9 statistical significance of loss tolerance.' Really 10 what we'd like to know,what'is

### sta~dard deviation of 11 typical transformer manufacturing process. 12 We have to adjust· divisor in the first 13 .method and key coefficient in second, and for that we do need the statis4ical parameters. If you do have 15 some actual test data, I would really appreciate that 16 you do go through these analyses and see what you 17 come. This is in our case modeling. So, well, there 18 will aiways be bucks in computer progrc:;lm. 19 Well, we would like to get if you have 20**~uggestions** 

### for any other sample plan. 21 Thank you. 22 Okay. Well, Kathi had a slide she wants

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5

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### S A G CORP. Washington, D.C. Fax: 202/797-2525: 94 2 to put up. No, I guess I beginby asking for comments 2 befQre DOE should proceed. 3 MR. BALDUCCI: Thank you, Oskars. 4 MR. HOPKINSON: PhilHopkinsonfromSquare 5 D, and representing NEMA at this point. 6 Oskars has. made a very**interes~ing** 7 presentation, and we have as part of N$MA studied the 8 two proposals and have some comments today, and we 9 .will follow up with written·comments later on so that 10 we will have a more complete response at that time. 12 NEMA at this p6int believes.that sampling 12 plan number one is not,appropriate for distribution· 13 transformers. Let me comment a little bit·about 14 sampling plan number one. 15 It 

### is based on a provision for a very 16 small'number of samples to be taken, such as two, and 17 apparently that drew from appliances that are v;ery 18 difficult to test, and Oskars mentiC?ned something 19 about 'airconditioners, something about refrigerators 20 early on, where the testing is quite expensive and 21 where the numbers of samples taken for the testing are 22 very limited, and inherently it sives a wide,standard

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1 2 deviation if you don't have very many samples in the

test'. The result is that it puts in unreasonable

5

7

10 11 12 13 14 15 16. 17 18 19' 20 21 22 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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I 95 1 deviation if you don't have very many samples in the 2 test. 3 . The result is that itputs inunreasonable 4 restraint.on theproduct and suggests that the product 5 has to be fundamentally designed to be much more 6 .efficient for guaranteeing that the endresult of that 7 whole population will meet the standard. 8 And it·doesn't apply. Transformers are 9 testedmore regularly, more routinely inproductionby 10 all manufacturers today, andthe:r;efore, samplingplan 11 number two becomes the preferred. 12 So .going back and. taking sampling·plan 13 number two, NEMA prefers a modified sampling plan to 14 DOE's proposal number two as is now documented in 15 Draft 6 of TP-2. This plan differs from the'DOE 16 proposal number two in the following. 17 First, the sample size is calculated in 18 TP-2 prior to establishing the lower control limit. 19' . The second difference is that 'the 20 confidence limit is set at 95 percent both for use by 21 ,manufacturers and for any later audit of performance. 22 I think you'll see that in the presentation that was

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2. 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 in the NISI 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 

### S A G CORP. . 202/797-2525 Washington, D.C. Fax: 202/797-2525 

### l 96 1 .

### in the NISTwrite-upthat thepossibilitywas left for " 2 several confidence levels to be 'explored and the 3 possibilitythat,there maybe a 90 percent I 95 percent 4 or 97 and a half percent. 5 At this point 95 percent would seem to be , 6 t'he right number. 7 NEMA agrees alsowiththeDOE'proposal for 8 a general 

### six percent' total loss tolerance to be 9 assumed'in the statistical calculations. However, to 10 the point that data has been requested, we are trying

, , 11 to accumulate that data" and that 'may change our 12 assumptions, especially

### since intheTP-1 document,'in 13 the TP-1 document of NEMA which establishes certain 14 'eft'iciencies, thos'e efficiencies are calculated at 15 less than full load, 

### like 35 percent for low voltage 16 transformers and 50 percent for ,medium voltage 17 transformers. 18 The ,fact that those efficiencies are 19 calculated at a less .than full load rating of the, 20 transformer suggests that the loadloss component will 21 be considerably reduced, and it tends to be the more' 22 stable of the two components 

### in computing sta'ndard

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1 2 3 4

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22. 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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### 1 efficiency of the losses. 2 The core loss or the no load loss is a 3 much more variable item both with product received 4 from the manufacturers of magnetic steel, as well as. 5 to the manufacturing process variability in the 6 production of cores. 7 At the point of'measurement, the no load 8 loss andthe load losswouldnominallybe at about the 9 same'level, so that the inherent variability.is going 10 

### to be greater. We will get some·datai' and we will 11 respond to that issue inwriting as we do,.in fact, in 12 writing after this meeting. 13 

### So we at' this point agree with the DOE 14 proposal for a general six percent loss tolerance to 15 be assumed ·in the statisticai calculation. 16 

### Finally, . addressing the frequency of 17 repeat**te~ting,** 

### we do not support 180 days as the 18 

### standard requirement. Rather, we believe that the 19 manufacturerhasa responsibilitytoinsurecompliance 20 and maintenance of his products by doing as much 21 testing as is necessary. 22 I have some cases, one through five, that

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1

3 4 5

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

202/797-2525 

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### 98 1 might help in giving some betterclarification. This 2 is

-- I'd like to say it's real data, but it's not. 3 I just thought up some data, and it came about from**~** 

### the assumption that we had a 7S kVA low voltage, dry S t.ype transformer, and that transformer'carried an 6 efficiency level from TP-l of 98 percent. 7 Soas it

### turned inthe samples, we assumed 8 five samples were drawn. You can see the five right 9 

### here. So of this'five.samples, they had an average. 10 performance level of 97.93 percent efficiency and a 11 standard deviation of 4.6 or 4.7 percent, a standard 12 error of two percent. 13: This K factor is really a T factor that**~4** 

### goes cHong .with a 90 percent confidence leveli 

### and a lS calculatednumber of samples based on what worked out 16 to be a low standard deviation of less tHan one. 17 

### So in this particular case, a lower 18 control limit was calculatedof 97.967. If we compare 19 that nuInber to the mean of the sample that we tested, 20 we'seeI 

### oh, my gosh, it didn't pass,**an~** 

### as we move to 21 the right, in the next column, in the.center column, .22 it's the same data, but now we are going with a 9S

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# I 99

2' 3 4

6

10, .11 12 13 14 15 16 17 18 19 20 1 21 22 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. 

### SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 " 

### 99 1 percent confidence level. 'So the only thing that is



### - 2'changed is the two numbers, the calculation of the N 3 and the calculation of the lower**controllimit~** 

### 4 And YOl,l 

### can see that as the confidence 5 level rises, there 

### is a requirement to test more**6s~mples.** 

### There's also a lower control limit that is 7 more favorable to the manufacturer. 8 Well, we will sharpen .those calculations 9 as we look at additional data, but the trend of this 10 is that as the confidence level rises, the lower ,11 controllimit tothemanufacturergetsmorefavorable, 12 allowing a bigger population to pass. 13 

### Now, since in each of the three cases, 14 even at 97 and'a halfpercent efficiencyassumed, none 15 

### of them passed. So it required us to go back and 16 select another sample. 17 So we said that in this sample, it just 18 happened to be done on a different day, and the steel 19 that came in was a little better on,this day so that 20 our core loss**~ested** 

### a little better, and the result 21 is now when we tested the five samples, they happened 22 to be above 98 percent.

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3 4 5 6 7 8

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

### S A G CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 100 1 Well, from that we had a different 2 standard deviation. . We have a different standard 3 error, the same T, but now in each of the three cases, 4 it still shows the trend that as the confidence level 5 rises,' it allows a greater number of units ...- thank 6 you -- ..a greater number of units to pass, and it says 7 that our lower control limit gets more favorable for 8 the manufacturer. 9 In this case though, ,the standard 10 deviation was a little higher. It reqUired more 11 samples, and itwouldhave required stillmore samples 12 had we gone with a 97 and a half percent confidence 13 level. 14 On the'third case, we took another set of 15 samples. On this one we said, well, let's say that 16 they straddledthe'98percentefficiencylevel equally 17 all the way from 98.1 on**t~e** high side to 97.9 on the 18 low side, and the average worked out exactly at 98 19 percerit.



### . . 20 Well, 

## it still says that as the confidence 21 level rise,s, we.allow more units to'pass so that this 22 does look like a pretty interesting treatment. We



### .SAG CORP. 2021797-2525 Washington, D.C. 

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5 6

10 11 12 13 14 15 16 17

22 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, to 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?

202/797-2525 SAG CORP. Washington, D.C. Fax: 202/797-2525 101 1 will have to get specific standard deviations of 

### '. 2 populations to sharpen that assumption'of 95 percent 3asthe'operatingpoint, but in the case'four,

# we took 4 the sum of the first two populations. Remember the 5 secondone passed; the fi:r;st one didnot pass, and, 

### .10 6 and behold, here's the average now at 97.97, and in 7 this case all three of the confidence levels allowed , 8 the populations to be**cons~dered** good.

9 So finally, when we, took case five, case 10 five took all. 15 samples and the.standard deviation 11 was such that the number of samples required was 12 actually quite low. 13 So I think that when we get some hard, 14 fast data fordifferent types of transformers, i't will 15 sharpen our thinking on the confidence level. It 16 looks like 95 percent is the best place to operate at 17 this point. It looks like that we will support the 18 theme of a six percent base**variab~lity** in the 19 statistics calculations. 20 Thank you., 21 MR. BALDUCCI: Questions or comments for 22 the discussion on this issue?

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## . '102 MR. KLINE: I'm Don Kline of Southern

3

5 6

V 8

1

### 0 11 12 13 14 15 16 17 18 19 20 -21 22 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 tothat 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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### MR. KLINE: I,'m Don Kline 'of Southern 2 Transformer. 3 Some of Us might be very confused here on**~** 

### 4 the situation'where you have a model population of 5 one. We've not covered that yet, and this 

### is one of 6 the major

-- getting some comments -- 7' (Laughter.)

j'8 

### MR; KLINE: How is the population of one

. ' . 

### . 9 or two taken into account in this statistics here? 10 

### MR. PETERSON'S: We.tried to discuss this 1l in definition' of basic model where we will combine / 12 

### both trapsformers of the same nominal kVA rating into 13 

### onepopulation, normallyusingefficiencyas a**mea~.ure** 

### 14 for normalized losses. 15 

### MR. BALDUCCI: Does that answer your 16 questionwith regards tothat orclarifying

-- this is 17 Anthony Balducci -..,would a clarifyingpoint to that? 18 

### . If, for instance I learned this 19 

### yesterday is that there's a lot of specialty 20 

### transformersmade, where**yo~** 

### maymake one of

# acertain '2l type. What DOE is looking to'dois take that one that 22 

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



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### I 103 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### SAG CORP. Washington, D.C. Fax: 202/797-2525 103 1 a kVA rating or some other rating

-- can it be lumped' 2 with other types, ,one single units ormaybe a group'of 3 transformers so that you have this basic model is 4 basicallyall of these different model numbers, if you 5 will, that are all similar? 6 Then you would pull a sample from those. 7 So you may not test that one-specialty unit per se, 8 but you may'test something that's in,that basic model, I 9 or did I confuse you more? 10 MR. McCABE: This is Michael McCabe. 11 Let me follow itup with a question. What 12 Anthony has said as far as what we're trying to do 13 with the basic model is to take models that have 14 similar characteristics and put them together for the 15 purpose of testing in order to reduce testing burden, 16 but that doesn't eliminate the possibilitythat there 1 7 ' may be products out there which are one of a kind. It 18 may· be a -transformer that has specialty made 19 characteristics that are unique to that, not like 20 anything else the manufacturer manufactures. 21 I don't know if that's the situation that 22 exists. I don't believe inOskars' that this sampling

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3 4 5 6

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

## 22 11 and I test one, I did 100 percent testing. I'm 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 202/797-2525 104 l plan really addresses that because it talks about .2 sampling a lot, and so it assumes more than one unit 3 in the basic model. 4 I'dbeil1terested**~n,** one,'knowingwhether 5 ornot.the situationexistswhere there are individual 6 units, and, two, what is your practice iri testing 7 those units? 8 MR. PATTERSON: Wes Patterson, 

### ABB. 9 The first. comment I had, I think it 10 pertains to everything we've been discussing, 11 The twomethodsthat areproposed, there's 12 really a**thi~d** method, and the third method is where 13 the manufacturer does 100 percent testing of every 14 product,' andin our**indust~y** there are segments of the

, . 15 industry where 100 percent of the product is tested. 16 If,you're doing 100 percent testing, then 17 thereIs no criteria .for .sampling.' Sampling only 18 implies that tim not 100 pe'rcent testing. 19 So there ,needs to be a third method that 20 incorporated where I did 100 percent testing.

22 Now, if 

## ±have a model definition of one' and I test onei I did 100 percent testing. I'm

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I105

2

6 7

9' 10 11 12 13 14 15 16 17 18 19 20 21 22 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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" ' 2**whic~** 

### is not in the'document. Okay?**~** So the document has to incorporate some , 4 methodol.ogy to handle 100 percent testing of the

5 product. 6 MR. KLINE: My question hasn't been 7**answered'~** 8 MR. STRICKLETT: I have a quick question 9 about the interpretation of the standards. I took 10 these standards, I believe 11 MR. BALDUCCI: Ken Stricklett. 12 MR. STRICKLETT; 

### Yeah. Sorry. Ken 13 Stricklett from NIST. 14 And I'm learning about the -.:. trying to 15 understand the industry practice. So if,there could 16 be some comments to clarify this, I'd appreciatE;! it. 1 7 The IEEE standardsI both the 57.00 a.nd 18 57.01, have thetolerance specifiedin those standards 19 for**'th~** losses, and'that includes samples of 20 discusses the ,case of sample of one, sample of two, 21 and samples larger than two. ' 22 Now, byputtinga tolerance onthe losses,

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# ------------------------------------i 106

1

3 4 5 .6

8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 '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 

### S A G CORP. 2021797-2525 Washington, D.C.' Fax: 202/797-2525 

# r 106 1 that. effectively provides a sampling plan, and has 2 that been'discussedbyNEMA as a control mechanismfor 3 quality control, and is that IEEE tolerance protocol 4 followed by industry currently? 5 I guess those are.my questi'ons. MR. BALDUCCI: Phil, before you answer 7 that question, I'm going to ask one other question, 8 and this goes back to Wes' comment about 100 

### percent 9 testing. 10 Whenyoutest -- for instance, you sayyou 11 test 100 percent ofyour transformers. If you've got, 12 say, ten transformers that are identical and you test 13 every single one, of those; how,do you rate those? Do 14 you rate those individually or**doyo~** 

### rate those as a 15 family of ten? 16 That's.mine. 17 

### MR. PATTERSON: The units in IEEE beyond 18 a certainclass of ratings, you're require to test 100 19 ,percent**o~** 

### the products. 20 

### MR. BALDUCCI: Okay. 21. MR. PATTERSON: By standards. Those 22 products, if there were ten 

### units being manufactured 

### .SAG 

### CORP. 202n97-2525 Washington, D.C.**F~:**202n97-2525107 1 2 3 4. 5 6 7 8 9 10 11 12 13 14 '15 16 17. 18 19 20 21 22 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 right now.

Going back over the years, the IEEE

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### 107 1 that were virtually**iden~ical,** 

### are still looked at as 2 though they were one unit. 3 

### MR. BALDUCCI:. Okay. 4. 

### MR. PATTERSON: Phil's going·to address 5 .this probability, thi? six percent/tenpercent limit '6 atldwhat it 

### means to the industry. So I'll defer that 7 to him. 8 

### MS. ·EPPING: Kathy Epping. 9 Do I correctlyunderstand you that you're 10 saying that,each one gets an individual rating? 11 MR. PATTERSON: Each one gets' an 12 individual rating.. Now, the commerci.al issue of if a 13 unit 

### is beyond the guaranteed losses, the·guaranteed 14 losses, how that ishandledcommerciallyiswherethis 15 percentage comes ·into in the standards. 16 MR. HOPKINSON:· Thank you, Wes. 17 I'm Phil Hopkinson;from Square D. 18 The issues that Mr. 'Stricklett raised are 19 interestingones,· andwe have addressedthose in IEEE, 20 and it's a dynamic addressing issue as we talk about 21 it.

### right now. 22 Going back over the years, the IEEE

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2 3

5 

### 6 7

9 10 11 12 13 14 15 16. 17 18 19 20 21 22 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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### S A G CORP. Washington, D.C. * Fag: 2021797-2525 108 1 standards for sixpercent loss tolerance ontotal loss 2 and ten percent loss tolerance on no load loss were

! 3 set up as the 'presumptions for performance by a 4 manufacturerto guarantees of losses that weremade to 5 a customer between a producer and a buyer of the 6 product. 7 If a transformer would exceed the no load 8 lossbymore than tenpercent, it didn't fundamentally 9 get thrown away, but it did require some financial 1.0 1;ransactionbetweenthemanufacturerandthepurchaser 11 of the equipment. 12 'Well, then they raised the question of, 13 well, okay, what abOl.;jt thenominal requirement? Well, 14 it turned out that in th,e'l,iteral interpretation as 15 the standard was published and has been for years and 16 years, required that a**~hipment** of transformers meet 17 the guarantee. 18 Well, what's a shipment?**~ell;** that got 19 a lot of different interpretations. Someviewed it as 20 a truckload. Some viewed it as a month's production. 21 Some viewed**~t** as a quarter's production. Some used 22 a whole year's production. After all, most of the

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4 5

7 8 9 10 11 12 13 14 15 16 17 .18 19 20 21 22' transactions between manufacturers and utilities were

consummated overa 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 f act, 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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### S' A G CORP.. Washington, D.C. Fax: 202/797-2525 109 1 transactions betweenmanufacturers and utilities were 2 consummated over a blanket 'period or a year's period 3 tyPically. 4 So over that blanket of· a year, it was 5 reasonable to consider that the Whole, year's 6 population was the shipment and, therefore, tliat any 7 financial transaction andanyrequirement for the,mean 8 of the population should be done over that period. 9 Well, but then the purists came back and 10 said, "Well, wait a minute.. 'This 

### six percent, ten 11 percent" the so-called cutoff limits to the. mean, 12 doesn't really have any statistical validity, 13 especially as it'

### is being used' and applied 

### in 'the 14 industry today. It really needs to be rewritten 15 altogethe'r." 16 And, 

### in fact, that Is what Is 

### goingonright ·17 now. .The requirements are being modified and will go .18 to a more statistically relevant sampling basis, much 19 as Oskars has prepared and we also have included in 20 the NEMA TP-1 document.' 21 So I think that the original intent of the 22 loss tolerance was not as it has been used 

### in recent

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2

4 5

7

9 10 11 12' 13 14 15 16 17 18 19 20 21 22 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 trans formers. 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 can the teri percent/six percent 

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### 1 110 1 times f but I do think that var.:j.ability of tenpercent, 2 plus and minus, on no load loss is something that was 3 reasonably representative of where the industry has 4 been performing in the past, and so that it gives us' 5 some c1ue as towhat th:e standarddeviations are going 6 to work out for the different types of products that 7 we have in our arsenal ,of transformer products that 8 are considered**distribut~on** transformers,today, anda;; , 9 we sharpenup those numbers for the different types of 

### iO construction, then we'll have an ability to shc;rpen 11 what shouldbe the statisticalmeans andcutoff limits 12 'and so on for the population. 13 MR. BALDUCCI: Thank you. 14 .**MR~** PETERSONS': Could I just? 15 MR. BALDUCCI: Sure. 16 MR. PETERSONS: I'd like to respond toMr. 17 Patterson's comment. On page 23, second paragraph or I 18 first full paragraph does address what should be done 19**~hen** all units are tested. 20 MR. BORST:' John Borst, ABB. 21 Just to adda littleclarificationtowhat 22 Phil tal,ked, about on ,the ten' percent/six percent

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111

1

4

7

9 10 11 12 13 14 15 16 17 18 . 19 20 21 22 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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## I 111 1 tolerances, the basic IEEE standard that is out**f~r** 2 ballot right now retains the ten percent tolerance on 3 no load and six percent on total loss, but it only· 

# . 4 applies to the individual unit. All reference to 5 multiple units, shipments'. orders has been dropped. 6 The feelingwasfromthe IEEEperspective, 7 was that those tolerances there were to deal with 8· manufacturing variability of a single unit, and that 9 anydialogue ongroups of units were really commercial 10 considerations between the user and the producer, and 11 as Phil quite appropriately pointed out, the ten 12 percent/six percent limit is not an absolute limit. 13 .It's a point of dialogue.between the user and the 1 14 producer. 15 So that's where that standard is headed. 16 It's·**ou~** for ballot currently, and ·if that is 17 retained, then the multi-unit requirements will be 18 dropped from the ANSI standard. 19 MR. BALDUCCI: Do we have any·other 20 further questions or comments regarding this issue? 21 Clarifications? 22 Why don't we then press on to the next

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2 3 .4

6 7 8 9 10 11 .12 13 14 15 16 17 18 19 20 21 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 e-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 22 11- levels would. be the way to go. i



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### 112 1, topic, which is the measure of energy consumption? 2 MS. EPPING: The established ANSI/IEEE 3 standards use lo.sses as the rated measure of ,4 performance, andNEMATP-1'usestransformerefficiency

5 at specified loading levels as the measure of energy 6 consumption. 7 DOE 

### at this timebelieves that this,method 8 is preferable because it allows manufacturers to use 9 tradeoffs between load and no load losses and because 10 efficienGY at appropriately selected levels provide a 11 better estimate of energy consumption. 12 For test procedures, this'topic should 13 onlybe significant with respect to the calculations. 14 Allmeasurements, corrections, conversion1:0

### reference' 15 ,temperatures**~ndproc~ssing** 

### of statistical analysis 16 will be performed using loss data; 1

### 7 So we'd 1ike to know if there are' any 18 strong reasons why efficiency shouldnot be used, and 19 if any other measures of energy cOIlsumpt'ion'shouldbe 20 considered, suchas losspowernormalized, andwhether 21 or not reporting efficiencylosses at reduced loading 22 levels would be the way to go.

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### CORP. ,Washington, D.C. Fax:202/797-2525113 1 So I'll let NEMA speak now. MR. BORST:' John Borst, ABB, representing 3 NEMA. Since transformer. losses include both 5 .6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 113 1 So I'll let NEMA speak now. 2 

### MR. BORST:'**Joh~** 

### Borst, ABB, representing 3 NEMA. ,4 

### Since transformer, losses include both 5 

### fixed and variable components, the use of efficiency ,6 

### as the preferable measure of energy consumption 

### is

7 

### considered appropriate by NEMA. 8 

### NEMA does not see a need for additional 9 measures of energy consumption, such as loss power 10 normalized relative to outpu1;: kVA, and reporting 11**effici~ncy** 

### at reduced loading levels is considered 12 appropriate by NEMA. 13 MR. BALDUCCI:' Thank you. 14 

### Is there any questions or comments with, 15 regard to that? That's too -- oh, we've got one. I 16 was going to say that's too easy. 17 

### MR. BOHLK: Not iri particular, but I have 18 a question. 19 

### MR. BALDUCCI: State your name, please. 20 

### MR. BOHLK:JimBohlk, RUB inWashington. 21 Not inparticulartothat, but the general 22 question of measurements of efficiency. I do believe

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3 4 5 6 7

9 10 11 12 13 . 14 15 16 17 18 19 .2 0 21 22. 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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### I " 

# + that efficiencies are a'very good number and.**v~ry** 2 useful number, especiallY for labeling. 3 However, I don't.really see a practical 4 application as we 

### like it to be used. RUS presently 5 advocates that theirborrowerspurchaser.transformers 6 on a bid'rate'based on the A&Bfactor and the tot.al 7 owning cost, if you will, as published and explained '8 very nicely in the October 22nd Federal Register 9 notice. 10 It is important then that.manufacturers 11 and purchasers be, aware of the load, no load, and 12 tot,al losses and, of course, the first p'rice, and this 13. is the basis of the purchase. 14 Again,. I think this is very important. 15 RUS advocates'the use of this methodology. We will 16 continue,to advocate the,use of this methodology, and 17 we don't reallyparticularly see a useful application 18 forwhat we Ire lookingat forpublishingefficiencies. 19 MR. BALDUCCI: Othercomments'orquestions 20 regardingtheenergyconsumptionmeasurementwhereDOE 21 .is

### proposi~g using

### efficien~y? 22.

2021797-2525 . MR. HOPKINSON: Phi1 Hopkinson, Square D. 

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1 2

4

6`' 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 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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### 115 1 Reporting at this time just to the,issue 

### .' 2 raised about A&B factors andno load and load loss,

### ,in 3 the considerations for the development of TP-l, we as 4 a NEMA organization addressed the question of whether 5 we would go for specific watt loss levels or try to 6' get something that was a more general term, like 7 ' 

### 'efficfency. 8 

### Well, there were a, lot of factors of 9 consideration. One of them was the'fact that there 10 aremanytypes ofmanufacturerof transformers. There'

,11 are trapsformers that are core type, which means two

12 

### coils, one core. There are transformers that are 13 shell type, whichmeans one coil, two cores for single 14 phase. 15 There are transformers that use stacked 16 17 ' 18 19

,20

21 

### 22 core. There are transformers that use wound core. There are transformers'that have various kinds of windings, diskwindings andlayer**windi~gs** 

### andothers. And out of that, the concern that**~e** 

### had was we wanted a parameterthat would tellthe enduser the performance that he would expect to get at**~he** 

### nominal usage level of the transformer, but we wanted

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1 2 3 4

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 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-1, 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-1 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.

202/797-2525 

### S A G CORP. Washington, D.C. Fax: 202/797-2525**~J.6** 1 that to be not a discriminatory clause that would 2 unduly put certain types of manufacturers or types of 3 constructions under pressure, competitive pressure, 4 whi.ch would· make ,them no longer· salable in. the 5 industry when, in fact,they are a very fine product. 6 ,Soefficiencybecametheverybestmeasure**~** that would do that because it does communicate what 8 .the transformerwou,ldexpect.tobedeiiveringin total 9 watts loss consumed at the nominal usage level. 10 And indetermining·efficiency, inthework 11 that we did in NEMA to develop TP-1, we also did very

.12 careful consideration of how transformers are ,used,

13 what types of loads are on them, how variable they 14 are, and tried -to get to an RMS equivalent loading 15 that would represent the lowest common'denominator of 16 what the industryusage of those products are, so that 

### , 17 the TP-1 document isa pretty good reflector of 18 efficiencies and, therefore, of end performance, and 19 I think that it 'does ,address the other kinds of 20 ,parameters for how one could establish a metric or a 21 measure of energy consumed. 22 Thank you.

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1 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 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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### 117 1 MR. BALDUCCI: Thank you verymuch, Phil.



### .. . 2 

### MR. LEVY: This is Ed LevyfromDOE again.

3 I wanted to ask the gentleman, I believe, 4 from the Department of Agriculture.are you suggesting 5 that: the department should use something other.than 6 efficiency as a measure of energy consumption? 7 

### ·MR. BOHLK: No, not at all. I didn't mean 8 to imply that. I did.not want to lose the option of 9 purchasers to be able to use the A&B formula, if you 10 will. So both would be fine with me. I just don't 11 want to lose the first. 12 PARTICIPANT: .We agree with that. 13 

### MR. LEVY: Thank you. 14 

### MR. BALDUCCI: Thank you. 15 Anyfurtherquestions, comments I 

### regarding 16 the selection of measure of NG consumption? 17 (No response.) 18 

### MR. BALDUCCI: It is 20 of 12 right now. 19 How is everyone feeling regarding lunch? Do we need 20 to break now or do we want to press on? 21 (Laughter.) 22 MR. BALDUCCI: Or we can knock off the

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## I 118

2

5 6 7 8 -9 10 11 12 13 14 15 16 17' 18 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" 

### SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 118 l' next one, which 

### is the burden imposed by industry by . 2 additional.testing and data processing. Why don't we 3 

### try and go through that? 4 MS. EPPING: We've gotten from various 5 sources that there's some concern expressed over 6 significantbUl;,dentoparticularlysmallmanufacturers 

### 7 posed by the testing requirement$. .So we'd like to 8 know from.you what anticipated difficulties you see, -9 and we'd l,ike some suggestions on solutions to 10 addressing these difficulties. 11 And we'd also like to know what specific 12 requirements in the draft test procedure document are 13 causing these**diffi~ulties.** 14 MR. GAUTHIER: .John Gauthier from,NEMA. 15 NEMA's position 

### is basically compared to 16 current practices, the imposition of this mandatory 17' requirement contained in any. DOE regulation will 18 result 

### in.increased burdens for manufacturers large 19 'and small. 20 Additional eqdipment may be required.to 21 comply with the mandates of this regulation. The 22' effort will be directed toward meeting -the three'

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1

3 4

6 7

10' 11 12 13 14 15 16 17 18 19 20 21 22 119

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 

### S A C CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 I 119 1 percent test 'tolerance for loss measurements. 2 Approximately 200, distribution manufacturers, both 3 liquid and dry type, must up grade their testing 4 equipment. 5 New measuring equipment is available that 6 will meet the specification

-- is available. It is 7 hoped that NIST will provide the small manufacturers, 8 guidance on the changes necessary. 9 Our experience in other areas involving 10' mandatory regulati'on has been that reporting is 11 increased and record keeping poses an additional 12 burden. 13 Additionally, NEMA recognizes the need to 14 address the following burdens: need to meet both old 15 and newversions of 'standards, that is to say that DOE 16 test requirements identified in an oldversion of the 17 standard that has been superseded. 18 Two, labeling**require~ents.** 19 Three, third party' certification 20 accreditation. 21 MR. BALDUCCI: I do have' this is 22 'Anthony Balqucci again I do have a specific

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6

9 10 11 12 13- .14 15 16 17 18 19 20 21 22 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 manufarvcturer -- we cannot 

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### 120 1 questionregarding

- - and this goesback to an earlier 2 comment by Wes with regards to 100 percent testing. 3 You're talking these additional burdens. 4 With test equipment how would that be different than 5 what's being performed now by the manufacturers? 6 

### MR. ,PATTERSON: The''r,equirements for the 7 accuracy of the equipment may result in additional,' 8 equipment having to be purchased and obsoleting 9. existing equipment. So we'll have to make a capital 10 .change in the buildings. So that's a burden. 11 And for some of themanufacturers, some of 12 the larger manufacturers, it's maybe riot as big a 13 

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

, 

### 14 that was the point that we were trying to get at. 15 

## MR. LEVY: This is Ed Levy again. 16 

### I have a question. In light of the fact 17 that' DOE is discussing adoption of the existing 18 industry standards, how does the burden result? ' 19 

### MR. GAUTHIER: John Gauthier. 20 The key thing here is that when we issue 21a standard as a voluntary

-- on a voluntary basis, we 22 cannot deny an industry**manuf~cturer** 

### - - we cannot

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6 7 8 9 10 11 12 13 14 15 .16 17 18 19 20 21 22 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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### 121 1 write a standard that will deny anyone access to the 2 marketplace. A regulation issued by the government 3 can do that. 4 

### And that imposes when you issue a 5 requirement for certain levels of test, if it's not 6 available, it then poses an additional burden on the 7 manufacturer to have that. 8 

### Again, the key element here is market 9 force, the market placing demand on the manufacturer. 10 The manufacturers do what their customers want, but 11 when the government imposes a requirement; that is a 12 little different. 13 

### MR. LEVY: So let me**j~st** 

### ask a follow-up 14 question. 15 

### MR. GAUTHIER: Sure. .16 

### MR. LEVY: So are you suggesting that 17 there are differences among manufacturers in the 18 amount of t-esting that they c.onduct and in the rigor 19 of their testing? 20 MR. GAUTHIER:' Oh, absolutely, absolutely. 21 MR. PATTERSON: Oskars has. had a problem 22 with the industry standards when he first came into

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### CORP. Washington, D.C. Fax:202/797-2525**-.~--------------------**122 1 2 3 4 5 6

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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### 1 this thing between the liquid standards and the dry 2 standards. The requirements for the accuracy of the 3 measurement between these two gr.oups is 'fundamentally 4**dif~erent,** 

### and he's always had a problem with it. 5 So he wants to move everything to the 6 liquid. Well, the reason why there's a liquid and a 7 dry is they are different markets, right, ,servicing 8 different industries.**~** 

### Now, sometimes they overlap, but by and 10 

### large they don't. So there were fundamental .11 

### c:iifferences in 

### the commercial side of. the system, but

12, 

### we're trying 

### to' normalize that with the government 13 regulation. 14 So that's going to createjust by itself 15 an increased burden on the dry manufacturers. 16 MR. LEVY: 

### So to put it a little 17 differently,are you saying that**~he** 

### different'markets is 

### demanddifferentdegreesof testing, dif;erentamotints 19 of testing? 20 

### MR. PATTERSON: The different markets 21 some of the,' requirements' for the markets, yeah, 22 ,they're different, yeah. They require different ways

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1 .2 3 4 5

9 10 11 12 13 14 15 16 17 18 19 20 21 22 of looking at the game. MR. MOREHART: Gene Morehart, Acme Electric. The answer to your question, right now 601 volt, transformers below 500 kVA do not require any loss measurements by industry standards.. As a matter of fact, if you read those standards real close, that line of transformers is not even included in those standards. So that's another reason why it will be necessary to put ST20 in there as a reference..

MS. EPPING: Kathi Epping. I have a question to you. If we make different requirements for, both liquid and dry, and I understand your reasoning on why we might want'to do that, is there a problem with treating the two unfairly that you're preferring -- giving preferential treatment to one or the other? Is that a concern?

PARTICIPANT: What's your question? MS. EPPING: If we have different testing requirements for both the liquid and the drytransformers, would that create any sort of Problem202/797-2525 

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### 123 1 of 

### looking at the game. .2 

### MR. MOREHART: Gene Morehart, Acme 3 Electric. 4· The answertoyourquestion, 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 th,ere 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 unfairlythatyou'repreferring

- - 

### givingpreferential' 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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10 11 12 13 14 15 16 17 18 19 20 21 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 j ust . 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 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. 22 II that the intent of the organization; to wipe out a 

### S. A G CORP. Washington, D.C., Fax: 202/797-2525 202/797-2525 124 1 that peoplewhomanufacture liquidtransformers ordry 2 transformers would think that we were -- there.were 3 less stringent requirements on the other group? 4 Does that make sense? 

## s MR. McCABE: This is Michael McCq,be. 6 Let me just,addto it. Assuming that they 7 are both the notice says where they are going 8 towards the same market. Would that give one a 9 competitive**advan~age** over another? 10 PARTICIPANT: It might. 11 .MR. PATTERSO:N: Potentially it migh,t.· 12 However, the twp**p~oducts** are fundamentally different 13 products. When we .look at. just

-- although it's not 14 part of this meeting" when.we.look at establishingthe 

### is limits, the criteria that the unit wouldhave tomeet, 16' you know, the very first simplistic pass is. well, if 17 it's a 1,'000 kV unit, we'll jU'stmake it 99 percent 18 efficient whether itI S a dry or a liquid. Who cares? , 19 Well, they're fundamentally different 20 products, and if you were to make that move, you'd 21 just wipe out an entire market, plain and simpl·e. Is 22 that the intent of the**organization~** to wipe out a

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2 3 4 5 6 7

9 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,



### S A G CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 125 1 market? 2 . On this particularquestion, the question· 3 was: are t:here burdens on the industry? Can we 4 identify·burdens on the industry? 5 All we're trying to do. 

### is state there 

### is 6 a dis·tinct burden o"n the industryby the requirements 7 for the accuracy of the measurement which is now 8 different than what 

### is out there in the marketplace 9 today. We're just .trying to illustrate t,hat it's 10 there. 11 MR. LEVY: Do you think that we should try 12 and replicate what's in the marketplace withregard to 13 the accuracy of measurement? 14 MR. PATTERSON: Again, ifyou're askingme 15 my opinion, my opinion is that the industry.has been 16 quite good'at

### policing itself inrespect to efficiency 17 over the years. So I don't believe that the 18 government coming in and telling us what the industry 19 has been doing all along is buying us anyt,hing. 20 That's my own personal opinion. Okay? 21 22

2021797-2525 MR. BALDUCCI: Hold on.·one second. MR. PETERSONS: Could I respond on, well, SA

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3 4

7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### S A G CORP. Washington, D.C. Fax: 202/797-2525 126 1 my concern on, accuracy situations in the measurement 2 of dry type transformers? 3 There was no accuracy requirement at all 4 for measuring losses of dry type transformers. If 5 there is no accu'racy requirement, measurement by 6 itself is an undefined sort of opera,tion. You can be -7 15 percent out,. It would be very difficult to

8 enforce. 9 So I pushed very' s.trongly in working 10 groups to introduce similar table also,' accuracy 11 table, for dry types. My understanding is that the 12 next division this is or will be'accepted nearly'as 13 'for liquids, except for temperature measurement, and 14 t'here is apparently one negative vote. 15 So primarily I was pushing that there is 16 some accuracy for dry type measurements., To me loss 17 measurements in dry or liquid t,ype' situation I don't 18 think is any more burdensome accuracy-wise. 19 MR. ROLLING: Dave Rolling from Cooper 20 Power Systems. 21**Twoqui~k** comments. First,' I believe'here 22 would be some concerns if you would**~ake** different

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2 3 4

6 7 8 9 .10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 127 '1 

### testingrequirements for different types ofproducts, 2 which I believe could be more' fully discussed in 3 individual manufacturer comments which follow this 4 meeting. 5 

### And, .secondly, I don't believe itt S 

### a 6 discussion for this meetingt 

### but I presume in the 7 future we will, discuss differences in people's 8 conceptions between l:i,quid immersed and dry type 9 transformers, but since this is just a test meeting, .10 

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

11 Thanks. 12 MR. BALDUCCI: 

### Any other questions, 13 concerns or comments regarding the potential burden 14 imposed on industry? 15 I would encourage those who are reluctant 16 to speak now to submit commerits in' writing with 17 regards,to that. The more data you give us that you 18 can cite, the better off we are and can be able to 19 answer those questions and concerns. 20 Seeing the time, how does everyone feel 21 about

-- I'm sorry. 22 MR. LEVY: Also, I'dexpanduponthatjust

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3 4 5

7 8 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. 1

### 0 11 12 13 14 15 16 17 18 19 20 21 22 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



### SAG CORP.,' 202/797-2525 Washington, D.C. Fax: 202/797-2525 128 1 a little. rt's. not just a matter of reluctance to' 2 speak, but people get ideas as a result of 3 .contemplating what's said here. We'd like to hear 4 that, too, you know, responses or amplifi'cations, 5 agreement.s, disagreements. You knowI that's part of 6 the purpose of having the written comment, is to give 7 people an opportunity to .follow up on wha·t's said 8 here. 9 MR. BALDUCCI: Thank you very much. 10 Yeah, and I'd iike to reiterate that. 11 That goes for all ·the topics, as well. If you get 12 home tonight and have a revelation about the way we 13 should do something a little bit different, feel free 14 to write us and tell us. 15 Again, .as we discussed earlier, if you 

### .16 agree or disagree" it's good to hear from both sides.

17 Anyotherquestions orcomments? How does 18 everyone feel'abouttaking a one hour break for lunch 19 about now? 20 It's five of 12. why don't we try and 21 . meet back here at five of one·? 22

20'4./797-2525 Again, the cafeteria is in the West, 

### SAG CORP •. Washington, D.C. Fax:2021797-2525129 1 2 3 4

7

.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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T 129 1 Building. If we can kind of work our way over there, 

## '. 2 it's easier to gp,underneath than across, and also 3 there are restaurants up in L'Enfant Plaza, and for 4 those of you who are daring, we do have the "street 5 vendors selling hotdogs, as well. 6 (Laughter.) 7 MR. BALDUCCI: See you in one hour. 8 (Whereut:>0n, at 11:56 a.m.,'the workshop 9 was recessed for lunch, to reconvene at 1:00 p.m., the ,10 same day.) , 11 12 13 14 15 16 17 18 19 20 21 22

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3 4

7 8 9 10 11 12 13 14 15 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

202/797-2525 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 130 1 A-F-T-E-R-N-O-O-N**S~E-S-S-I-O-N** 2 (1:01 p.m.) 3 MR. BALDUCCI: Welcome back; everyone. I 4 guess we can get back into it.**~** Before we go on to the next topic, there 6 was a request from the gentleman from Canada. Dave 7 wanted to talk about with regard to the measurement of 8 en,ergy**con~umption** and,what they have 'found'at CSA. 9 

## MR. WIEGAND: Thanks, Anthony. 10 , Just, a very few 11 MR. BALDUCCI: Could you give for the 12 rebord your name? 13 MR. WIEGAND: Oh, Dave Wiegand. I'm from 14 London, Ontario 

### in Canada. If you don't know where 15 London 

### is; it's halfway between Toronto and Detroit. 16 (Laughter.) 17 MR. WIEGAND: So ,people there, some'of 18 them are Tiger fans. Some 

### 6f them are Blue Jay fans. 19 Okay. So I was actively involved in the 20 CSA C802 standardthat got

### dev~loped in Canada'in 1994 21 on ma;)l:imum losses for'transformers, and I just wanted 22 to comment in general about what I'mfinding here with

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4

6 7 8

10 11 12 13 14 1s .16 17 18' 19 20 21 22 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 

### SAG CORP. 202/797-2525 Washington, D.C. Fax: 2021797-2525 13i' 1 studying the losses from the C802 stapdard, which are 2 maximum losses, and how they**com~are** with NEMA losses 3 when they are put into a 50 percent**load~ng** situation. 4 I've done some spreadsheet calculations

, ' . . 5 more or less to get, my mind in gear on this, but I 6 would be pleased to send copiest'o anyone interested, 7 but the relationship is very, very close both for 8 liquid filled transformers and dry tyPe. 9 In fact, ,it makes-me wonder, well, .the 10 people that drewup the NEMA losses, were they looking 11 at our standard for maximum losses, but anyWay, why 12 did we pick maximum losses instead of efficiencywhen 13 the pursuit'in itself waS for greater efficiency in 14 transformers? 15 It was largely related to the commercial .16 aspect of the transformer business tpat we were in. 17 We were dealing

### mainlywithelectricutilitieswhEm it 18' came to transformer losses, and so the'electric 19 utilities were purchasing on the basis of total 20 ownership cost. 21 So it seemed rather natural since they :;}2 were all looking very closely at no·load and load

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1 2 3 4 5 6 7 8

10 11 12 13 14 

### i5 16 17 18 19 20 21 22 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 that we opted for that, but that doesn't mean that

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### i 

### '132 1 losses as part 'of the guarantee that that be 2 incorporated into some way of 'going toward higher 3 efficiency in 

### transformers. 4 

### Another part about it was that we 5 recognized that transformers by their nature have 6 always been efficient, whether manufactured in 1910, 7 1940 or 1990, and so when we talk about improving the 8 efficiency of a transformer, it's like going from 98**9~nd** 

### a half percent to 99percent'. 10 In other words, the'changes aren't all 11 that dramatic, at first sight, and on the.other hand, 12 when we're looking'at losses**alon~,** 

### the changes very 13 definitely are dramatic. 14 For example, a 100 kVA single phase

, 

### 15 transformer in the 1960s had a no load'loss of 340 16 watts, andnow under the influence of loss evaluation 17 ,formul'asand the like, that no load loss is'more down. 18 around220 watts orthereabouts, and similarlywhen it 19 comes to load loss, there have been quite qramatic 20 changes., 21 So, it was''looking ina, practical sense 22 that we opted for that, but that doesn't mean that

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5

7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 it' s cast in stone, and having done the analysis of

comparing these C802 losses converted into efficiency at 50 percent load, comparing it with the NEMA efficiencies, they're very, very close, especially if I was to make some corrections to compare apples with apples. So I just wanted to indicate that I will be going back to Canada and casting a vote in favor of efficiency as the way of going. We're all interested in harmony. So --

,(Applause.) MR. WIEGAND: Just so you would-be aware of it. MR. BALDUCCI: Thank you very much, Dave.

MR. GAUTHIER: Dave, just a comment. John Gauthier.. With regard to your interest in harmony, we'd like to propose - to begin talking , about standardization between Canada and the United States and Mexico for a single tri-national standard on energy efficiency. We'll be in touch with you.

MR. WIEGAND: Okay.

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### S A G CORP. Washington, D.C. Fax: 202/797-2525 133 1 it's cast in stone, and having done the analysis of 2 comparing·these C802 losses converted into'efficiency 3 at 50 percent load, comparing it with the NEMA 4 efficiencies, they're very, very close, especially if

" 5 I was to make some corrections to compare apples with 6 apples. 

### 7 So 

### I just wanted to indicate that 

### I will 8 be goingback to Canada and casting a vot'e 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 ·tobegin talking about 19 standardization**bet~een** canada and the United States 20 and Mexico for a single tri-nat:Lonal standard on 21 energy efficiency. We'll be in touch withyou. 22

20217.97-2525 MR. WIEGAND: Okay. 

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3 4 5

7

9 1 0 11 12 13 14 15 16 17 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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I 

### 134 1 

### MR. GAUTHIER: Is that okay, guys? 2 

### -(Laughter.) 3 

### MR. BALDUCCI: Great. Harmony is 4 

### wonderful. 5 

### Now we're going'to, go into the toughest. 6 

### part of the day because it's the afternoon**~ession,** 7 

### and hopefully everyone can remain awake for the next 8 

### three topics. 9 

### The next one is the reference 

### :to temperatures. As I know nothing of this I'm 11 thinking ambient temperatures, which I know is • 

### 12 completely incorrect

-- I'm going to turn it over to 13 Kathi and let her talk about that. 14 Thank you. 15 

### MS.' EPPING: The reference temperature 16 

### stated' in the cited: documents' are ,somewhat 17 inconsistent',with respect to reference temperature. 18 What we're considering is specifying

-- that lookS 19 better ,-- specifying ,a 20 degree temperature,for no 20 load for both dry transformers and liquid immersed. 21 We're also at this point favoring using a 22 singlereference temperature of 75**~degrees** 

### forno load

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3 4

6

8 9 10 it 12-

. 13 14 15 16 17 18 19 

### 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.

202/797-2525 

### SAG CORP. Washington, D.C. Fax: 202/797-2525 135 1 or, rather, load losses of liquid immersed or did I 2 say that wrong? For dry type, and then 55 degrees for 3 the. liquid immersed. 4 So we would like your comments**o~** these 5 reference temperatures, if you think that they're' 6 reasonableor'not. 7 " MR. COULSON: Lake Coulson with NEMA. 8 NEMA's position on this, 'specifying a 9 reference temperature of 20 degrees Celsius for no

,10 load losses, is considered appropriate byJ:\l'EMA.. It 

### is

11 anticipated that C57.12 and C57.12.01 ,will be' 12' harmonized to that value 

### in the future. 13 NEMA is in agreement with reduced 14 reference temperatures'for load loss, but has no 15 comment on the specific values proposed at this time. 16 MR. HOPKINSON:**~hil** Hopkinson, Square D. 17 Just following up on Lake's comments on 18 reference temperatures, for 'liquid and for.dry as a 19 company position for Square D and not for NEMA, then 20 it**i~** our belief that 75 degrees represents the load 21 loss reference temperature formediumvoltage dry type 22 transformers.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 therea little high. Okay?

MR. ROLLING : Dave Rolling, Cooper Power



### S A G CORP. 202/797-2525 Washington, D.C. Fax: 2021797-2525 

### I 136 1 

### We believe that 55 degrees C. represents 2 

### the reference temperature for liquid filled 3 

### transformers. We believe that 55 degrees also 4 representstherefer.ence**te~perature** 

### for a lowvoltage 5 dry transformers. 6 Just togive a littlemorebackground, the 7 low voltage dry type**transform~rs** I 

### when we thought 8 back as t;:.o what happened andwhywe,got to 75 degreesI 

### 9 as the evolution of TP-l came along, the fact is'that 10 we had been using a higher loading assumption on low 11 ,voltage dry type transformers up to the point of 12 establishing'thetables, anditwas afterwe collected 13 some data showing the kinds of loads that exist on 14 those transformers,that we realized at a latertime in 15 the evolution of that standard that 50 percent'load 16 was not appropriate for lowvoltage dries that a lower 17**-~** 

### loadingpresumptionprevailed, and that 35 percent 18 load was most representative. 19 However, we failed to.go back and change 20 the reference temperature ,for the document so that 21 that one actually sits up there a little high. Okay? 22

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### ,MR. ROLLING: Dave RollingI 

### Cooper Power 

### SAG CORP. Washington, D.C. Fax:2021797-2525137 1 2

4 5 6 7

9 10 11 12 13 14 15 16 17 is 19 20 21- 22 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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### 137**~** 

### Systemst 

### in this case speaking for Cooper Power 

### ". 2 Systems. 3 

### Prior to this meeting, I had gone and 4 looked at some of our thermal test data for liquid 5 immersed transformers as they would be running at 50 " 6 percent load, and based on that, an appropriate 7·reference temperature would be down below 55, down in 8 the area more of 45 for those types of transformers 9 

### that were meeting**TP~1** 

### type efficiencies or better. 10 

### MR. BALDUCCI: Any further questions or**~lcbmments** 

### regarding the reference temperatures for.dry 12 and liquid immersed transformers? Clarifications? 13 So pretty much in agreement with the no I.

, . 

### 14 load. It I S 

### just the load that we heed to investigate 15 a little bit more. 16 

### Seeing that, our next topic is the 17 measurement corrections.. Kathi I 

### again I'm going to 18 ask you to take that one. 19 MS. 

### EPPING: The requirements.. in test 20 '. 'codes C57.12.90 and CS7.12.91 differ with respect to 2l the corrections for measure losses due to the phase 22 angle of the test equipment andthe correction that is

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2 3

5

7 8

10 11 12 13 14 15 16 17 18 19 20 21 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 .22 II methodology in Section 4.1.4. Generally speaking, the SAG CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 138 1 required for liquid immersed transformers, but it's 2 not applied to the dry type. 3 DOE believes at this time that the 4 c.orrections should be applied to bot·h types of 5 transformers usingan algorithmand C57.12.90, as well 6 as the guidance describing when the corre9tion should 7 be applied. 8 SimilarlyI the department is inclined at Q this point to propose no,load losses of dry type 10 transformers be corrected to a reference temperature 11 of 20 degreee; if it's measured at, a temperature 12 significantly different. 13 Andwe would likeyourcomments onwhether 14 these corrections are appropriate,. and if it's 15 appropriate to**~ppJ,y** the corrections used for the 16 liqUid,to the dry type transformers. " 17 MR. HOPKINSON: .Phil Hopkinson, Square D, . 18 speaking for NEMA. 19 corrE7ctions for low power factor 20 measurements may be necessary for both liquid filled 21 and dry type transformers.. TP-2 provide$ a .22 methodologyinSection4.1.4. Generally speaking, the

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## I 139- 1 2 3 4

7

10 11 12 13 14 15 16 17 18 19 20 21 22 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-1 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. MR. BALDUCCI: That.' s fine.

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### S A G CORP Washington, D.C. Fax: 202/797-2525

1 139' 1 highestpowerratingswiththehighest impedances will 2 have the lowest load loss power factors. 3 A TP-1 compliant 2,500 kVA dry type 4 transformer at eight percent impedance wil:j. have a 5 load loss power factor of about nine .percent, as 6 measured, while a liquid filled transformer of the 7 same rating that also meeting TP-1 will have a load .8 loss power factor of about 6.5 percent. 9 Dependent on test set error, a correction 10 may be needed for both types of transformers. For. 11 both casespower factor correctionswouldbeneeded.if 12 total test error exceeds one minute. 13 No corrections are necessary for no load 14 loss, for core'loss, in otherwords, if temperature is 15 with ten degrees of the' 20 degrees C. reference 16 temperature. 17 MR. BALDUCCI: Questions or comments 18 rega;r-ding the measurement cO.rrections for

-- Wes. 19 MR. PATTERSON: This is a thought I 20 haven't sharedwithNEMA beforeI but itjust dawnedon 21 me. 22 MR. BALDUCCI: That.'s fine.

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2

4 5

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 MR. PATTERSON: With ,respect to the no

load loss at 20 degrees C., when you say that the temperature of the losses must be corrected to 20 degrees C. if the core is not 20 degrees C., the implication there is you know what the temperature of the core is. 'How are you going to establish temperature of the core?

MS. EPPING: Oskars? MR. PETERSONS: From history of ambient conditions, I am fully aware that temperature dependence of core losses is very small. If you-put these plus/minus ten degree limits, that's just -- you ought to be able to know ambient temperature within those limits, and if it is not significant, you don't.

If there is situation where your ambient is perhaps above 30, between 30, 40 degrees, I think crude correction would be reasonable.

MR. BORST: John Borst, ABB. I think Oskars' point is right. The degree of correction for no load losses, it's a very weak function of temperature. So you're not making a .large correction, and the plus or minus ten degrees,

202/797-2525 

### S .A G CORP. Washington, D.C. Fax: 2021797-2525 140 2 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 no't 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: O'skars? 9 MR. PETERSONS: From history of ambient 10 conditions, I am fully· aware that temperature 11**de~endence** of core losses is very small. If yo'U'put 12 theseplus/minus tendegree limits, that's just

-- you 23 ought to be abie to know ambient temperature within 14 those limits, and if it 

### isnot significant, you don't. 15 If there is situation where your ambient 16 is perhaps above 30, between 30, 40 degrees, I think 27 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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10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 141 1 I believe that's consistent with what's in the ANSI 

## '. ,2 

### standard, that basically ifyou test within a certain 3 "range of ambient, then you're not required to make a 4 

### correction. There's a methodology for making a 5**correction~** 

### It ought to apply as well to liquid or 6 .dry. '7 

### Wes' point is very clearlycorrect". In a

8 manufacturing process, you don't have a precise 9 measurement on the average core temperature, but I 10 think most of us at least in the' high**volum~** 

### 11 operations have a pretty good feel at least in the



# . 12 liquid world because we've introduced a liquid, and 13 we've introduced it at a' certain temperature, and 14 we're testing'within a certain period. 15 So I think we're pretty comfortable with 16 it in the liquid world. 17 

### MR. PATTERSON: Inthe dryworld, there is 18 a process where the unit may be put through an oven 19 cycle, okay, and when the unit comes out of the oven 20 cycle, at some point in.time you need to measure the 21 core loss, okay? 22 

### The problem .with the no. load loss

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### CORP. Washington,D.C. Fax: 2021797-2525142 1 2 3 4 5 6 7 8 9.

11 12 13 14 15 16 17 18. 19 20 21 22 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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1 142 

### 1 measurement 

### is as the temperature goes up, the losses 2 ,are higher, corr§ct? 3 

### PARTICIPANTS: Are lower. 4 

### MR. PATTERSON.: Are lower, are lower. 5 And when,the unit comes out of this oven,

, 6 

### in order for it to stabilize back to an ambient, it 7 may be 24 hoursi 

### it may be 36 hours. ,So you',re going 8 to take this potentially 40, $50,000 

### worth of 9' 'inventory and let it sit in your building for a day, 10 two days, trying to get it back to an ambient unless 11 

### you. measure 

### its tempel;:"ature. 12 

### And thenthe questionbecomeswheredoyou. 13 mei9-sure the core's temperature at. Do yoU: measure the 14 

### top temperature, the bottom temperature, .side 15 temperature? Can you get,underneath the coals? How 16 do you establish what its temperature is given this 17 process, or do you just let it 

### sit in**yo~r** 

### building 18, and then absorb it? 19 And then if you do, that goes back to the 20 

### burdens on the manufacturers. That's going to 21 

### increase our carrying cost. 22 MR. BORST: John Borst, ABB.

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6

8 9 10 11 12 13 14 15 16 17 18. 19 20 . 21 22 Wes' points are absolutelyscorrect. 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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### 143 1 

### Wes' points are**absolutel~correct.** 

### The 2 standards'process, we deliberately-left that somewhat . 3 ambiguousbecauseI .

### again, the correction is**~**

### sT\1all, and

4 we've left it to the manufacturertodetermine for his 5 processes what type of temperature to expect, and I 6 believe what people have done is they've done some 7 statistical studies to, you know, measure multiple 8 points**a~d** 

### get an average temperature and .then have 9 some means of either monitoring a particular part on 10 the core or timeor some other algorithm'so that they 11 have an algorithm of knowing what the temperature is 12 at the time of t·est. 13 They don't wait. As**yo~** 

### say it would be 14 very costly and inefficient to allow the uIiit to go to. 15 

### ambient temperature. I mean, you always have that 16 optionobviously, but mostpeople have B.ome sort of an 17 algorithm in place that allows them to estimate the 18. temperature at the time of test, andtha.t may involve, 19 you know, one measurement at one point, and there's a 20 calibration to what the average is. 21 $0, 

### you know, if you don't have that in 22 place, you're goingtohave todevelop some defensible

2021797-2525 SAG CORP. Washington, D.C. Fax:2021797-2525144 1 2 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21, 22 algorithm. MR. PATTERSON: This is just illustrating

the differences, again, between the dries and the liquids. When the dry is operating, in the operational mode even on an 80 degree C. rise transformer, this transformer core is going to be upwards of 120 degrees C. in operation.

Now, when we are; testing, we are testing the no 'load losses somewhere in the range of.from 80 degrees C. to 20 degrees C., but in its operational mode when it's installed, it's going to be running at over 100 degrees C. So we are. always on the safe side. Now, to require us to hold this thing in inventory for no particular gain in the marketplace doesn't make a lot of sense..

Now, John'.s comment about having algorithms to establish what this core temperature is is true in a high volume, repetitive type business,; but in a customized business where you're building one and the variety is changing dramatically in scope from one unit to the next, these algorithms don't hold up. 

### S A G CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 

### I 144 1 algorithm. 2 

### MR. PATTERSON: This is just illustrating 3 the differences, again, between the dries and the 4 

### liquids. When the dry is operating, in the 5 operational mode even.on an 80 degree C. rise 6 transformer, this transformer core is going.to be 7 upwards of 120 degrees C. in operation. 8 NOW,· when we are:testing, we are testing 9 the no load losses somewhere in the range of.from 80 10 degrees C. to 20 degrees C., but in its operational 11 mode when it's installed, it's going to be running at 12 over 100 degrees C. So we are .always on the safe 13 side. 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 .hav.ing 18**algorithms~oestablish** 

### what this core temperature is 19 is true in a high volume, repetitive type business., 20 but in'a customizedbusinesswhereyou"rebuildingone 21, andthe varietyis changingdramaticallyin scope from 22 one unit to the next, these algorithms don't hold up.

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2 3

7

9 10 

### 11 12 13 14 15 16 11 is 19 20 21 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 asolution 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 at issue that needs 22 I to be addressed. 

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# ·

' 145

1 This 

### is just illustrating the diff·erences 2 that we have in these processes, in this product 3 scope; 4 

### MR. BALDUCCI: Further questions or 5 clarifications? 6: Wes, in your comments, I would hope that 7 you would address not only this problem, but a 8 suggestionfor a'solution tohow the department ,should 9 handle that. 1Q MR. PATTERSON: My suggestion on handling 11 

### it is that the temperature rise for the core, the 12 reference temperature for the core should be**1~** reflective of the installed condition. Okay? 14 Now, if the installed condition 

### is going 15 to be 100 degrees C. on the core, that's,where our 16 reference temperature for the core should be. It 

### 11 should not be sitting at 20 degrees C.because the 18 core 

### is never going to be at 20 degrees C. in that 19 environment anyhow. 20 

### MR. BALDUCCI: Okay. 21 MR. PATTERSON: .It's an 

### issue 'that needs 22 to be addressed.

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### G CORP. Washington, D.C. Fax:2021797-2525146 MR. BALDUCCI: Okay. 2

4

7

9 10 11 12 13 14 15 16 1T 18 19 20 21 22 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 

### SAG CORP 202/797-2525 Washington, D.C. Fax: 202/797-2525 146 1 MR. BALDUCCI: Okay. 2 MR. HOPKINSON: Well, Phil Hopkinson from ,3 Square D. 4 I certainly can'agree that the,core is 5 going to be "operating pretty much as Wes indicated. 6 So if the intention all the way around is to get 7 losses as the transformer is"to be used, then truly, 8 the best place to get the losses is to take a**h~gher** 9 reference temperature than 20 degrees C. for, core 10 loss. 11 And that will result in somewhere between 12 four and five'percent lower losses of core at the 13 operating temperature ,than it would at 'the 20 degrees ! 14 C. 15 MR. BALDUCCI: I'm thoroughly confused, 16 and that probably mealis we've beaten this ope pre'tty 17' good. Any other**ques~ions** or comments with that? 18 Oskars. 19 MR. PETERSONS: Well, apparently for 20 liquid immersed transformers this has been a decade 21 longdebate, what shouldbe the**referenc~** 'temperature, 22 and I'm sure some of these arguments were voiced

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### CORP.**Wa~hington,** D.C. Fax:2021797-2525147 1 2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### SAG CORP. Washington, D.C. Fax: 202/797-2525 147 l' there, and they did agree to standardize it as ten to' 2 20 degrees C., anq if it is sort of left completely 3 open, then we again have possible measurement 4 Uncertainty of, well, five, six percent of losses. 5. I mean 'how can you, is it possible 6 really ,to standardize at this high a temperature? Do 7 we know the right temperature? Is it not possible, 8 really to measure ,that ambient after it is wound? You 9 have'to intimate and so on. 10 MR. BALDUCCI: Wes. Thank you. 11 MR. PATTERSON: For the ,purpose of this 12 meeting, I just think the point was to illustrate the 13 problems, not to'come up with the solutions, and we 14 can have other dialogues to 'arrive at the solutions 15 that are needed. 16 . MR. BALDUCCI: I have one question. This 17 maybe out of sheer'**ignoranc~.** You mentioned earlier, 18 Wes, that you never know the temperature of the core, 19 correct, if you're going to test an ambient? How

,20 would yOu knoW' then the temperature of'the core at

21 operating temperature? 22

i02/797-2525 MR. PATTERSON: There's a manufacturing 

### SAG CORP. Washington, D.C. Fax:202/797-2525i 148

2

4

6

8 9 10 11 .12 I 13 14 15 16 17 18 19 20 21. 22 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 -- • 

### S A G CORP. 202/797-2525 Washington, D.C. Fax: 202/797-2525 148 

### ·1 process that the units go through,that are -- they're 2 controlled, but**they~re** 

### not 'reflective of the 3 installed condition. 4 

### MR. BALDUCCI: Okay. 5 

### MR. PATTERSON: Now, when I put the unit 6 in service, we know through calculation exactly what 7 those temperatures will be in service, and ·our 8 manufacturing processes are typically running these 9 things at a lower level. Okay? 10 

### Sowe are always producing'a unit that is

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

12 what has been happening 

### is if we had a guarantee on 13 the no.load loss and we measured the thing and it 14 

### didn't pass, we'd let it cool down. It was to our 15 economic advantage to,tie it up in inventory. So we 16 would let it cool down. Okay? 17 

### But if it passed hot, okay. 18 

### PARTICIPANT: The other way around. 19 

### MR. PATTERSON: The other way around. 20 

### MR.' BORST: If you would know the 21. temperature, you could do 

### a precise correction, and 22 then you might get

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1 2 3

6

10 11 12 13 14 15 .16 17 18 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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### 149. 1 

### .MR. ,PATTERSON: And the temperature 2 measurement -- folks, the temperature**meas~rement** 

### on 3 the dry historically has been top core temperature, 4 historically'because you can get at it. You're using .5 that as your reference point. r' 6 

### Whereas ina liquid filled unit, you're 7 

### assuming that the unit· is stabilized. ·So you'**~e** 

### 8 looking at the oil temperature or the average 9' temperature of the unit coming down the line. It is 10 a fundamentally different process. 11 But in any case, the details of the 12 problem, this is a problem that is different between 13 

### the liquid and the dry, and it's one of those'issues 14 that needs to be worked out. 15 MR. BALDUCCI: 'Thank you.

.16 

### MR. BORST: John Borst, ABB. 17 One of the historical reasons that it's 18 differentisbecauseliquidfilledtransformersbecame 19 subject to loss evaluation sooner than .dry type 20 transformers, and actually, you know, that's not real 21 prevalent in dry type transformers today, and before 22 the correction was put in, no load losses were

2021797-2525 SAG .CORP. Washington, D.C. Fax:2021797-2525150

2

5

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

## !1 if you don't specify.

### SAG CORP.

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### 150 1 measured at whatever temperature, and that was the 2 value. 3 

### But as the value of no load losses 4 increased to ·higher levels, some manufacturers were 5 astute enough to figure out that you couldmanipulate 6

-- a poor choice of words 7 .(Laughter.) 8 

### MR. BORST.: you could come up - - you 9 could come up with a different end res'l+lt if you were 10 to take into account temperature, and that forced the 1·1 industry to address a standard correction method and 12 a standardreferencetemperature, and sothat'swhy it 13 evolved in liquid filled and has not evolved to that 14 point in dry type, because loss evaluation has not 15 been as promi,nent in'dry type. .16 

### MR. PETERSONS: A hypothetical

17 

### MR. BORST: Historical. 18 

### MR. PETERSONS:

-- for 35 p'ercent**loade~** 

### 19 drytype transformer, who would.preventthen**op~rating** 

### 20 the transformer. at full' load for 24 hours and 21 measuring losses then? They would be ;lower, I mean, 22 if you don't specify.

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1 2 3

5 6 7 8 9 10 11' 12 13 14 15 16 17 18 . 19 20 21 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 2211 the 100 percent or the unloaded position. 

### S. A G CORP.. Washington, D.C. Fax: 202/797-2525 202/797-2525 151 1 

### MR. BORST: That loophole exists, I 2 presume, since there's no specification of where 3 the

-- currently there's no' specification at what, 4 temperature the no load loss test is done, and there's 5 no correction method theoretically currently. 6 So you're right. 7 

### MR. PETERSONS: My purpose is to 8 

### MR. BORST: Establish-- 9 

### MR. PETERSONS:

-- significant loophole 10 that we really should try to close. II' 

### MR. BORST: Right, and I think Wes' only 12 ,point is

-- well, one of his pOints 'is should it be 13 

### 'representative of operating conditions or riot. I l4 

### think the IEEE position was it's such a weak function l5 of temperature. Let's leave itnear ambient, and that l6 was primarily driven by power.transformer influence 17 because most power**tr~risformers** 

### are tested when they' 18 are near ambient temperature. 19 So let's don't do 

## a big correction, and 20 actually for liquid**fille~** 

### distribution transformers I 

### 2l it'sprobablya toss-up as towhetheryou're closerto 22 the 100 percent or the unloaded position.

202/797-2525 SAG CORP. Washington, D.C.. Fax:2021797-2525152

3 4

6

8 9 10 11 12 13 14 15 16 •17 18 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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### S A C CORP. Washington, D.C. Fax:. 202/797-2525 152 1 MR..BALDUCCI: Thank you.' 2 Any other further questfons or comments 3 regarding this temperature correction? 4 (No response.) 5 MR. BALDUCCI:. Seeing none, we'reon to 6 our last topic, 'which 

### is quality assurance. 7 MS. EPPING: C57.12.00 provides the table 8 of measurement uncertainty tolerances, .and it's my 9 understandingthat C57.12.01, which is currently'in

-- 10 has a revision that's in the process of being 11 reviewed,I understand,' 

### is considering using these 12 tolerances as well. 13 So at this time, DOE is considering**~sing** 14 these tolerances and make them applicable to both 15 types of transformers. I believe it's now done for 16 just the dry type transformers, and we're considering .17 dping them for the liquid as well.

18 So we'd like to ·know' if you have any 19 concerns about applying these measurement accuracy 20 requirements to the dry type**transformer~** as it's now 21 being done for the liquid, and we're also considering 22 including a clause from ISO 9001 for guidance to give

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2 3 4 5 6 7 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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### 153 1 people who might want to know how they implement the 2 requirements of 12.00. They coulduse the guidelines 3 in ISO 9001 to implement these procedures. 4 

### MR. KLINE: I'm Don Kline of Southern 5 .Transformer Company. I.'mgiving the NEMA response to 6 the.question on quality assurance and testing. 7 

### NEMA does not have any concerns about 8 applying the measurement accuracy requirement for dry 9 type transformers as 

# is now done for liquid filled 10**t~ansformers,** 

### nor does it include any concerns about 11 the application of the ISO .9001.measurement quality 12 assurance program. 13 As Kathimentioned', IEEE is intheprocess 14 of revising C57

### .12.01 and. C57

### .12.91 to include the 15 liquid test tolerances in the dry type transformer.. 16 

### NOW, Section

-- okay. The proposed NEMA 17 

### standard, TP-2, standard test methods fOr the' 18 measurement of energyefficient

-- energy consumption 19 of distribution transformers; is written to establish 2

### a the test procedures fo"r distribution transformers for 21 the'measurement of losses. The standardwil'l place a 22 large responsibility on the manufacturer to certify

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1 2 3 4 5

7 8 9 10

15 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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i 

### 154 1 that the loss measurements meet the efficiency 2.requirements of any efficiency standard that might be 3 adopted, such as NEMA TP-2. 4 

### Section 7 of TP-2 includes the testing 5 

### qualitycontrol requirements, and this indicates that 6 the test -- this specifies the'test methods and the 7 

### record keeping. 8 .

### Loss measurement in TP-2 for both liquid 9 

### and dry tyPe transformer specifies the .loss 10**measure~ents** 

### shall be within three percent of the 11 total losses. At first:. blush, three percent sounds 12 like a wide margin. 13 

### However, this Seems wide until you take 14 into account the lost test power factor, the power 15· factor of the actual test'at the room temperature; 16 Take, 'forinstance, a largerliquidfilledtransformer 17 ordrytype transformer forhigherimpedance, just say 18 at 1,500 kVA at eight percent impedance. The losses 19 of load loss as measured by the test is only five

..20 pe:):,cent of ,the total kVA that· the test set sees.

21 We're only measuring five percent of the total kVA. 22

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### So the three perce.nt requirement now SA

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 application's, 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 .i5 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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### 155
1 

### becomes not three percent, but .15 percent. The 2 accuracy of the overall,test now must,be .15 percent, 3 which is very, very tight. 4 

### Now, a distribution transformer, the 5 smaller distribution transformers have a ,loss 6 

### measurement, loss power factor of about 20 percent. 7 

### So in those applications, the test set will have to 8 

### have an accuracy of the three percent times.2, or .6 9 

### percent. 10 Now, that .6 percent is much broader than 11 the 

### .is percent for the "larger distribution 12 transformers. 13 

### Now, this up to now, a limited range of 14 

### small general now, many distribution transformer' 15 manufacturers do not have both liquid filled and dry

.. 

### 16 type, both, not.just dry.type, but liquid and dry; .do 17 not have the test facilities to accurately.measure the 18 losses for' the lowloss transformers as we are talking 19 about today. 20 Most of the'se**manufa~turers** 

### are looking 21 for ways of improving their test facilities just for 22 their own individual application, as well as f,or any

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4

6 7

9 10 11 12 , 13 14 15 16 17 18 19 20 21 22' 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. I trust and urge that DOE sees fit to have

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### 156 1 future application for,the DOE. 2 Sowhat we are suggesting 

### is that adequate 3, time be allowed for all manufacturers to update their 4 

### test equipment ,to meet requirements of NEMA 

### TP-2 or 5 

### ,whatever standard that DOE'adopts. , 6 

### MR. BALDUCCI: Thank you. 7 

### Any questions or comments?' 8 

### Clarifications? 9 

### (No,response.) 10 MR. 

### BALDUCCI: Everybody must have had 

### a 11 'really good lunch because everybo¢y 

### is starting to 12, doze off on us. 13 MR. 

### KLINE: I 

### have a personal re,sponse. 14 

### MR. BALDUCCI: Microphone, please. 15 

### MR. KLINE:' I mentioned that there 

### is a

,16 need to update many of the

-- the small transformer

17 manufacturers to update their equipment. In ,the past 18 two years,',Oskars Petersons has give,n me some 19 suggestions on how a small transformer manufacturer 20 can do it, and I have done it for SouthernTransformer**~**

### 1 'Company. 22' I t;:.rust andurge that DOE sees fit tohave

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1 2 3

6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 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. HOPKINS.ON: 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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## '. 157 1 

### OskarE1 Petersons continue with his effort to aid all 2 transformermanufacturersinupdatingtheirequipment, 3 calibrating**a~d** 

### updatingtheirequipment tomeet these 4 standards. 5 I'mputting in a plu9'for you, Oskars, and 6 also a personal**thanks~** 7 

### MR. BALDUCCI: Thank you. 8 Any**oth~r** 

### questions regarding the**qu~lity** 

### 9 assurance and testing? 10 

### (No response.) 11 

### MR. BALDUCCI: According to our agenda, 12 

### we're done with regards to topics. 1s there anything' ,13 

### else anyone wanted to talk about with regards to the 14 

### proposed test procedures or any of the issues'we've 15 

### talked about·today or any other issue with regard to

. \ 16 

### test procedures for transformers? 17 

### MR. HOPKINSON: Phil Hopkinson, Square D. 18 

### It occurred to me this**mo~ning** 

### when the 19 

### issue came up of the six percent and ten percent 20 'limits on core loss and of the ten percent on core 21 

### loss, the six percent on total loss, at the time we 22 

### were addressing from an efficiency standpoint those

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2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 toprovide long life to the end consumers, so that theten 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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## r 158 1 factors, but truly .that isn't**r~ally** 

### what· drove the 2 adoption of ten percent limits for core loss or six 3 percent for total loss. 4 The background on that . I am absolutely 5 certainwasrelative.tothermalconsiderations andthe 6 impact'on life and the ability of the transformer to 7 provide long life to the end consumers, so that the 8 ten percent was a good representative indication·of 9 what kind of no load loss performance was in the 10 .transformer, and the ten percent, 

### since loss ratios 11 were in the range of four to one on typical 12 transformers, a no load loss represented. around a 13 nominal consideration, around 20 percent of the total 14 losses for the transformer. 15 So a tenpercent variation of the no load 16 loss didn't change the total lqss of the transformer 17 \by very much, and therefore, it didn't have a 18 deleterious effect on the thermal ra.tingof the 19 transformer or its**expecte~** 

### life in the field. 20 So I think .that it was a background or a . 21 lore of where those efficiencies came from that then 22 when, in the 1970s, loss evaluation techniques were

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1 2 3 4

6 7 8

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

### SAG CORP. 202/797

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### 1 started to be applied to liquid filled transformers, 2 thenthose same factors,were continuing tobe,applied, 3 but appliednow from an efficiency consideration, and 4 thequestionof acceptabilityfroma lossperformance, 5 did the manufacturer provide a transformer that met 6 ,the, efficiency that the transformer was being 7 purchased to? 8 

### But really when those factors were 9 developedoriginally, itreallywas not anythingto do 10 with efficiency. It was only the question of was the 11 'transformer able to provide acceptable life. 12 

### MR. BALDUCCI: Any other**qu~stions** 

### or 13 concerns regarding t'ransformer test procedures or 14 anything of the sort? 15 (No response.) 16 MR. BALDUCCI:,As I mentioned earlier in 1 7**th~** 

### workshop, we wanted to determine, based on issues 18 that werebrought to light here, other,issues that may 19 have sparked your interest or other issues you may 20 think may spark your interest, a comment period and 

## 21 how long that comment period should be in relation to 22 what was discussed here and the material that'was

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2

4 5 6 7 8

10 11 12 13 14 .15 16 17 18 19 20 21 22 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, a

'gain,.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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### 1 160 

### 1 passed out. 2 Again, I'd like to reiterate with regard 3 to comments that,will be submitted in writing, if you 4 pad a s.trong point that you felt wasn't covered 

### in 5 detail enough at the workshop, please submit it. If 6 you have some points that you**~elt** 

### were well covered 7 and want to reiterate them, please do. If you have 8 items that you come up**~ith** 

### tonight or in the next 9 week or two, again, please submit it. 10 The more comments we receive, for and 11 'against arguments, helps us out. 12 One thing I do .ask with regards to the 13 comments. If.youdisagree withtheway the department 14 has proposed something or is 

### thinking of something in .15 theirdoc'!-lments, pleaseprovideus.with.a solutionand

16 rationale for that solution, as well. This waywe can 17 defend any changes that we make.**1~** 

### Ifyoujust say, "Well, we thinkit should 19 be this because we think it should be this," that 20 doesn't really help us. 21 Now .I guess would be an appropriate time 22 to discuss a comment period and how long that.comment

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2 3

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 161 1 

### period.would be. 2 I'm going to ask Kathi first off what she 3 was anticipatipg for a comment period. 4 

### MS. EPPING: Generally speaking, we would 5 have a comment period of 30.days, but I'm told that, 6 that might not be long enough for the people in this 7 room, and I guess 

### .r need to get a sense from you. 8 

### Obviously the sooner I can get the. 9· comments in, the sooner I can get working on putting

.. 10**t.o~ether** 

### the proposed rule. I would like to get them 11 no later than the end of March just so that I can

## try 12 to stay on my schedule, and I don't know if that's a 13 

### problem for you or not. So I'm looking for your 14 comments. 15 

### . MR. BALDUCCI: Can we get some -- what I 16 just was squeaking and writing out here quickly was 17 

### the schedule of what we talked about earlier. 18 Right now the department

- - andpart ofmy 19 

### writing now I know why I wasn't a school teacher, 20 because I can't write well at this level --the 21 department· is looking at a notice of proposed 22 rulemaking this summer. In that will be a 75 day.

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1 2 3

5 6 7 8 9 10 11 12 13 14 .15 16

21 22 comment period and public hearing relating to the

notice of-proposed rulemaking.

What Kathi is talking about with regard to the comment period, she wants to have ample time to evaluate all of those comments because they need to be answered and talked about in the notice of proposed rulemaking. So that's why we're asking what you would feel as ample time to make comments.

Think about that for a second: MR. ROLLING: Dave Rolling, speaking for NEMA here. We did discuss this yesterday when the question came up , Kathi, and I think you said 30 days. We said 60 days.. Some follow-up conversation says we. could probably live with 45 days if you could live with that, and again, I'm speaking for NEMA here., We may have folks in the audience who feel differently than that. .

And secondly, we have a question that you can address at some point here, is. whether or not there will be any additional workshops prior to the notice, the preliminary ruling, the summer of '98.

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### 162 1 

### comment period and public hearing relating to the 2 notice of-proposed rulemaking. 3 What Kathi istalkingabout withregardto 4 the comment period, she wants to have ample time to 5 evaluate all of those comments because theyneed tobe ·6 answered and talked about in the notice of proposed 7 rulemaking. So·that'swhy we're askingwhat youwould Sfeel as ample time to make comments. 9 Think about that for a second. 10 MR. ROLLING: Dave Rolling, speaking for 11 NEMA here. 12 We did discuss this yesterday when the 13 ques1:ion came up, Kathi, an.d I.thinkyou said 30 days. 14 We said 60 days.. Some follow-up conversation says we " .' 

### "15 could probably live with 45 days if you could live

16 with that, and again, 

# I'm speaking for NEMA here. We 17 may have folks· in the audience who feel differently 18 than that. 19 And secondly, we have a question th1;lt you 20 can address at· some point.here, is. whether or not 21 there will be any additional workshops prior to the 22 notice, the preliminary ruling, the summer·of '98.

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### G CORP. Washington.D.C.. Fax:2021797-2525163 1 MS. EPPING: The proposed rulemaking. MR. ROLLING: Proposed rulemaking. Thank 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 ,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 1.63 1 

### MS. EPPING: The proposed rulemaking. 2 MR. ROLLING: Proposedrulemaking. Thank 3 you. 4 

### MS. EPPING: At this time we don't have 5 

### any workshops. anticipated. If there's a need to have 6 

### one, we would certainly consider having one.**~** 

### Do you anticipate a need to have another 8 

### workshop? 9 

### MR. ROLLING: I guess, yes, it might corne 10 

### out ofyour sense of how the commen·ts come backtoyo. 11 

### MS. EPPING: Right. 12 

### MR. ROLLING: If the**comm~nts** 

### comebackto 13 

### you with lots of disagreements and

# you have to make 14 

### choices and then you put a 

### proposed rule in, you can 15 

### count on the same disagreements existing. 16 

### MS; EPPING: Right. 17 

### MR. BALDUCCI: Dave, I'm going to 18 reiterate .what Michael mentioned earlier in the 19 workshop. Hopefullythis is not going to be the only 20 time that we talk. When I say "we," I mean DOE and 21 industry and other interested parties; that·it would 22 be more interactive·.

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1

3 4

7

9 10 11 12 13 14 15 !16 17 18 19 20 21 22 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 westartedSo a public workshop, we may or may not . have one, but again, as we mentioned earlie"r, 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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### I 164 1 I mean, if in the middle'of this comment 2 period, if we saythe comment period is going to close 3 some time in March, you have a question about exactly 4 what you're sUbmitting or of what DOE is thinking; 5 call us. I mean, it's

-- and that',sone of the things 6 I want to stress here

- - it's supposed,to be very 7 interactive. ,We want to make sure that we're 8 ,addressingyour conqerns and we're understandingyour. 9 concerns that we do get it so that we don't run into 10 a. situation where Wf= have a notice .for proposed 11 rulemaking out anQ. thEm all of a sudden there's all 12 this contention about it and we're back to where we 13 started .. 14 So a public workshop, we mayor may not 15 have one, but again, as we mentioned earlier, feel ,16 free to contact Oskars or Ka,thi"if you can't get hold

17 of those two, myself as well, withregards to concerns 18 with 'this. 19 So does that kind of 'help you out and 20 answer your question? 21 MR. PETERSONS: Question. I see· for 22 severa+ of the topics where some reallyextensive fine' 

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1 2 3 4 5

8 9. 10 11 12 13 14 15 16 17 18 19 20 21 22 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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### 165 1 tuning will have·to be done, although we probably 2 already at this point perceiv.e that we can come to 3 agreement. It would reallybe very good if Kathi and 4 I could meet with somebody, especially those who 5 raised these arguments, that we couldmeet, say,with 6 a small group, dedicated to a specific topic. 7 

# MR: ROLLING: Let me comment from a NEMA 8 standpoint on that, Oskars. I believe that ,the NEMA 9. organization would·be certainly willing to do. that, 10 

### 'and that ·meeting among NEMA members could be 11 coordinated'through NEMA probably through Lake here, 12 'and I t11ink everybody would agree in NEMA that would 13 be appropriate. 14 MR•. 

### HOPKINSON: 'Phil Hopkinson, Square D. 15 Yes, I certainlyreflect favorablyonwhat 16 Dave just indicated on funneling through NEMA and· 17 coordinating that way. 18 I also would raise issue on the'NOPR for 19 the summer of '98, recognizing that there's a tough 20 period to get people together from the standpoint of 21 vacations, and so maybe some backward thinking as to 22 the plan and adequacy of**tim~** 

### to respond that would

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2 -3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21' 22 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. 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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1 166 1 coordinate around your time setting. 2 MS. EPPING: Right. Thank you. MR..BALDUCCI: One other thing that I, 4 would like to stress inregard to the s'chedule, and it 5 was brought:up yesterday a little bit and just to 6 reiteratewhat NEMA stated todaywith regards to TP-2, 7 the quicker that gets finalized, it makes it a little 8 easier for Kathi when she writes the rule. 9 Summer '98 can go all the way through 10 August. So 11 MS. EPPING: Through September 21st. 12 MR. BALDUCCI: Through Septeinber 21st 13 actually. Michael is shaking his head back there 14 because he's.the one who's got to sign off on the 15 schedules. / 16 So, yeah, we're sensitive tothat. Again, 17 with regards to the NOPR, what will happen, once it,'s 18 published there will be a 75'day comment period. 19 Within that 75 day comment period the department will 20 hold a publichearing/workshop to discuss theNOPR and 21 'decisions on why we're proposing certain things. 22 So 

### 45 days is about?

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7

9 10 11 12 13 14 15 16 17 18 19 20 21 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 22 II a very different set of requirements that are on us 

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1 

### ,MS. EPPING: It's the 27th of March I've 2 

### calculated. 3 

### MR. BALDUCCI: That's what I figured out 4 

### as well. 5 

### MS. EPPING: And it's a Friday. 6 

### MR. BALDUCCI: Is that suitable for 7 everyone, 27 March? Do the ayes'have it? 8 

### (No response.) 9 

### MR. BALDUCCI: Okay. We'll put it down. 10 

### Anyone have any questions or commerits 11 before 'I pass out our evaluations? We have one from 12 the back., 13 

### MR. McCABE: Michael McCabe again. 14 I'djustliketothankeverybody, but also 15 in talking about the comments and how we can work 16 together inthe meantime 

### is topoint out that we're in 17 an informal process right now that:s pre-rulemaking,

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

19 20 

### 21 22 

### overstep the bounds, but we are Administrative Procedures Act in rulemakings, and once we publish the a very different set of requirements

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### guided by the conducting the NOPR, there are

that are on us

Fax:2021797-2525I 168

2 3

5 6



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

F 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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### 168 1 then than beforehand. 2 

### ,But the spirit of the Administrative 3 Procedures Act should'apply to us now as well. We're, 4 tryingto get the input from allparties indeve,loping 5 

### this proposed' ,rule. So while we may talk about 6 working informally with**-~** 

### you know, sharing Oskars' 7 and Kathi's time,withyou to answer questions anq. have 8 a 

### dialogue during this periodprior to the NOPR, that 9 they are,also 

### going to be**t~sked** 

### to working with some 10 other parties. They're,not going to be able to say, 11 "This 

### is what DOE's going to propose." 12 They're going to look to get .as 

### mucp ],3 inf'Ormation. In some of those

### discussionsi 

### they'll be 14 

### looking to come up with what would seem to be a 15 resolution, taking into consideration'issues that an 16 individual, be it the manufacture, an efficiency 17 advocate, representative of another government, you 18 know, what they're trying to resolve, but they're 19 still 

### going to,be bringing that information back**~o** 

### 20 DOE that we still have to answer to Dan Reicher and 21 

### his staff as to what the policy 

### is going to be. 22 But we have a lot more 

### flexibility prior

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5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 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 It . Thank . you. 

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### 169 1 

### to publishing the,NOPR about being able to sit down 2 with parties, and'it is to all of our benefit to 3 identifyissues, talkabout specific language. That's 4 one reason why Oskars' work was shared, so that you 5 had a sense rather than having a vague outline, that 6 we wanted to have something specific. 7 Now, if, you can complete TP-2 in a very 8 ,timely fashion and we look at it and get input from 9 others and we decide that we want to go and 10 incorporate it, we're going to have to de'a:l with a '11 number of issues that haven't even come up explicitly '12 today, and that's do we incorporate it by reference 13 entirely, do we incorporate sections of it,andwe're 14**g~ing** 

### to be having to deal with that. 15 

### So we will try to have as much 16 communication as we can, but we also have to -- I have 17 to answer in certain respect to Ed Levy's guidance to 18 what I can and cannot say, what Kathi can**~nd** 

### cannot 19 say, same way withOskars, but we will try to share as 20 much as we can, but we had better do it sooner rather 21 than later. 22 Thank,you.

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I

3 4 5

8 9 10 11 12 13 14 15 16 17 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. 

### SAG CORP. . 202/797-2525 Washington, D.C. Fax: 202/797-2525 1 170 1 

### MR: BALDUCCI: Thank you, Michael. 2 One thing I do ask of everyone before you 3 go 

### is we have an evaluation form for today's workshop 4 that I**~ill** 

### pass out'now. 5 So I would like 

### to thank everyone for 6 their time today. I know a lot of people have verY ,,7 .busy schedules, and .I 

### thank everyone for attending

8 today's workshop. 9 

### Again, we do appreciate your comments, 10 

### both verbal and written. 11 

### If,'You've got extras, I'll come back 12 around and grab them. 13 (Pause in 

### proceedings.) 14 

### MR. BALDUCCI: We stand adjourned. 15 

### MR. ROLLING: Before we do that·, I, 16 speaking for NEMA here, and.I'm sure the rest of the 17 

### folks who attended'the workshop, want.tothank all the 18 folks' from DOE, Michael McCabe" Anthony Balducci, 19 

### Kathi Epping, Mr. Levy, and .Oskars, as well, for all 20 of the help that you've given us, and I do think the 21 meeting was well run, professionally run, and we 22 certainly appreciate participation.

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2

6 7 .8

10 11 12 13 14 15 16 17 18 19 20 21 22 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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1 171 1 Thank you. 2 MR. BAbDUCCI: Thank you verymuch, Dave. 3 Why doesn't, everyone give themselves a 4 round of applause for a**mee~ing** well done today? S Thank you. 6 We stand adjourned now. 7 (Whereupon, at 1:SSp.m. I theworkshopwas .8 concluded.) , 9 10 11 12 13 14 15 16 11 18 19 20 21 22

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## G CORP. Washington, D.C. Fax:202n97-2525C E R T T P 3 C A T E

This is to certify that the foregoing transcript in the matter of: WORKSHOP ON TEST PROCEDURES FOR DISTRIBUTION TRANSFORMERS

Before: DEPARTMENT OF ENERGY

Date: FEBRUARY 10, 1998 Place:. WASHINGTON, D.C. 172

represents the' full and complete proceedings of the aforementioned matter, as reported and reduced to typewriting-.

V



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### C I B T 

### X

### r 

## x CAT B



### This is to certify that the foregoing transcript in the matter of:

Before:

Date: Place:·· 

### WORRSHOP ON TEST PROCEDURES FOR DISTRIBUTION TRANSFORMERS

DEPARTMENT OF ENERGY

FEBRUARY 10, 1998 WASHINGTON, D.C.

represents the full and complete proceedings of the aforementioned matter, as reported and reduced to typewriting·.

(202)797·2S2S 

### SAG,CORP. 4218LENORELANE,NW WASHINGTON,D.C. 20008 VIDEO:TRANSCRDnnONS