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UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

WORKSHOP ON TEST PROCEDURES FOR

DISTRIBUTION TRANSFORMERS

Tuesday,, February 10, 1998

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The workshop was held in Room 1E-245,

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

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

Chairperson, presiding.

PRESENT:

KATHI EPPING, Chairperson

ANTHONY BALDUCCI, Facilitator

EDWARD LEVY

OSKARS PETERSONS

MICHAEL McCABE

ALSO PRESENT:

RANDY BARNES

JAMES BOHLK

SAG CORP.

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

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UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

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WORKSHOP ON rEST PROCEDURES FOR 

PISTRIBUTION TRANSFORMERS 

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Tuesday, ,February 10, 1998 

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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 

SA G CORP. 

Washington. D.C.- Fax:' 2021797-2525 
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ALSO PRESENT (Continued):

JOHN BORST

LAKE COULSON

JOHN GAUTHIER

PHIL HOPKINSON

DON KLINE

GENE MOREHART

.WES PATTERSON

DAVID ROLLING

KEN STRICKLETT

DAVE WIEGAND

ALAN WILKS

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

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 

SA G CORP. 

Washington, D.C. 

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Fax: 202/797-2525 
C-O-N-T-E-N-T-S3

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 Quality Assurance 152 

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

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PAGE

NEMA Position on Quality Assurance 153

Discussion of Length of Comment Period 159

NEMA Position on Proposed Comment Period 162

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

NEMA Position on Quality Assurance -

Discussion of Length of Comment Period 

NEMA Position on Proposed Comment Period 

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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

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

2 (9:01 a.m.) 

3 'MR. BALDUCCI: Good morning, everyone'. My 

4 name is Mthony Balducci, and Ii 11 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 Ed Levy with our General Counsel should be 

14 here soon,' and we also have Os cars -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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presented in the comments submitted in formulating a

proposed rule for test procedures for distribution

transformers. We seek, the department, to gather

additional information on data on certain questions

and issues being considered by the department in its

..development' of this proposed rulemaking.

We do'not expect to resolve all of the

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

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

things we want to do today is identify issues. We

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

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

The department on January 12th sent a'

letter to interested parties announcing this workshop

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

test procedure prepared by NIST for transformers.

Since. the test procedure document was sent

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

I believe, are in the documents that, were passed out

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

meeting.

22 11. - A public notice of the workshop was

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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 data to guide us on 

9 that. That 1 s a very important point here. One of the 

10 things we want to do today is identify issues. We 

11 don 1 t expect to answer all of those issues today. 

1~ It 1 s going to be more of a data' collection. 

13 The department on 9'anuary 12th sent a' 

14 letter to interested parties announcing this workshop 

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

16 test procedure prepared by NIST for transformers. 

17 Since the test procedure document 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, morning I, as well, as the agenda for today's 

21 meeting. 

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2021797-2525 

A public notice of the workshop was 

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published in the Federal Register on January 20th of

this year, and anyone attending today's workshop or

anyone who submitted comments will be added to our

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

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

workshop or you do submit comments, you will be added

to our mailing list for future mailings regarding

distribution transformers.

The comments received here today and

received. at today's workshop will assist the

department in developing the proposed rule for

transformers.

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

presiding officer and will facilitate the workshop.

I'•ll set the guidelines for conducting the workshop,

as. well, as we go through this -and provide other

pertinent information.

In approximately two weeks, a complete

transcript .will be available for inspection and

copying at the department's Freedom of Information

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

Anyone wishing to purchase a copy of the

202/797-2525

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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 or you 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. 

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2021797-2525 

Anyone wishing to purchase a copy of the 

SA G CORP. 

Washington. D.C. Fax: i0217-97-2525 
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transcript can see the court recorder at the end of

the workshop.

The purpose, again, of the workshop is to

discuss the draft test procedure for distribution

transformers and the issues surrounding it. The

objective is to gather views' and-information on the

draft test procedure for transformers before the

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

department issues a notice of. proposed rulemaking.

We will not be seeking to reach consensus

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

and gather information on them.

To provide the department with as much

pertinent information and as many views as can be

reasonably obtained and enable interested parties to

:.express their views, the workshop will be conducted in

accordance with the following procedures.

Kathi Epping will introduce and lead the

discussion on all the topics. NEMA has requested that

a five minute presentation be given before each topic,

which we have granted. Also NEMA has requested a five

minute overview before we get into each topic, which

202/797-2525

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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 

lIon the issues. We'll be trying to identify the 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 obtained and enable int~rested parties to 

16 ,.express their views, the workshop will be conducted in 

17, accordance with the following procedures. 

18 'Kathi Epping will introduce and lead the 

19 discussion on all the topics., NEMA has requested that 

20 a five minute presentation be given before 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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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 in with regards to each topic ~', ,and all are imTi ted 

5 to participate in the discussions. 

6 'we'll begin with introductions ,after I 

finish my opening comments. Then we'll have a 

8 presentation by Michael McCabe., It'll be 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 then proceed right into the discussion on each topic. 

14 At the end of the workshop we 'll have 

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

16 do is set' a date for ~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, which will be passed 

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out later in the workshop.

We'll take an hour break for lunch around

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

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

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

for coffee. The cafeteria is on the second floor of.

the. West Building. If you need directions for that,

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

can'hold,hands and work their way over there.

Up the street there are also some

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

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

please remember that we want to take on hour.

We will expediate the workshop to be sure

of obtaining each participant's views, -and.if everyone

waits to be recognized , you will have a chance to

speak.

Please remember, and this .is very

important for the court recorder and for the formal

transcript, when you do speak, 'introduce yourself,.

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

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

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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's views ,and, if everyene 

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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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 end by 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 

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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 written comments and'data submissions 

will be available for public in~pection at the DOE 

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Freedom of Information Room, which is down'the hall.

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

comments should be addressed to Sandy Beall at the

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

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

Edwards - Jones as -indicated in the notice that was

published in January.

.-Ten copies of comments or data, 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

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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 should be 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 Any person SUbmitting information which he 

18 or she believes'to be 'confidential an exempt by law 

19 from public '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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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

SAG CORP.

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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 appreciate your time and effort 

14 you have taken in preparing 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 and the issues surroup.ding it, 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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head table?

MR. LEVY: Ed Levy, Office of General

Counsel, DOE.

CHAIRPERSON EPPING: Kathi Epping. I am

the. Program Manager in the Office of Codes and

Standards on distribution transformers.

MR. PETERSONS: Oskars Petersons , National

Institute of Standards and Technology.

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

get a little difficult. I would like if everyone

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

take a little time, but it's worthwhile.

MR. COULSON : Lake Coulson , National

Electrical Manufacturers Association.

MR. ROLLING : David Rolling , Cooper Power

Systems.

MR. PATTERSON: West. Patterson, ABB.

MR. BOSIGER: John Bosiger, ABB, South

Boston, Virginia..

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

MR. HENRY: George Henry, Central Moloney

Transformer.

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1 head table? 

2 MR. LEVY: Ed Levy I Office of General 

3 Counsel, DOE. 

4 CHAIRPERSON EPPING: Kathi Epping. I am 

5 the, Program Manager in the Office of Codes and 

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6 Standards on distribution transformers. 

7 MR. PETERSONS:. Oskars Petersons, National 

8 Institute of Standards and Technology. / 

9 MR. BALDUCCI: This is where it's going' 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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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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Washington, D.C. Fax: 202/797-2525

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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: 'John Peltz, Atlantic Division, 

17 Navy. 

18 MR. GLENN: Peyton GI~nn, Atlantic 

19 Division, Navy. 

20 

21 Institute. 

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2021797-2525 

MR. HALV: Ken Hall, the Edison Electric 

MR. SIQUEIROS: Carlos Siqueiros, ,Cutler 

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Hammer.

Company.

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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.

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

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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. 

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MR. LINK: Dick Link, General Electric.

MR. BOHLK: Jim Bohlk, United States

Department of Agriculture, Rural Utilities Service.

MR. AGUDO: Mike Agudo, RUS.

MR. SMITH: Henry Smith, PEMCO

Corporation..

MR. BUSH: Carl Bush, PEMCO Corporation.

MR. HYLAND: Mike Hyland, American Public

Power Association.

MR. STRICKLETT: Ken Stricklett from

National Institute of Standards and Technology.

MR. RABA: Jim Raba, Department of Energy,

Office of Codes and Standards.

MR. ADAMS: Carl Adams, Office of 'Codes

and Standards, DOE.

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

MR. NASSERI: Cyrus Nasseri, Department of

Energy, Office-of Codes and Standards.

MR. BARNES: Randy Barnes, Oak Ridge

National Laboratory, Oak Ridge, Tennessee.

MR. McCABE: Good morning. Michael

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

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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. STRI CKLETT: Ken Stricklett from 

11 National Institute of Standards and Technology. 

12 MR. RABA: Jim Raba, Department of Energy, 

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: Cyrus Nasseri, Department of 

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 

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Standards.

MR. BALDUCCI: Thank you -very much,

everyone, for the musical chairs exercise we just went

through.

One other thing,before Michael gives his

presentation. We do have some extra copies of the.

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

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1 Standards. 

2 MR. BALDUCCI: Thank you' very much, . 

3 everyone" for: the musical chairs exercise we just went 

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 to Washinsrton. It's 

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

18 something which I can certain appreciate since I've 

19 been in the middle of a six and a half week process 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 wi thin ' 

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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

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Washington, D.C. Fax: 2021797-2525

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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 ,of products, including electric distribution , ' 

6 'transformers, to determine whether or not the 

7 department should proceed with a rulemaking program. 

8 As ,many of you are aware ,October this 

9 ,past year we issued a determination that standards 

10 appear -- and I 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 and our overall process because 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 , 

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like to reiterate that this is not a standards

rulemaking.

If somebody were to ask me whether or not

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

when the department will issue a final rule on

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

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

procedure .rulemaking and any subsequent standards

rulemaking will determine whether and if there will be

a standards rulemaking.

But I'd like to deviate briefly from the

topic of today's workshop and address some of the

points on standards that.'have been raised. I would

like also to entertain any questions at the end of my

presentation . If there's something that is confusing

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

free to raise your hand and ask me to clarify the

statement that I've made.

The department has gone through a process

which lasted approximately a year to develop a new

process for.conducting standards rulemakings-. We will

apply that process to transformers. This is part of

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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 ", rulemaking will determine whether and if there" will be 

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 standards rulemakings. We will 

22 apply that process to transformers. This is part ·of 

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that process in many respects.

The key element to the process, in my

view, is to share information early and often with

interested and affected parties so as to .make sure

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

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

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

for you to know where we're headed.

So this workshop, much of what we're doing

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

test procedure, labeling, or even a standards

rulemaking such as what we have.a workshop next month

on, the standards analysis for standards for

residential clothes washers. So a major element to

the new process is this exchange..

Kathi and Oskars, for example, are

available to all. We have encouraged'the NEMA staff

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

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

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

also raised some questions.

Oskars, for example, 'is not a DOE staff

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

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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 So this wb:t:kshop, much of what we're doing 

io throughout the entire process, whether or not 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 to use 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 

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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

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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 often than not they're on target, 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 

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

.that efficiency.

I can remember back in the early days of

the program when we were working with two legislative

deadlines to establish energy efficiency targets for

residential equipment, and at the same time we were to

set test procedures for those products. The deadlines

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

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

because as manufacturers were trying to give us

information on how efficient a product is for a

central air conditioner, if you're talking about

steady state efficiency, are you talking about an

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

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

temperatures, you're going to get different results.

So we have. committed that in order to have

an effective, valid standards rulemaking for any

product, that we will get 'the test procedures in place

before we go into the standards rulemaking.

And' once the test procedures are

developed, the standards rulemakings for any product

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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 program when 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 test procedures for those products. The deadlines 

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

. 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 So we have .committed that in order to hav:e 

18 an effective, valid standards rulemaking for any' 

19 product, that we will get the test procedures in place 

20 before we go into the standards rulemaking. 

21 And once the test procedures are 

22 developed, the standards rulemakings for any product 

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are kicked off through the prioritization process,

where we, the department, will identify through an

open process what the priorities are.

That process invites public input, where

we will share preliminary information prior to

establishing the process. In that preliminary

information,,we will have 'staff recommend what the

staff, opinion is as to what the priorities should be.

We're going to be seeking public comment

on. that. We've gone through two priority setting

processes already, and this is an'annual process.

both cases we receive comment 'on the priorities that

resulted in us changing or the department came. out

with a -- the final priorities were different than

what the staff initial recommendation was.

It is important' in the priority setting

process that if you agree with the staff

recommendation you.say so. If you disagree with it,

say so as well because there are. parties who have

different agendas, and if we only get comments from

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

like to see you change the priorities for this reason

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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 

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

we respond to where the noise is in many cases.

The priority process, the prioritization

is based primarily on the.potential energy savings.

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

the economic and the environmental impacts of such

standards..

We may look at a particular level of

efficiency as far as what its potential savings is,

but generally we will look at a range because, you

know, there are certainly for, some products where you

can go with a maximum standard, very stringent

,standard, but for economic reasons, impact on

consumers and the like, that level would not be

reasonable.

.So we will look principally at energy

savings, but we . will try to balance it with other

factors.

If a product is a priority product for

standards and we go into rulemaking, having a chemical

engineering background, which is, just an advanced

plumbing degree, I kind of like this image -

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1 or the other," and everybody 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 certainly for 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 and we go into rulemaking, having a chemical 

21 engineering background, 'which is, just an advanced 

22 plumbing degree, I kind of like this image 

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(Laughter.)

MR. . McCABE: -- because to me it just

looks like a whirlpool. Otherwise some of the water.

hydraulics. It just looks like a toilet.

But the process is -- and some of the

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

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

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

screen.

So we'll go through a process to get

stakeholder input in order to develop the regulatory

agenda, which will be published -- the priorities

which will be published in the regulatory agenda.

We will then go through a screening

process for the standards rulemaking where we will

screen out efficiency designs which have health,.

safety, utility impacts that do not warrant

consideration in the standards rulemaking in order'to

narrow the range'of options that are being considered

for standards such that. when we' come out with an

advanced notice of proposed rulemaking, with the

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

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

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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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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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, dishwashers I ' 

7 cen~ral air conditioners; any of the products 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 or nota standard is warranted 

12 at a particular level and make. that recommendation to 

13 the department before we go out with the proposed rule 

14 and then the final rule. 

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16 

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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 --

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microphone, please.

MR. HOPKINSON: I'm sorry. Phil Hopkinson

from Square D.

Michael, I'm sorry, but the economic

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

in the presentation that you have what measures you're

using to reflect the economics. Can you comment on a

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

so on?

MR. McCABE: In the standards analysis, as

part of the advanced notice of proposed rulemaking,, at

that point 'we expect to have a -- our preliminary

analysis will include preliminary energy savings

forecast, preliminary life cycle cost analysis, and

price efficiency curves for the various products.

What we will strive to do before that

point, before we. do the analysis for the proposed

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

what are the appropriate metrics to examine in the

economic analysis, in the engineering analysis, so

that it will give you an opportunity to help to

structure the analysis.

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1 micropho~e, please. 

2 MR. HOPKINSON: I'm sorry. Phi I Hopkinson 

3 from Square D. 

4 Michael, I'm sorry, but the economic 

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

6 in the presentation that you have what measures you're 

7 using to reflect the economics. Can you comment on a 

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

9 so on? 

10 MR. McCABE: In the standards analysis, as 

. . 

11 part of the advanced notice of proposed rulemaking,. 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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But we're 'looking at both impact on the

customers, the impact on the nation, the impact on

manufacturers, and the specifics as to what those

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

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

of _a residential product, or in this. case transformers.

If we go into the priority setting and

transformers ends up being a priority product, we will

then come back and look to those who are involved with

this product to help us structure the analysis.

So there are many other questions as far

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

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

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

priority product, and then' we're going to work

together to try to structure that analysis.

MR. PATTERSON: Wes Patterson, ABB.'

Where in that chart are we right now?

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

now.

(Laughter.)

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

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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 to you, to help us 

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

6' ofa residential product or in this, case transformers. 

7 If we go into the priority setting and 

8 transformers ends up bei~g a priority pro9uct, 'we will 

9 then come back and look to those who are involved wi th 

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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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

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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 interested in .your suggestions 

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

14 I-think I had mentioned that Oskars has been working 

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

16 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. 

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consensus standards that we have adopted. Some we

have incorporated entirely by reference in our

regulations.. We look to do that Wherever possible.

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

look to support that activity, and we will adopt any

consensus standard that meets our needs and

objectives. Where it does not completely meet our

needs,' we will adopt that portion that does'and'then

supplement, with the balance from our work, but we will

try to share that information with you early so that

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

needs are so that we can:work together and'hopefully

incorporate any consensus standard in its entirety

with a minimum amount of input from us.

Again, the process that we're looking at

and the three principal blocks in this program,. the

determination notice has been completed, and we're now

in'the middle block in test procedures.

Questions about the standards analysis,

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

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

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

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1 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 that you're working on TP-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 the balance from oUr work, 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, . determination notice has been completed, and we're now 

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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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

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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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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 the program is ac:::tuallythe Consumer Products 

9 Program - - . Energy Conservation Program for Consumer , . 

10 . Products Other Than Automobiles, and I would not try 

11 to' describe an electric motor i 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· generically to 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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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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1 The test procedure is also the basis for 

2 labeling. The Federal Trade Commission labels most 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 test proa:edures are also the basis 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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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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1 we're 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 on TP9 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 our proposed .rule, we're not going to propose 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 to be based on either something that's --

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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 if we I re proposing to aqopt something, it's there. 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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MR. ROLLING: No.

These are going.to-be brief. My name is

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

Transformer Section of our Equipment Division within

NEMA.

_ And on behalf of the largest trade

association in the United States, representing the

interests of the electric industry manufacturers, the

National Electric Manufacturers Association, NEMA, I

want to thank you for the opportunity-to 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 industry manufacturers, 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 the positive determination notice of 

22 October 22nd. We wan:t to compl~ment the DOE and Oak 

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Ridge for assembling very.competent folks in putting

together those reports, and we' want to compliment the

quality of those reports.

We note, however, that this does not mean

we're in full agreement with everything, with all

aspects of those statements. For example,. in the

determination notice, the definition of distribution

transformers was expanded down to a quarter of a'kVA.

We disagree with that, and there are other points we

disagree with. .

Also, we would like to reaffirm NEMA's

basic principles regarding energy efficiency

standards. we believe that energy efficiency is a

national concern and should be driven: by market

forces. Industry should be proactive in establishing

voluntary efficiency standards , performance standards,

test procedures, and measurement tolerances.

Manufacturers, should provide consumers

with accurate and standardized information about

energy efficiency performance that is based upon

voluntary, consensus standards.

We look forward to participating in

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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 wi th everything, . wi th 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;' IndustrY should be proactive in establishing 

16 voluntary efficiency stanqards, performance standards, 

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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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 work shop 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

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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 will not have an industry 

7 position or" response and will be seeking-. further 

8 clarification or seeking definition of terms on a 

9 particular topic. 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 In tho'se instiances, it will be 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 review just 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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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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1, di$cussing, and Kathi, as I said before, will be 

.2 leading the discussion on 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 quality assurance. That's all in the 

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 and what 

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' 11 have an evaluation and then 

20 an adjournment. 

21 With what, any questions, additions or 

22 deletions from theagend~? 

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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

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1 (No response.) 

2 MR. BALDUCCI: Seeing none, I will turn it 

3 . OVer to Kathi I and we'll j.ump right. into the' topics I 

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 would like to incorporate the existing 

10 national consensus stanqards to the extent possible . 

. 11 However, the consensus stfandards do not address issues 

12 that are normally included, topics that are normally 

13 included in DOE ·testpr~cedures, .such as the concept 

14 of a basic model and the 13election of a sampling plan, 

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 that might cause 

21 ambiguities, and' DOE w0'!lld like to eliminate those 

22 ambiguities and differences as much as possible when 

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we issue our test procedures.

There are four primary consensus standards

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

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

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

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

requirement standards.

In addition, we'd also be looking at the

TP-1 guide and the ISO standard 9001.

And in addition,. we'd also like to

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

We know that these are nearing.completion, and once

they are approved by their sponsoring organizations,

and preferably if we can get` this,. if they get

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

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

they were an official document.

So what we'd like to know is are these

standards. appropriate for us to be referencing and

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

would we want to reference appropriate chapters.

And we'd al$o like to know if the

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1 we issue our test procedures. 

2 There are four primary consensus 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 organizations I 

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 

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standards that are in the preparation, stages, the

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

and we d also like to 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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1 standards that are in· the preparation stages, the 

2 PCS7.12:3and the TP-2,if .we should reference them, 

3 and we'd also like to knq,w fro,m you what your 'schedule 

4 is regarding getting thqse documents out. 

SSo now 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 incorporated into Tp-2 th~ testing components from the 

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(:mentsfrom NEMA's TP-1 .1996 

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and ISO 9001, 1993.',

Additionally;,-we have included into TP-2

additional relevant standards that are in the

preparation and approval stages, such as IEEE

PC57.1233.

In topics to be covered during today's

workshop, NEMA's response will include the relevant

section from TP-2.

.The DOE 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

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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'd like to open it up how 

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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

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~ 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: phil Hopkinson from Square 

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 referred to 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 ask with regards 

17 to TP-2, and this questiol\1 Michael brought up ~ariier, 

18 waS DOE cannot reference.~ standard or a test standard 

19 without it in place. The I one 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 

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anticipate a notice of proposed rulemaking for test

procedures. We were curious when NEMA anticipated

that TP-2. being finalized.

MR. 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 believe

the 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.

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. 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 .to be prepared. There may be some additional 

9 editorial comments we haJve to make. I' would believe 

10 the document should be afproved by 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 availability be 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, it will be put ~n for publication and would 

22 be available to the publ~c as soon as it's printed. 

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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.

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1 I would expect i t shou~d be printed wi thin 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. GAUTHIER I: 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 

1 7 it's an appropria te docum~nt - - it should be ... - that's 

'18 part of the general refe#ences. It will be.included 

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

20 'b~lieve' in the informatip~ that we gave you that it 

21 probably was equally the~ame thing. It's available. 

22 

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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. GAUTHIER

al? 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 s t andard .

.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

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1 So it contaifns testing protocols 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 i EPPING: 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, you might address TP-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've I indicated, 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 ANS I process, . CS 7. We 

20 expect as soon as it' s ap~roved as a NEMA standard. and 

! 

21 received comments back frctm their review, we'll adjust 

22 the document and then su~mit it to ANSI for approval 

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as an American national; standard, and that process

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

And of-course, with regard to -- just by.

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

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

ballot. So 45 days 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.

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'1 as an. America~ nationa~ standard, and that process 

2 should-- I would believ~ -- will begin probably mid- . , 

3 March if not sooner, 19~8. 

4 And of' courS!;e I wi th regard to - - just by. 

5 way, Mr. Levy, of indi~ating the process f. I'm the 

6 secretary for C57, and tj:he ballot is about a 4S-day 

7 ballot. So 45 days after I 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 

1 7 ahead of schedule now. : We're not going to take a 

18 break now because 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 

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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.

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I' Let me ask 'j NEMA whether or not there I s '. 

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 he t s 

5 been involved, is, you kl\low, what have you seen in the 

6 development of TP-2 thatl you 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 wi t;.h regard to your 

20 question with regard tp' Oskars, we've been very 

21. priv'ileged to ha";-'e Oskarsi involved in our process from 

22 almost the get-go. 

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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

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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' think perhaps only , 

, . 

4 in the area of the samfling formulae' is . there'. any 

5 modem of difference, but! I think that t s 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· couple lof 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 i really having - - 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 

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

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

existing primary IEEE/ANSI standards, and this has

been done also.

So really I,have been quite pleased what

the progress has been, and there are obviously some

fine points where I may;not agree immediately, but I

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

as a green light.

MR. 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.

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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:err test 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 basic models partly to refuce the testing requiremen~s 

21 . for the manufactu'rersl~nd basic models are ,used in 

22 the sampling process. 

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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 alre ady 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.

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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 should def ine basic modells so we don't ov.er burden you 

I 

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

l 

11 objectives, as well. 

12 So we've alrelady heard that there 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, if we could gr9uP models 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. 

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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 TPS A C CORP.

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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 your presentation, I just 

6 wanted to recognize Debofah Miller 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 started on this project jthat for some ma'nufacturers, 

13 each transformer is practically its own -- , , 

j 

14 MR. BALDUCCI:\ Use one of the microphones) 

15 either one. 

16 MR., PETERSON~: -- is its own basic model, 

17 but I believe usingsuc~ a normalized approach in 

i 

18 representing either lossts -- efficiency is already I 

I ' 

19 normalized -- one can real!ly combine 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 what lis done, for example, in TP2021797-2525 

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1 and in Canadian standard, there were minimum

efficiencies or maximum losses applied to standard kVA

ratings, and I believe all transformers in that

' •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.

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1 1 and in Canadian strndard, there were minimum 

2 efticiencies or maximum ~osses applied to standard kVA 

3 ratings I 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 loss I and you subtract 

8 mandated loss and dividt and then add one, and you 

i 

9 will end up 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 

Wi th . regard to NEtJIA' s 

21 position. on the definitio~ of basic model, we support 

22 the following definitionlfor basic model. 

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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,

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1 Basic model would be defined by output 

2 power I kVA 'rating I 'su'ch as one of those tabulated in 

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

4 power, kVA +"ating i insulation type; liquid immersed or 

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 ,in one 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' on what 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 

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Oskars, on the formula that you just gave, 

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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.

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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 normalized loss would be over the 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 shouid be, at least from a· Square D position 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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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

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1 I would propose that the 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 In addition, I would also add transformers 

18 for unusual te~perature rises 

19 MR. LEVY: This is Ed Levy from Department 

20 of Energy. 

21 I take it what you're talking about here 

22 is or what you were describing there were transformers 

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that would be excluded from coverage of the test

procedures?

MR. HOPKINSON: These transformers would

not be part of the basic model'.

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

model ',.the purpose for -- there would be presumably

several basic models of any manufacturer depending on

what was produced. The purpose of the concept of. a

basic, model is to group' different models of

transformers that a given manufacturer, produces so as

to limit the testing burden.

I inferred from what you were saying that

the exclusions that you described would be equipment

that would not even be subject to the standards, would

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

intention?

MR. HOPKINSON: Yes, that's correct.

MR.. LEVY Okay. Which I see is something

we certainly need-to deal with as part of this entire

effort, but it's a different question from grouping

those transformers which are covered into groups so as

to eliminate or not eliminate, but reduce the amount

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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 of any manufacturer 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 given manufacturer. 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 even be subject to the 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 certainly need·to deal with as part of this entire 

, . 

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

. . 

21 those transformers ~hich are covered into groups so. as 

22 to eliminate or not 'el~minate, but reduce theamou~t 

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of testing that's required.

MR. HOPKINSON: Yes, we agree with that.

I think those transformers that are included would fit

the definition that Mr. Coulson presented from NEMA,

those transformers that are not included, and should

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

one. that I just mentioned.

MR. PATTERSON: Wes Patterson,'ABB.

Edward,. the list of exclusions that Phil

.just ran off pertains to in the proposed test

procedure draft, there's a definition of distribution

transformer which included all.of those products. So

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

also have to have an exclusion clause.

Thank you.

MR. GAUTHIER- John Gauthier.

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

scope identifies these lists of equipments ,as excluded

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

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

covered it.

MR. BALDUCCI: Michael has just 'made a

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10f testing that's required. 

2 MR. HOPKINSON: Yes, we agree with that. 

3 I think those transformers that are included would 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 lists of equipmen.ts ,as excluded 

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 

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

to add on the agenda would be coverage of the test

standard and which transformers would be covered,by

the test'standard.

Before we move to that, -do we have any

other questions or comments or concerns regarding

basic model either from the panel up here or anyone in

the audience?

MR. WILKS: Alan Wilks, ARMCO.

I understand that the normalized formula

given would be an accumulation of an average of all of

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

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

unit. or units could .exceed the minimum efficiency.

However, the average would be necessary to be below;

is that correct?

MR. PETERSONS: Yes..

MR. BALDUCCI:. Further .questions- or

comments regarding basic model?

(No response.)

MR. BALDUCCI: If not, 'I would suggest we

move in to have a short discussion on coverage of

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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 basic model 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 would be 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 

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transformers. We heard some comments .of what's

covered and what's not covered.

Michael, did you have any comments to

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

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

confusion of where we are, what the test standard

would cover, and I think we, need to clarify that

before we press on.

MR. McCABE: Yeah,. this is Mike McCabe.

Building on what Ed Levy has said, the

basic model, the concept for that has historically

been to recognize that while, a manufacturer may have

a number of individual models and that. some of them

may only' be differentiated from others based on

geometry or features that do not affect efficiency,

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

concept of basic model in order to bin, cluster,

group, 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

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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 different models to t~stingi that 

22 you can just take and clump them into one cohort and 

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test them for the. purposes of this program for making

ratings on. efficiency.

That.doesn't necessarily mean that those

are all the same models as. you would consider them

because you're marketing products to a very diverse,

very specialized-application, and you know, 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

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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 should be eliminated and why, in order, to provide 

20 that rationale because when we come out with the 

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

22 not a quarter kV transformer should or shouldn't be 

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covered.

If^ we're going to take -a position and say

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

said. so, because Valerie., representing Natural

Resources, Canada, may have a very different position.

So we'd like to have an open discussion

and the rationale in order so that we can make a

reasonable decision and put that into the language in.

the proposed rule..

MR. ROLLING: Dave Rolling from Cooper

Power Systems.

I can address parts of the exclusion, not

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

was identified for exclusion has some particular

characteristic about it as a product that makes it

difficult to let energy efficiency be the overriding

need.

For instance, when you're designing a

rectifier transformer, many times there'are -- it has

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

load characteristics based on the load it's driving

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

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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, may have a very 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 and put that into the language in, 

9 the proposed rule .. 

10 MR. ROLLING: Dave Rolling from Cooper 

~1 Power Systems. 

121 can address parts of the exclusion, not 

13 all of it. Generally speaking, each of 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 des igning 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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that, the product won't work properly.

So efficiency, while you could try to get

it, it cannot be your overriding consideration.

Another situation would be if you're

trying to retrofit a transformer into a building, into

a particular basement area or something like that, you

have dimensional constraints, and so the overriding

constraint in that transformer design doesn't become

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

location you're trying to put the transformer to hit

the type of efficiency that the minimum efficiency

standard would want you to make.

And you could go down that whole list of

transformers and come up with the fundamental reasons

that each of them, has some other overriding design

constraint.

MR. LEVY: Let me raise a question with

you, Dave.

This is Ed Levy again.

MR. ROLLING: Yes.

MR. LEVY: The question here is whether

or not. a particular transformer is -appropriately

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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 trying to retrofit a transformer into a building, into 

6 a particular basement area or something like that, 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 up with 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' 

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described as a distribution transformer. That's what

the department is charged with regulating or at least

examining the issue of regulation.

And if it's a distribution transformer,

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

that the points you're raising are not appropriate for

consideration. Those points may affect the precise

test procedure for that kind of transformer or the

standard level for that kind of transformer.

So the question here is not so much what

distinction should be made among transformers, but

rather at a sort of broader level. What should be

properly classified as a distribution transformer and

what should be classified as not being a distribution

transformer?

I don't know if your comments really

address that question.

MR. McCABE: Mike McCabe.

Excuse me for interrupting here. Let me

add one other point.

MR. BALDUCCI: Michael, leave it on.

22 11 MR. McCABE: How's that?

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

2 the department is charged with regulating 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 the points you're raising are 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 

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MR. McCABE: How's that? 

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Many of us are much like myself in being

task oriented and look very specific in using some

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

deal with many of those issues you'raised in the test

procedures by establishing different categories of

products.

The first question now that we have is

whether or not it appropriately is a covered product

and whether or not it is a transformer.

So, for example, one of the first tasks I

had to do with this program was to define whether or

not a'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

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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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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.

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1 . . PTAC was in order to exclude it from the program 

2 because the program at that point in time was intended 

3 for residential products, not for commercial products. 

4 So that . one question we' 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 water heaters. 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 water heaters that are covered by the 

21 test procedure, which is a smaller set than what is 

22 covered by th~ program. 

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So by defining the definition of water

heaters for coverage under test procedures, we

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

that physically couldn't test, and there will be

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

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

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

hard time in this industry since a chemical engineer

can understand water flowing,. but why current goes one

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

(Laughter.)

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

give us direction. So instead of going like that.

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

what makes sense.

Granted there are reasons why you cannot

design any more. efficiency into a product because of

space limitations, but that has been addressed in many

instances before, and Chuck Hastings when he was

working with some of the residential products can

appreciate that we can establish classes, and -we have,

22 11 • which those classes recognize some of those

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, 1 So by defining the definition of water \ 

2 heaters for' coverage under test procedures I we 

3 eliminated products, some of which you'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 ·can understand water 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 has been addressed in many 

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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limitations,' and through the-process of establishing

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

classes may or may not be subject to standards.

So what we're looking for in coverage is:

is this a transformer? Is this a product that should

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

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

the ANSI standards? Is it a product that we should

consider.for test procedures?

But then when it gets into standards,

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

going to have to address.

MR. ROLLING: Unfortunately the choice of

words, "distribution transformers, ".that was in the

original legislation is very ambiguous terminology,

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

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

different definitions probably within this room.

So we start from that rather broad

categorization in the original legislation, and that

does make this difficult, not overly, difficult, but, it

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

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1 limitations, and through the process of establishing 

2 classes, that if it gets into a '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 does make ., this difficult, 'not overly difficult ,but· it , 

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

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definition of distribution transformer first.

MR. McCABE: This is Mike McCabe.

That's key. Every product that we cover,

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

product is so that we then.know what is covered.and

what we're talking about.

MR. PATTERSON: Wes Patterson with ABB.

If you go to page 16 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

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l' definition of distribution transformer first. 

2 MR. McCABE: This is Mike McCabe. 

3 That', s key. Every product 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, test procedures,' there's a definition by the 

10 DOE of what a distribution transformer is. In this 

11 definition, they have takenwhat has been historicall,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 from primary circuit to secondary distribution 

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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never meets that paragraph.

So all that was, all that Phil was trying

to do was to elaborate on the specific instances of

that paragraph which do not pertain, but people can

translate from the following paragraph to be included.

So we have a confusion between these two

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

do is clarify either that or maybe in your test

procedure' you can just remove the definition of

distribution transformer and pick it up over in the

energy efficiency standard later on. down the road and

not try to establish definitions in this document.

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

also what's normally done in the standards industry.

MR. LEVY: But we do need to establish a

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

getting here on this issue are entirely pertinent and

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

sentence too broad. You said at the outset of your

comment here that the-.second sentence --

MR. PATTERSON: For instance --

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

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1 never meets that paragraph. 

2 So all that was I 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 from the following paragraph to be 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 establish how 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 entirely pertinent 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 

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MR. PATTERSON: For instance --

MR. 'LEVY: -- things that would be

considered distribution transformers.

MR. PATTERSON: It says, "For the purpose

of this DOE test procedure, transformers of the

following rating are included: primary voltage of 480

to 35 kV." Okay?

MR. LEVY: Yes.

MR. PATTERSON: Starting off with a

primary voltage of 480 and-contending that that is a

distribution class . voltage is counter to what the

entire industry has done for the past 100 years.

Distribution is usually rated much higher than 480.

MR. LEVY: Where would you set the floor

on that?

MR. PATTERSON: Personally I would set it

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

manufacturers here and see where they would put it,

but most of them probably will not' put 480 volt,

because that's usually an application voltage, not a

distribution class voltage.

Okay. The next thing is that' between

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1 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 procedure I transformers of the 

6 following, rating are included: primary voltage 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. 

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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

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1 liquid and dry there are two definitions.' Is that 

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

3 ten kVA. No, it's a -- but I thought that was 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 for distribution different between liquid ,and dry when 

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

9 any sense. 

10 MR. LEVY: Which is not.justifiable? 

11 MR. PATTERSON: Trying t'o say - that a 

12 transformer because of its insulation class determines 

13 whether or .not it's distribution. The insulation 

14 class has nothing to do with distri~ution. It's the 

15 application of the product that has to do with whether 

16 or not it's 'distribution. 

17 The most correct statement in this whole 

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

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

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

'21 this docume~t . 

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

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become more explicit. When you look at his specialty

transformers, they are not being deployed in

distribution class service. They are being deployed

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

piece of equipment like the transformer that's inside

that light box, and that, shouldn't be considered

distribution.

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

the table now. So I think --

MR. PATTERSON. Thank you.

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

MR. 'BALDUCCI: Do we have any other

comments or questions or clarifications on that point?

Oskars, you look like you were ready to

say something or no?

MR. PETERSONS : Well, the way I arrived at

that.definition, I believe, was the first part comes

from IEEE dictionary and inclusion or exclusion, 'I

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

voltage ratings,'but that can be modified.

MR. HOPKINSON: This is Phil Hopkinson

from Square D.

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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 or questions or clarificat~ons on that point? 

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. 

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I was just reading from the Federal

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

Ridge National Lab analysis," which we presumed is a

forerunner for this meeting today, "did not consider

transformers which are not continuously connected to

a power' distribution system, such as distribution

transformer. For example, transformers that are part

of machinery which are switched off from electrical

power were considered by the study as a component of

the machinery circuit and not part of the power

distribution circuit.' Also special purpose control

and signal transformers," which these quarter kVAs, by

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

transformers were excluded from consideration because

they are not classified as distribution transformers. "

So that our position would be that

transformers like control power transformers, which

the fractional kVA transformers represent, are not

distribution transformers.

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

you go on in the next paragraph, it articulates the

definition in terms of primary voltages and

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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, " which these quarter kVAs, by 

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

14 transformers were excluded frbm consideration because' 

15 they are not classified as distribution transformers. " 

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 

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capacities, stating that. the language that you just

described would be accepted-from that.

Are you saying that in some of these

capacity ranges, for example, that there are .no

transformers that don't fall within these accepted

areas of distribution?

MR..HOPKINSON: I would say that I would

agree with the definition that primary distribution

transformers are above 1.2 kV class.' primary, and

secondary distribution transformers are those below

1.2 kV class primary, but that fractional kVA up and

below ten kVA would be considered as excluded because

they are predominantly not distribution transformers.

MR.. LEVY: Now, when you say

"predominantly," I mean, how predominant?

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

80 percent of those transformers would be machine tool

control type transformers. They'd be part of another

piece of equipment. They wouldn't be used separately

as a power transformer.

MR. LEVY: So would you say 15 to 25

percent would be used as

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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 wi thin 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 excluded because 

13 they are predominantly not distribution transformers. 

14 MR. LEVY: Now, when YOll say 

15 "predominantly," I mean, how predominant? 

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

1 7 80 percent of those transformers would be machine tool 

18 control type transformers. They'd be part of another 

19 . piece of equipment. They wouldn'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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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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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 the voltage levels. That f s 

15 always been a little confusing to me. In the lower 

16 voltage class, transformer manufacturers rate those 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 

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insulation class when they talk about low voltage,, and

then they talk about operating voltage classes when

they go to medium voltage.

It's not an important issue , but it is

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

Do you want to comment on that?

MR. PATTERSON:. I'll- comment. Wes

Patterson, ABB. .

Within. the design industry of these

products, 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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1 insulation class when they talk about low voltage,' 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 Wi thin'. the design industry of these 

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

11 . between a 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 typically covered everything that was greater than 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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Then we would size the lightning arresters

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

standards were built around the system class , but the

actual specific voltage, operating voltage was

anywhere from the one class to the next class.

MR. BALDUCCI: Thank you.

I'd like to ask again if we have any

questions or comments or clarifications with regard to

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

concerns aren't expressed , please do submit those in

writing, and again, we will determine. the comment

period closure at the end. of the workshop.

How's everyone feel?* Are we ready to take

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

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

10:40?

'(Whereupon, the foregoing matter went off

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

the record at 10:44 a.m.)

MR. BALDUCCI: If everyone would like.to

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

about 30 seconds.

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1 Then we would size the lightning arresters 

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 or comments or clarifications with regard to 

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 matter went 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. 

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I hope everyone had a nice break and found

the coffee and doughnuts and everything else okay.

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

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

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

I'm told you will lead that discussion:

Hold on one second.

MR. HOPKINSON:: Anthony,. unfinished

business. Could ;I mention something more on

fractional kVAs?.

An area that occurred to me while. I was in

the break was,the question of the cost of testing of

small kVA products, -and frankly, the testing cost for

fractional kVA transformers can take on higher than

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

therefore, both for the application, as well as the

difficulty in testing, that there is another rationale

for why those products should be excluded.

MR. BALDUCCI: Thank you, Phil.

MR. PETERSONS: Well, we are now at the

third topic,, sampling, and Kathi sort of gave me

22 II orders to start to carry the thing myself.

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1 I hope everyone had a nice break and 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 occurred to me 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:] difficulty in testing , that there is another rationale 

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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(Laughter.)

MR. PETERSONS: Well, sampling really has

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

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

offering two plans for consideration.

Some of you NEMA 'people may recall that

"about three years ago I mentioned a sampling plan, a

very tough one, - where 95 percent of the population

should pass with a 95 percent confidence limit.

Then I got some informal feedback. The

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

.Transformer Committee meeting in Vermont, then I said.

the mean should pass, again, with an extremely high

confidence level.

Right now things are even more relaxed,

and maybe four years ago when I started this project

I was a brash, 62 year young man --

(Laughter.)

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

mature 66 year old.

(Laughter.)

MR. PETERSONS: So more realistic.

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1 (Laughter. ) 

.2 MR. PETERSONS: Well, sampling really has 

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 in Vermont, . 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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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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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 very much 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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sample or lower confidence limit of the estimated

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

based on six percent loss tolerance as in ANSI

standards, so to translate it into efficiency

tolerance.

Criteria for compliance is that

represented value. as obtained here should be equal or

higher than the mandated value or really the value on

the minimum efficiency in the standard.

Now, statistical methods and sample size.

The wording is very general, really not specified. It

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

tell whether you should use T test', Z test, and I

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

your product and certain flexibility can be allowed.

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

the tests for determining confidence limits, you

select your sample size , measure losses , compute

efficiency or continue working with losses, and then

compute your statistical parameters , X bar, which is

mean standard deviation, which is in text denoted by

capital S; standard error of the sample, which in

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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 value as obtained here 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 is very general, really not specified. It 

12 doesn I t 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 

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

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And having done this test, the represented

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

2 ,parenth~ses X, and then lower confidence limit. 

3 'And having done this test, the represented ' 

4 , value for cO,mpliance. 

5 Now I shall go to just show some 

6 distribution curves. Let's ,say your entire population 

7 for the basic model' is represented by 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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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.

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

2 mandated efficiency . 

. 3 Well, in both cases - - 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 sample you were less lucky and 

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 we Ire 

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

20 mandated efficiency. It ~ould be a rated efficiency. 

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MR. BALDUCCI: Thank you.

MR. PETERSONS: All right. Well, there is

a possibility even with this population, quite a high

probability or reasonable probability to fail, and if

you do operate exactly at the rated efficiency, the

best what you can achieve for demonstrating compliance

would be 50 percent.

So obviously if you do operate at the.

rated efficiency, you will not risk, failing your

production run, where you only have. 50 percent of

probability of demonstrating your compliance. You

would. try to move your production higher than this

rated efficiency. .

Well, here is a chart, sort of family of

curves which are not available in your handout. The

.reason they are not available 'in your handout, it is

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

we do need full editorial approval at NIST before we

can really publish.

I'm using these charts here just to

illustrate the operating characteristics, really the

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

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1 MR. BALDUCCI: Thank you. '. 

2 MR., PETERSONS: All right. Well, there is 

3 a possibility even with this population, quite a high 

4 probability or reasonable probability to fail, and if 

5 you do operate exactly at the rated efficiency, the 

6 best what you can achieve for demonstrating compliance 

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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of final thing that will be used or final thing that

'will be proposed.

Well, here on this scale here, we have

loss percent, and this is the normalized losses. A

hundred percent loss would be, if the losses are for

the rated efficiency. If your efficiency is higher,

your losses go lower. ,

Another way around, they go higher in

other direction, and along this axis here we have

standard deviation of your manufacturing process.

So if you work exactly at the rated

efficiency here at the lower standard deviations you

have 50 percent probability for passing, but if you go

to higher standard deviations, this 50 percent curve

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

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

losses, corresponding losses, it really should have

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

would be straight curve up to here and then would

start swinging away.

Well, I don't think a 50 percent

probability of passing would be good enough. You

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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 probability for 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. 

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Well, I don't think a 50 percent 

probability of passing would be· good enough. You 

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would probably move somewhere to 95 or 99 percent,

which would require moving or reducing your losses,

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

.or three percent.

So you would have to absorb all this other

statistical uncertainty.

If you go to higher standard deviation,

obviously your over design would have to be larger,

well, around eight percent, but if this one is

correct, it's only about six percent.

So there is this type of penalty, and if

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

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

higher.

Reading back in Federal Register when this

was originally proposed 20 years ago, I sort of have

the sense that industry, appliance industry, liked

this plan. It allowed using very small sample, sample

of two. The testing of appliances apparently is very

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

not against also on this over design because the

rationale seemed to be that this would improve

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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 So you would have 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 of penal.ty would be even 

. 14 higher . 

15 . . Rea~ingback in Federal Register when this 

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

17 tI;.e sense that industry, appliance industry, liked 

18 this .plan. It allowed us: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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customer satisfaction.

But this was proposed also in NOPR for

motors, and there were some objections to this one.

Now we go to' method two, which is based on

statistical T test.- In addition to that, requirement

for minimum sample size.

Criteria for compliance, there are two,

namely, that mean of the sample should be higher than

rated efficiency minus this factor here, which was

used also in lower confidence level, and N-should be

five or higher value depending on standard deviation

of the process.

Steps in implementation. This is very

.simplified. It is not as formidable as it may look

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

again, go through determining the statistical

parameters, and then determine the adequacy of sample

size.

I should say the parameters for

determining sample size will be,selected so that when

your standard deviation is really the industry norm,

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

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1 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 based on 

. .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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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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1 test for compliance. 

. . 

2 We are back again to these distribution 

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

4' confidence limit .. Here is your rated effie:iency; and 

5 you subtract from rated efficiency tllis 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 X bar 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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would probably move your operating point somewhere

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

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

losses by two percent , whereas in previous case, you

had to decrease your losses by about four percent.

So this is more favorable for producer

comparison to other plan where producer had to absorb.

all the risks due to statistical uncertainty . In this

plan, 'they would be sort of split between producer and.

consumer.

How these plans are, well, set for final

document -really depends from various factors: sample

size and what really is a' standard deviation in

industry for typical process.

I'd like to sort of summarize the two

methods. The first one, very simple, allows you

flexibility also. Obviously. high assurance. of meeting

EPCA requirements, and of course, determination

assurance increases with the sample size'.

One very, important advantage for

transformer application, this method is consistent

with IEEE/ANSI standards where the loss tolerances are

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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 statistical uncertainty. In this 

9 plan, : they would be sort of split between producer 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 flexibility also. Obviously high 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 standards where the loss tolerances are 

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given.

The disadvantages, well, is higher burden

on producers. Statistical methods, well, the way you

do this adjustment •by divisor factor, they are not'

readily available, not unless you have these operating

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

the result.

For method two, well, statistics is

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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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1 given. 

2 The disadvantage~, well, is higher burden 

3 on producers. Statistical methods, well, the way you 

4 do thi'sadjustmentby divisor factor, they are not' 

5 readily availab~e, not unless YOll have these operating 

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, balancing producer and consumer risks just by 

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 explain this 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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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 .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 really fine tune these things 

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

7 : general comments on the two plans as perceived by you . 

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

2 befQre DOE should proceed. 

3 MR. BALDUCCI: Thank you, Oskars. 

4 MR. HOPKINSON: Phil Hopkinson from Square 

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

test'.

The result is that it puts in unreasonable

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

2 test. 

3 . The result is that it puts in unreasonable 

4 restraint .on the product and suggests that the product 

5 has to be fundamentally designed to be much more 

6 . efficient for guaranteeing that the end result of that 

7 whole population will meet the standard. 

8 And it·doesn't apply. Transformers are 

9 tested more regularly, more routinely in production by 

10 all manufacturers today, andthe:r;efore, sampling plan 

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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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

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

" 

2 several confidence levels to be 'explored and the 

3 possibility that, there may be 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 also with the DOE'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 in the TP-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 load loss 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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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 and the load loss would nominally be 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 in writing 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 manufacturer has a responsibility to insure compliance 

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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might help in giving some better clarification. This

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

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

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

type transformer, and that transformer, carried an

efficiency level from TP-1 of 98 percent.

So as it turned in the samples, we assumed

five samples were drawn. You can see the five right

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

performance level of 97.93 percent efficiency and a

standard deviation of 4.6 or 4.7 percent, a standard

error of two percent.

This K factor is really a T factor that

goes along. with a 90 percent confidence level, and a

calculated number of samples based on what worked out

to be a low standard deviation of less than one.

So in this particular case , a lower

control limit was calculated of 97.967. If we compare

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

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

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

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

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1 might help in giving some better clarification. 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 So as it turned in the 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 level i and a 

lS calculated number 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 calculated of 97.967. If we compare 

19 that nuInber to the mean of the sample that we tested, 

20 we' see I 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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percent confidence level. So the only thing that is

changed is the two numbers, the calculation of the N

and the calculation of the lower control limit,

And you can see that as the confidence

level rises, there is a requirement to test more

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

more favorable to the manufacturer.

Well, we will sharpen those calculations

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

is that as the confidence level rises, the lower

control limit to the manufacturer gets more favorable,

allowing a bigger. population to pass.

Now, since in each of the three cases,

even at 97 and a half percent efficiency assumed, none

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

select another sample.

So we said that in this sample, it just

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

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

our core loss tested a little better, and the result

is now when we tested the five samples, they happened

to be above 98 percent.

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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 control limit to the manufacturer gets more favorable, 

12 allowing a bigger population to pass. 

13 Now, since in each of the three cases, 

14 even at 97 and 'a half percent efficiency assumed, 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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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

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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 it would have required still more 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 straddled the '98 percent efficiency level 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 

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will have. to get specific standard deviations of

populations to sharpen that assumption-of 95 percent

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

the sum of the first two populations. Remember the

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

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1 will have to get specific standard deviations of '. 

2 populations to sharpen that assumption 'of 95 percent 

3asthe'operating point, but in the case 'four, we took 

4 the sum of the first two populations. Remember the 

5 second one passed; the fi:r;st one did not 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 for different types of transformers, i't will 

15 sharpen our thinking on the conf idence 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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MR. KLINE: I'm Don Kline of Southern

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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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1 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 traps formers of the same nominal kVA rating into 

13 one population, normally using efficiency as a mea~.ure 

14 for normalized losses. 

15 MR. BALDUCCI: Does that answer your 

16 question with regards to that or clarifying -- this is 

17 Anthony Balducci -..,would a clarifying point to that? 

18 . If, for instance I learned this 

19 yesterday is that there's a lot of specialty 

20 transformers made, where yo~ may make one of a certain 

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

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

3 transformers so that you have this basic model is 

4 basically all 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 it up 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 possibility that 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 in Oskars' that this sampling 

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plan really addresses that because it talks about

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

in the basic model.

I' d be interested in, one,' knowing whether

or not the situation exists where there are individual

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

those units?

MR. PATTERSON: Wes Patterson, ABB.

The first comment I had, I think it

pertains to everything we've been discussing.

The two methods that are proposed, there's

really a third method, and the third method is where

the manufacturer does 100 percent testing of every

product, and in our industry there are segments of the

industry where 100 percent of the product is tested.

If you,.-re doing 100 percent testing, then

there's no criteria for sampling. Sampling only

implies that I'm not 100 percent testing.

So there"needs to be a third method that

incorporated where I did 100 percent testing.

Now, if I have a model definition of one,

22 11 and I test one, I did 100 percent testing. I'm

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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'd be il1terested ~n, one,' knowing whether 

5 or not. the situation exists where 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 two methods that are proposed, 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,' and in 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 there I s 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 one i I did 100 percent testing. I'm 

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immediately in compliance with method number three,

which is not in the document. Okay?

So the document has to incorporate some

methodology to* handle 100 percent testing of the

product.

MR. KLINE: My question hasn't been

answered.

MR. STRICKLETT: I have a quick question

about the interpretation of the. standards. I took

these standards, I believe --

MR. BALDUCCI: Ken Stricklett.

MR. STRICKLETT: Yeah. Sorry. Ken

Stricklett from NIST.

And I'm learning about the -- trying to

understand the industry practice. So if.there could

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

The IEEE standards, both the 57.00 and

57.01, have the tolerance specified in those standards

for the losses, and that includes samples of --

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

and samples larger than two.

Now, by putting a tolerance on the losses,

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1 immediately in compliance with method number three", " ' 

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. STRI CKLETT; 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 standards I both the 57. 00 a.nd 

18 57.01, have the tolerance specified in 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, by putting a tolerance on the losses, 

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'that. effectively provides a sampling plan, and has

that been, discussed by NEMA as a control mechanism for

quality control, and is that IEEE tolerance protocol

followed by industry currently?

I guess those are.my questions.

MR. BALDUCCI: Phil, before you answer

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

and this goes back to Wes ' comment about 100 percent

testing.

When you test -- for instance, you say you

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

say, ten transformers that are identical and you test

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

you rate those individually or do. you rate those as a

family of ten?.

That's. mine.

MR. PATTERSON: The units in IEEE beyond

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

,percent of the products.

MR. BALDUCCI: Okay.

MR. PATTERSON: By standards. ••. Those

products, if there were ten units being manufactured

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1 that. effectively provides a sampling plan, and has 

2 that been'discussed by NEMA as a control mechanism for 

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 When you test -- for instance, you say you 

11 test 100 percent of your 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 certain class 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 

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that were virtually identical, are still looked at as

though they were one unit.

MR. BALDUCCI:. Okay.

MR,. PATTERSON: Phil's going to address

this probability , this six percent / ten percent limit

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

to him.

MS. EPPING : Kathy Epping.

Do I correctly understand you that you're

saying that. each one gets an individual rating?

MR. PATTERSON: Each one gets an

individual rating.. Now, the commercial issue of if a

unit is beyond the guaranteed losses, the guaranteed

losses, how that is handled commercially is where this

percentage comes into in the standards.

MR. HOPKINSON:. Thank you, Wes.

I'm Phil Hopkinson ;from Square D.

The issues that Mr.•Stricklett raised are

interesting ones; and we have addressed those in IEEE,

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

right now.

Going back over the years, the IEEE

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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/ten percent limit 

'6 atldwhat it means to the industry. So I'll defer that 

7 to him. 

8 MS. ·EPPING: Kathy Epping. 

9 Do I correctly understand 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 is handled commercially is where this 

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 interesting ones,· and we have addressed those 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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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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1 standards for six percent loss tolerance on total loss 

2 and ten percent loss tolerance on no load loss were 

! 

3 set up as the 'presumptions for performance by a 

4 manufacturer to guarantees of losses that were made to 

5 a customer between a producer and a buyer of the 

6 product. 

7 If a transformer would exceed the no load 

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

9 get thrown away, but it did require some financial 

1.0 1;ransaction between the manufacturer and the purchaser 

11 of the equipment. 

12 'Well, then they raised the question of, 

13 well, okay, what abOl.;jt the nominal 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. Some viewed 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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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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1 transactions between manufacturers 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 and any requirement 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 indus try today. It really needs to be rewritten 

15 altogethe'r." 

16 And, in fact, that I s what I s going on right 

·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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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 times f but I do think that var.:j.ability of ten percent, 

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 to what th:e standard deviations 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, and a;; 

, 9 we sharpen up those numbers for the different types of 

iO construction, then we'll have an ability to shc;rpen 

11 what should be the statistical means and cutoff 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 to Mr. 

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 add a little clarification to what 

22 Phil tal,ked, about on ,the ten' percent/six percent 

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tolerances, the basic IEEE standard that is out for

ballot right now retains the ten percent tolerance on

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

applies to the individual unit. All reference to

multiple units, shipments,. orders has been dropped.

The feeling was from the IEEE perspective,

was that those tolerances there were to deal with

manufacturing variability of a single unit, and that

any dialogue on groups of units were really commercial

considerations between the user and the producer, and

as Phil quite appropriately pointed out, the ten

percent/six percent limit. is not an absolute limit.

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

producer.

So that's where that standard is headed.

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

retained, then the multi-unit requirements will be

dropped from the ANSI standard.

MR. BALDUCCI: Do we have any other

further questions or comments regarding this issue?

Clarifications?

Why don't we then press on to the next

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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 feeling was from the IEEE perspective, 

7 was that those tolerances there were to deal with 

8· manufacturing variability of a single unit, and that 

9 any dialogue on groups 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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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.

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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, and NEMA TP-1' uses transformer efficiency 

5 at specified loading levels as the measure of energy 

6 consumption. 

7 DOE at this time believes 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 only be significant with respect to the calculations. 

14 All measurements, corrections, conversion 1:0 reference' 

15 ,temperatures ~ndproc~ssing of statistical analysis 

16 will be performed using loss data; 

1 7 So we'd 1 ike to know if there are' any 

18 strong reasons why efficiency should not be used, and 

19 if any other measures of energy cOIlsumpt'ion' should be 

20 considered, such as loss power normalized, and whether 

21 or not reporting efficiency losses at reduced loading 

22 levels would be the way to go. 

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1 So I'll let NEMA speak now.

MR. BORST:' John Borst, ABB, representing

3 NEMA.

Since transformer. losses include both

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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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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:Jim Bohlk, RUB in Washington. 

21 Not in particular to that, but the general 

22 question of measurements of efficiency. I do believe 

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that efficiencies are a'very good number and very

useful number, especially for labeling.

However, I don't really see a practical

application as we like it to be used. RUS presently

advocates that their borrowers purchaser transformers

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

owning cost , if you will, as published and explained

very nicely in the October 22nd Federal Register

notice.

it is important then that. manufacturers

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

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

is the basis of the purchase.

Again,. I think this is very important.

RUS advocates ' the use. of this methodology. We will

continue,to advocate the use of this methodology, and

we don't really particularly see a useful application

for what we're looking at for publishing efficiencies.

MR. BALDUCCI: Other comments or questions

regarding the energy consumption measurement where DOE

.is proposing using efficiency?

MR. HOPKINSON: Phil Hopkinson, Square D.

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+ 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 their borrowers purchaser.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 really particularly see a useful application 

18 for what we I re looking at for publishing efficiencies. 

19 MR. BALDUCCI: Other comments 'or questions 

20 regarding the energy consumption measurement where DOE 

21 . is proposi~g using efficien~y? 

22. 

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Reporting at this time just to the-issue

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

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

a NEMA organization addressed the question of whether

we.would go for specific watt loss levels or try to

get something that was a more general term, like

efficiency.

Well, there were a lot of factors of

consideration. One of them was the fact that there

are many types of manufacturer of transformers. There

are transformers that are core type, which means two

coils, one core. There are transformers that are

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

phase.

There are transformers that use stacked

core. There are transformers that use wound core.

There are transformers that have various kinds of

windings, disk windings and layer windings and others.

And out of that, the concern that we had

was we wanted a parameter that would tell the end user

the 'performance that he would expect to get at the

nominal usage level of the transformer, but we wanted

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1 Reporting at this time just to the ,issue .' 

2 raised about A&B factors and no 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 are many types of manufacturer of transformers. There' 

, 11 are trapsformers that are core type, which means two 

12 coils, one core. There are transformers that are 

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

14 phase. 

15 There are transformers that use stacked 

16 

17 ' 

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19 

, 20 

21 

22 

core. There are transformers that use wound core. 

There are transformers' that have various kinds of 

windings, disk windings and layer windi~gs and others. 

And out of that, the concern that ~e had 

was we wanted a parameter that would tell the end user 

the performance that he would expect to get at ~he 

nominal usage level of the transformer, but we wanted 

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that to be not a discriminatory clause that would

unduly put certain types of manufacturers or types of

constructions under pressure, competitive pressure,

which would make them no longer salable in, the

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

-So efficiency became the very best measure

that would do that because it does communicate what

the transformer would expect. to be delivering in total

watts loss consumed at the nominal usage level.

And in determining efficiency, in the work

that we did in NEMA to develop TP-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.

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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 ,So efficiency became the very best measure 

~ that would do that because it does communicate what 

8 . the transformer wou,ld expect. to be deii vering in total 

9 watts loss consumed at the nominal usage level. 

10 And in determining ·efficiency, in the work 

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 industry usage 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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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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1 MR. BALDUCCI: Thank you very much, Phil. .. 

. 2 MR. LEVY: This is Ed Levy from DOE 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 Any further questions, 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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next one, which is the burden imposed by industry by

additional testing and data processing. Why don't we

try and go through that?

MS. EPPING: We've gotten from various

sources that there's some concern expressed over

significant burden to particularly small manufacturers

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

know from.you what anticipated difficulties you see,

and we'd like some suggestions on solutions. to

addressing these difficulties.

And we'd also like to know what specific

requirements in the draft test procedure document are

causing these difficulties.

MR. GAUTHIER: John Gauthier from,NEMA.

NEMA's position is basically compared to

current practices, the imposition of this mandatory

requirement contained in any DOE regulation will

result in-increased burdens for manufacturers large

and small.

Additional equipment may be required.to

comply with the mandates of this regulation. The

effort will be directed toward meeting 'the three"

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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 significant bUl;,den to particularly small manufacturers 

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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percent test 'tolerance for loss measurements.

Approximately 200. distribution manufacturers, both

liquid and dry type, must up grade their testing

equipment.

New measuring equipment is available. that*

will meet the specification -- is available. It is

hoped that NIST will provide the small manufacturers,

guidance on the changes necessary.

Our experience in other areas involving

mandatory regulation has been that reporting is

increased and record keeping poses an additional

burden.

Additionally, NEMA recognizes the need to

address the following burdens: need to meet both old

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

test requirements identified in an old version of the

standard that has been superseded.

Two, labeling requirements.

Three, third party certification

accreditation.

MR. BALDUCCI: I do have -- this is

Anthony Balducci again I do have a specific

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

16 test requirements identified in an old version 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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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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1 question regarding - - and this goes back 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 the manufacturers, 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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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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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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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 create just 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 demand different degrees of testing, dif;erent amotints 

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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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

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1 of looking at the game. 

.2 MR. MOREHART: Gene Morehart, Acme 

3 Electric. 

4· The answer to your question, right now 601 

5 volt, transformers below 500 kVA do not require any 

6 loss measurements by industry standards. As a matter 

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

8 line of transformers is· not even included in those 

9 standards. 

10 , 'So that's another reason why it will be 

11 . necessary to put ST20 in 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 unfairly that you're preferring - - giving preferential' 

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

19 PARTICIPANT: What's your question? 

20 MS. EPPING: If we have different testing 

21 requirements for both the liquid and the dry 

22 transformers, would that create any sort of problem 

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that people who manufacture liquid transformers or dry

transformers would think that we were -- there , were

less stringent requirements on the other group?

Does that make sense?

MR. McCABE: This is Michael McCabe.

Let me 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

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1 that people who manufacture liquid transformers or dry 

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,add to it. Assuming that they 

7 are both the notice says where they are going 

8 towards the same market. Would that gi ve 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 establishing the 

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

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 it I 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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market?

On this particular question, the question

was: are there burdens on the industry? Can we

identify burdens on the industry?

All we're trying to do is state there is

a distinct burden on the industry by the requirements

for the accuracy of the measurement which is now

different than what is out there in the marketplace

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

there.

MR. LEVY: Do you think that we should try

and replicate what's in the marketplace with regard to

the accuracy of measurement? ,

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

my opinion, my opinion is that the industry.has been

quite good 'at policing itself in respect to efficiency

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

government coming in and telling us what the industry

has been doing all along is buying us anything.

That's my own personal opinion. Okay?,

MR. BALDUCCI: Hold on one second.

MR. PETERSONS: Could I respond on, well,

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1 market? 

2 . On this particular question, 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 industry by 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 with regard to 

13 the accuracy of measurement? 

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

15 my opinion, my opinion is that the industry.has been 

16 quite good 'at policing itself in respect 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 

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my concern on accuracy situations in the measurement

of dry type transformers?

There was no accuracy requirement at all

for measuring losses of dry type transformers. if

there is no accuracy requirement, measurement by

itself is an undefined sort of operation. You can be

15 percent out.. It would be very difficult to

enforce.

So I pushed very strongly in working

groups to introduce similar table also, accuracy

table, for dry types. My understanding is that the

next division this is or will be accepted nearly as

for liquids, except for temperature measurement, and

there is apparently one negative vote.

So primarily I was pushing that there is

some accuracy for dry type measurements.. To me loss

measurements in dry or liquid type situation I don't

think is any more burdensome accuracy-wise.

MR. ROLLING: Dave Rolling from Cooper

Power Systems.

Two quick comments. First; I believe here

would be some concerns if you would make different

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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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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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'1 testing requirements for different types of products, 

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 it t S a 

6 discussion for this meeting t 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'd expand upon that just 

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

speak , but people get ideas as a result of

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

that, too, you know, responses or amplifications,

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

the purpose of having the written comment, is to give

people an opportunity to -follow up on what's said

here.

MR. BALDUCCI: Thank you very much.

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Yeah, and I'd like to reiterate that.

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

home tonight and have a revelation about the way we

should do something a little bit different, feel free

to write us and tell us.

Again, as we discussed earlier, if you

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

Any other questions or comments? How does

everyone feel about taking a one hour break for lunch

about now?

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

meet back here at five of one?

Again, the cafeteria is in the West

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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 know I 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 Any other questions or comments? 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 

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

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

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

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

vendors selling hotdogs, as well.

(Laughter.)

MR. BALDUCCI: See you in one hour.

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

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

same day.)-

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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.) , 

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

(1:01 p.m.)

MR. BALDUCCI: Welcome back; everyone. I

guess we can get back into it.

Before we go on to the next topic, there

was a request from the gentleman from Canada. Dave

wanted to talk about with regard to the measurement of

energy consumption and.what they have'found'at CSA.

MR. WIEGAND: Thanks, Anthony.

Just, a very few --

MR. BALDUCCI: Could you give for the

record your name?

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

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

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

.(Laughter.)

MR. WIEGAND: So people there, some of

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

Okay. So I was actively involved in the

CSA C802 standard that got developed in Canada in 1994

on maximum losses for transformers, and I just wanted

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

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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 wi th 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 standard that 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'm finding here with 

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studying the losses from the C802 standard, which are

maximum losses, and how they compare with NEMA losses

when they are put into a 50 percent loading situation.

I've done some spreadsheet calculations

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

would be pleased to send copies'to anyone interested,

but the relationship is very, very close both for

liquid filled transformers and dry type.

In fact, -it makes-me wonder, well, the

people that drew up the NEMA losses, were they looking

at our standard for maximum losses, but anyway, why

did we pick maximum losses instead of efficiency when

the pursuit'in itself was for greater efficiency in

transformers?

It was largely related to the commercial

aspect of the transformer business that we were in.

We were dealing mainly with electric utilities when it

came to transformer losses, and so the electric

utilities were purchasing on the basis of total

ownership cost.

So it seemed rather natural since they

were all looking very closely at no load and load

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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 drew up the NEMA losses, were they looking 

11 at our standard for maximum losses, but anyWay, why 

12 did we pick maximum losses instead of efficiency when 

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 mainly with electric utilities whEm 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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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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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 99 percent'. 

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, and now under the influence of loss evaluation 

17 ,formul'asand the like, that no load loss is' more down. 

18 around 220 watts or thereabouts, and similarly when 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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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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1 it's cast in stone, and having done the analysis of 

2 comparing·these C802 losses converted into'efficiency 

3 at 50 percent load, comparing it with the NEMA 

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

" 

5 I was to make some corrections to compare apples with 

6 apples. 

7 So I just wanted to indicate that I will 

8 be going back to Canada and casting a 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 with you. 

22 

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MR. GAUTHIER: Is that okay, guys?

,(Laughter.)

MR. BALDUCCI: Great. Harmony is

wonderful.

Now we're going to. go into the toughest

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

and hopefully everyone can remain awake for the next

three topics.

The next one is the reference

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

thinking ambient temperatures, which I know is

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

Kathi and let her talk about that.

Thank you.

MS. EPPING: The reference temperature

stated in the cited- documents- are somewhat

inconsistent with respect to reference temperature.

What we're considering is specifying -- that looks

better specifying .a 20 degree temperature for no

load for both dry transformers and liquid immersed..

We're also at this point favoring using a

single reference temperature of 75 'degrees for no load

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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 single reference temperature of 75 ~degrees for no load 

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

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

the. liquid immersed.

So we would like your comments on these

reference temperatures, if you think that they're'

reasonable or-not.

MR. COULSON: Lake Coulson with NEMA.

NEMA's position on this, 'specifying a

reference temperature of 20 degrees Celsius for no

load losses, is considered appropriate by NEMA.. It is

anticipated that C57.12 and C57.12.01 will be'

harmonized to that value in the future.

NEMA is in - agreement with reduced

reference temperatures .for load loss, 'but has no

comment on the specific values proposed at this time.

MR. HOPKINSON: Phil Hopkinson, Square D.

Just following up on Lake's comments on

reference temperatures, for liquid and for.dry as a

company position for Square D and not for NEMA, then

it is our belief that 75 degrees'represents the load

loss reference temperature for medium voltage dry type

transformers.

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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 by J:\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 for medium voltage dry type 

22 transformers. 

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We believe that 55 degrees C. represents

the reference temperature for liquid filled.

transformers. We believe that 55 degrees also

represents the reference temperature for a low voltage

dry transformers.

Just to give a little more background, the

low voltage dry type transformers, when we thought

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

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

we had been using a higher loading assumption on low

voltage dry type transformers up to the point of

establishing, the tables,. and it was- after we collected

some data showing the kinds of loads that exist on

those transformers, that we realized at a later time in

the evolution of that standard that 50 percent load

was not appropriate' for low voltage dries that a lower

-- loading presumption prevailed, and that 35 percent

load was most. representative.

However, we failed to.go back and change

the reference temperature -for the document so that

that one actually sits up therea little high. Okay?

MR. ROLLING : Dave Rolling, Cooper Power

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1 We believe that 55 degrees C. represents 

2 the reference temperature for liquid filled 

3 transformers. We believe that 55 degrees also 

4 represents the refer.ence te~perature for a low voltage 

5 dry transformers. 

6 Just to give a little more background, the 

7 low voltage dry type transform~rs I when we thought 

8 back as t;:.o what happened and why we, got to 75 degrees I 

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'the tables, and it was after we collected 

13 some data showing the kinds of loads that exist on 

14 those transformers, that we realized at a later time in 

15 the evolution of that standard that 50 percent' load 

16 was not appropriate for low voltage dries that a lower 

17 -~ loading presumption prevailed, 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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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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~ Systems t 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 and the correction that is 

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required for liquid immersed transformers, but it's

not applied to the dry type.

DOE believes at this time that the.

corrections should be applied to both types of

transformers using an algorithm and C57.12.90, as well

as the guidance describing when the correction should

be applied.

Similarly, the department is inclined at

this point to propose no load losses of dry type

transformers be corrected to a reference temperature

of 20 degrees if it' s measured at, a temperature

significantly different.

And we would like your comments on whether

these corrections are appropriate, and if it's

appropriate to apply the corrections used for the.

liquid to the dry type transformers.

MR. HOPKINSON: Phil Hopkinson , Square D,

speaking for NEMA.

Corrections for low power factor

measurements may be necessary for both liquid filled

and dry type transformers .. TP-2 provides a

.22 II methodology in Section 4.1.4. Generally speaking, the

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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 using an algorithm and C57 .12.90, as well 

6 as the guidance describing when the corre9tion should 

7 be applied. 

8 Similarly I 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 And we would like your comments on whether 

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 methodology in Section 4.1.4. Generally speaking, the 

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highest power ratings with the highest impedances will

have the lowest load loss power factors.

A TP-1 compliant 2,500 kVA dry type

transformer at eight percent impedance will have a

load loss power factor of about nine percent, as

measured, while a liquid filled transformer of the

same rating that also meeting TP-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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1 highest power ratings with the highest 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 cases power factor corrections would be needed .if 

12 total test error exceeds one minute. 

13 No corrections are necessary for no load 

14 loss, for core 'loss, in other words, 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 shared with NEMA before I but it just dawned on 

21 me. 

22 MR. BALDUCCI: That.' s fine. 

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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,

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

23 ought to be abie to know ambient temperature within 

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

15 If there is situation where your ambient 

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

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

,2 standard, that basically if you 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 clearly correct". 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: In the dry world, 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 .wi th the no. load loss 

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measurement is as the temperature goes up, the losses

are higher, correct?

PARTICIPANTS: Are lower.

MR. PATTERSON.: Are lower, are lower.

And when the unit comes out of this oven,

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

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

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

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

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

you. measure its temperature.

And then the question becomes where do you.

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

top . temperature, the bottom temperature, side

temperature? Can you get underneath the coals? How

do you establish what its temperature is given this

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

and then absorb it?

And then if you do, that goes back to the

burdens on the manufacturers. That's going to

increase our carrying cost.

MR. BORST: John Borst, ABB.

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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 hours i 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 then the question becomes where do you. 

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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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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1 Wes' points are absolutel~correct. The 

2 standards' process, we deliberately-left that somewhat 

. 3 ambiguous because I . again, the correction is ~ sT\1all, and 

4 we've left it to the manufacturer to determine 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 time or 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 option obviously, but most people have B.ome sort of an 

17 algorithm in place that allows them to estimate the 

18. temperature at the time of test, and tha.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 going to have to develop some defensible 

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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.

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1 algorithm. 

2 MR. PATTERSON: This is just illustrating 

3 the differences, again, between the dries and the 

4 liquids. When the dry is operating, in the 

5 operational mode even. on an 80 degree C. rise 

6 transformer, this transformer core is going. to be 

7 upwards of 120 degrees C. in 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 customized business where you" re building one 

21, and the variety is changing dramatically in scope from 

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

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This is just illustrating the differences

that we have in these processes, in this product

scope.

MR. BALDUCCI: Further questions or

clarifications?

Wes, in your comments, I would hope that

you would address not only this problem, but a

suggestion for 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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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 suggestion for a' solution to how 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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MR. HOPKINSON : Well, Phil Hopkinson from

Square D.

I certainly can 'agree that the core is

going to be,operating pretty much as Wes indicated.

So if 'the intention all the way around is to get

losses as the transformer is to be. used, then truly.

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

reference temperature than 20 degrees C. for, core

loss.

And that will result in somewhere between

four and' five percent lower losses of core at the

operating temperature , than it would at the 20 degrees

C.

MR. BALDUCCI: I'm thoroughly confused,

and that probably means we've beaten this one pretty

good. Any other questions or comments with that?

Oskars.

MR. PETERSONS: Well, apparently for

liquid immersed transformers this has been a decade

long debate, what should be the reference -temperature,

and I' m sure some of these arguments were voiced

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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 long debate, what should be the referenc~ 'temperature, 

22 and I'm sure some of these arguments were voiced 

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

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

open, then we again have possible measurement

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

I mean 'how can you --, is it possible

really to standardize at this high a temperature? Do

we know the right temperature? Is it not possible,

really to measure that ambient after it is wound?, You

have 'to intimate and so on.

MR. BALDUCCI: Wes. Thank you.

MR. PATTERSON: For the-purpose of this

meeting, I just think the point was to illustrate the

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

can have other dialogues to arrive at the solutions

that are needed.

MR. BALDUCCI: I have one question. This

may be out of sheer ignorance. You mentioned earlier,

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

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

would you know then the temperature of the core at

operating temperature?

MR. PATTERSON: There's a manufacturing

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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 may be 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? 

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

controlled, but they're not 'reflective of the

installed condition.

MR. BALDUCCI: Okay.

MR. PATTERSON: Now, when I put the unit

in service, we know through calculation exactly what

those temperatures will be in service, and our

manufacturing processes are typically running these

things at a lower level. Okay?

So we are always producing' a unit that is

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

what has been - happening is if we had a guarantee on

the no. load loss and we measured the thing and it

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

economic advantage to'tie it up in inventory. So we

would let it cool down. Okay?

But if it passed hot, okay.

PARTICIPANT:. The other way around.

MR. PATTERSON: The other way around.

MR. BORST: If you would know 'the

temperature, you could do a precise correction, and

then you might get -- •

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·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 So we 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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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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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 different is because liquid filled transformers became 

19 subj ect 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 

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measured at whatever temperature, and that was the

value.

But as the value of no load losses

increased to-higher levels, some manufacturers were

astute enough to figure out that you could manipulate

-- a poor choice of words --.

(Laughter.)

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

could come up with a 'different end result if you were

to take into account temperature, and that forced the

industry to address a standard correction method and

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

evolved in liquid filled and has not evolved to that

point in dry type, because loss evaluation has not

been as prominent in dry type.

MR. PETERSONS : A hypothetical --

MR. BORST: Historical.

MR. PETERSONS: -- for 35 percent loaded

dry type transformer, who would -prevent then operating

the transformer at full load for 24 hours and

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

22 !1 if you don't specify.

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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 could manipulate 

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 standard reference temperature, and so that's why 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 dry type transformer, who would .prevent then 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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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.

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

22 the 100 percent or the unloaded position. 

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MR..BALDUCCI: Thank you.

Any other further questions or comments

regarding this temperature correction?

(No response.)

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

our last topic, which is quality assurance.

MS. EPPING: C57.12.00 provides the table

of measurement uncertainty tolerances, and it's my

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

has a revision that's in the process of being

reviewed, -I understand, is considering using these

tolerances as well.

So at this time, DOE is considering using

these tolerances and make them applicable to both

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

just the dry type transformers, and we're considering

doing them for. the liquid as well.

So we'd like to -know if you 'have any

concerns about applying these measurement accuracy

requirements to the dry type transformers as it's now

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

including a clause from ISO 9001 for guidance to give

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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 understanding that 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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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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1 people who might want to know how they implement the 

2 requirements of 12.00. They could use the guidelines 

3 in ISO 9001 to implement these procedures. 

4 MR. KLINE: I'm Don Kline of Southern 

5 . Transformer Company. I.' m giving 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 Kathi mentioned', IEEE is in the process 

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 energy efficient -- 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 standard wil'l place a 

22 large responsibility on the manufacturer to certify 

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that the loss measurements meet the efficiency

requirements of any.efficiency standard that might be

adopted, such as NEMA TP-1.

Section 7 of TP-2 includes the testing

quality control requirements, and this indicates that

the test -- this specifies the test methods and the

record keeping.

Loss measurement in TP-2 for both liquid.

and dry type transformer specifies the loss

measurements shall •be within three. percent of the

total losses. At first blush, three percent sounds

like a wide margin.

However, this seems wide until you take

into account the lost test power factor, the power

factor of the actual test at the room temperature.

Take, for instance, a larger liquid filled transformer

or dry type transformer for higher impedance, just say

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

of load loss as measured by the test is only five

percent of the total kVA that the test set sees.

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

So the three percent requirement now

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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 quality control 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, 'for instance, a larger liquid filled transformer 

17 or dry type transformer for higher impedance, 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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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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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 low loss 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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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 So what 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 Southern Transformer 

~ 1 ' Company. 

22' I t;:.rust and urge that DOE sees fit to have 

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Oskars Petersons continue with his effort to aid all

transformer manufacturers in updating their equipment,

calibrating and updating their equipment to meet these

standards.

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

also a personal thanks.

MR. BALDUCCI: Thank you.

Any other questions regarding the quality

assurance and testing?

(No response.)

MR. BALDUCCI: According to our agenda,

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

else anyone wanted to talk about with regards to the

proposed test procedures or any of the issues we've

talked about today or any other issue with regard to

test procedures for transformers?

MR. 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 transformer manufacturers in updating their equipment, 

3 calibrating a~d updating their equipment to meet these 

4 standards. 

5 I'm putting 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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factors, but truly that isn't really what-drove the

.adoption of ten percent limits for core loss or six

percent for total loss.

The background on that 'I am absolutely

certain was relative. to thermal considerations and the

impact on life and the ability of the transformer to

provide long life to the end consumers, so that 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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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 certain was relative. to thermal considerations and the 

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 ten percent 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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started to be applied to liquid filled transformers,

then those same factors were continuing to be applied,

but applied now from an efficiency consideration, and

the question of acceptability from a loss performance,

did the manufacturer provide a transformer that met

-the, efficiency that the transformer was being

purchased to?

But really when those factors were

developed originally, it really was not anything to do

with efficiency. It was only the question of was the

transformer able to provide acceptable life.

MR. BALDUCCI: Any other questions or

concerns regarding transformer test procedures or

anything of the sort?

(No response.)

MR. BALDUCCI:.As I mentioned earlier in

the workshop, we wanted to determine, based on issues

that were brought to light here, other.issues that may

have sparked your interest or' other issues you may

think may spark your interest, a comment period and

how long that comment period should be in relation to

what was discussed here and the material that was

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1 started to be applied to liquid filled transformers, 

2 then those same factors, were continuing to be, applied, 

3 but applied now from an efficiency consideration, and 

4 the question of acceptability from a loss performance, 

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 developed originally, it really was not anything to 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 were brought 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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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 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. you disagree with the way the department 

14 has proposed something or is thinking of something in 

.15 their doc'!-lments, please provide us. with.a solution and 

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

17 defend any changes that we make. 

1~ If you just say, "Well, we think it 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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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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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 - - and part of my 

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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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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1 comment period and public hearing relating to the 

2 notice of-proposed rulemaking. 

3 What Kathi is talking about with regard to 

4 the comment period, she wants to have ample time to 

5 evaluate all of those comments because they need to be 

·6 answered and talked about in the notice of proposed 

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

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.think you 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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1 MS. EPPING: The proposed rulemaking.

MR. ROLLING: Proposed rulemaking. Thank

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,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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1 MS. EPPING: The proposed rulemaking. 

2 MR. ROLLING: Proposed rulemaking. 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 of your sense of how the commen·ts come back to yo. 

11 MS. EPPING: Right. 

12 MR. ROLLING: If the comm~nts come back to 

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. Hopefully this 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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I mean, if in the middle-.of this comment

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

some time in March, you have a question about exactly

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

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

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

interactive. We want to make sure that we're

.addressing your concerns and we're understanding your_

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

a, situation where we have a notice for proposed

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

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

startedSo 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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1 I mean, if in the middle'of this comment 

2 period, if we say the 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 ,addressing your conqerns and we're understanding your. 

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, with regards 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 really extensive fine' 

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tuning will have to be done, although we probably

already at this point perceive that we can come to

agreement. It would really be very good if Kathi and

I could meet with somebody, especially. those who

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

a small group. dedicated to a specific topic.

MR. ROLLING: Let me comment from a NEMA

standpoint on that, Oskars. I believe that the NEMA

organization would be certainly willing to do. that,

,and that meeting among NEMA members could be

coordinated through NEMA probably through Lake here,

and I think everybody would agree in NEMA that would

be appropriate.

MR..HOPKINSON: Phil Hopkinson, Square D.

Yes, I certainly reflect favorably on what

Dave just indicated on funneling through NEMA and

coordinating that way.

I also would raise issue on the'NOPR for

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

period to get people together from the standpoint of

vacations,. and so maybe some backward thinking as to

the plan and adequacy of time to respond that would

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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 really be very good if Kathi and 

4 I could meet with somebody, especially those who 

5 raised these arguments, that we could meet, 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 certainly reflect favorably on what 

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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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 coordinate around your time setting. 

2 MS. EPPING: Right. Thank you. 

MR .. BALDUCCI: One other thing that I, 

4 would like to stress in regard to the s'chedule, and it 

5 was brought: up yesterday a little bit and just to 

6 reiterate what NEMA stated today with 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 to that. 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 public hearing/workshop to discuss the NOPR and 

21 'decisions on why we're proposing certain things. 

22 So 45 days is about? 

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calculated.

as well.

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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'd just like to thank everybody, but also 

15 in talking about the comments and how we can work 

16 together in the meantime is to point 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 

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20 

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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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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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1 then than beforehand. 

2 ,But the spirit of the Administrative 

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

4 trying to get the input from all parties in deve,loping 

5 this proposed' ,rule. So while we may talk about 

6 working informally with -~ you know, sharing Oskars' 

7 and Kathi' s time, with you to answer questions anq. have 

8 a dialogue during this period prior 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 discussions i 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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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 identify issues, talk about 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,and we'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 with Oskars, 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. 

202/797-2525 

SA G CORP. 

Washington, D.C. Fax: 202/797-2525 
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MR: BALDUCCI: Thank you, Michael.

One thing I do ask of everyone before you

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

that I will pass out'now.

So I would like to thank everyone for

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

busy schedules, and I thank everyone for attending

today's workshop.

Again, we do appreciate your comments,

both verbal and written.

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

around and grab them.

(Pause in proceedings.)

MR. BALDUCCI: We stand adjourned.

MR. ROLLING: Before we do that, I,

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

folks who attended the workshop, want.to thank all the

folks' from DOE, Michael McCabe,. Anthony Balducci,

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

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

meeting was well. run, professionally run, and we

certainly appreciate participation.

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 .to thank 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. 

202/797-2525 

SA G CORP. 

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

MR. BALDUCCI: Thank you very much, Dave.

Why doesn`t everyone give themselves a

round of applause for a meeting well done today?

Thank you.

We stand adjourned now.

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

concluded.),

2021797-2525

S A G CORP.

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

1

171 

1 Thank you. 

2 MR. BAbDUCCI: Thank you very much, 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 the workshop was 

.8 concluded. ) , 

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202n97 -2525 

SA G CORP. 

Washington, D.C. Fax: 202n97-2525 
C 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

SAG, CORP.

4218 LENORE LANE, NW

WASHINGTON, D.C. 20008

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172 

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 

typewri ting·. 

(202) 797·2S2S 

SAG, CORP. 

4218 LENORE LANE, NW 

WASHINGTON, D.C. 20008 

VIDEO:TRANSCRDnnONS