Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 TO: Patrick Coleman Alabama Power Single Phase Harmonics Task Force IEEE PES/Transmission and Distribution Committee 7/10/00 From: Robert E. Gardinier Member, IEEE PES Member, U.S. Technical Advisory Group, IEC 77A Member, IEC 77A, WG1, TF1, TF1a, TF5a, TF5b Subject: Comments on the draft guide for harmonic limits. Reference: “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 1/28/00 Patrick, Per our email notes, please find attached comments in regard to the reference document. My comments are intended to be constructive and to assist with the development process. Please feel free to share these comments with anyone that has an interest in the development of this guide. I am looking forward to the discussion of this draft document at the PES meeting on Tuesday, 7/18/00 in Seattle. Regards, Bob Gardinier REG_P1495_Comments 02/12/16 1 R. E. Gardinier Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 Overall Comments The guide addresses products that represent future non-linear loads that will be attached to the public low voltage network, which may cause harmonic voltage compatibility levels to exceed some acceptable level. The object is to “arrive at a reasonable set of limits for single-phase equipment such that the likelihood of a problem caused by harmonics is small”. Participation by product manufacturers is essential to meeting these objectives and to arrive at a guide that will have the right balance to achieve the lowest cost to society at the same time it achieves the desired effect of protecting the public low voltage network. A rationale that justifies the need for limits at any level is currently missing from the document. The limits proposed in Section 7.6 of a maximumTHD of 15% for all products , with a maximum 3rd harmonic current of 10%, are totally unjustified and there is insufficient evidence given in this document, or can be found anywhere in the current literature, that supports such extreme limits. It would require that active power factor correction circuitry be added to most electronic equipment manufactured today in order to meet these limits. There is no justification for the need to impose this added cost burden on society, or that this is the most cost effective approach to solving a potential future problem. An additional list of references has been added and they are referred to throughout the comments where appropriate. Some of these references are duplications to those that are contained within the draft guide but are included here for continuity. Comments by Section Overview(1.) Before we attempt to set limits to solve a problem that has not been completely defined, we need a better definition of the problem.This includes continues monitoring of the low voltage network to determine the current levels of harmonic distortion and the rate of growth of the harmonic levels over time. We also need to have a better understanding of the combined effect of a mixture of non-linear loads and linear loads distributed within premises, and within a network. Scope(1.1) The scope should be consistent with the United States National Committee Position Paper on power line harmonics [1] and be limited to high impact products that can be identified as having a high potential of causing problems on the low voltage network and which can not be addressed by IEEE 519. Not all products may need to have limits because of a combination of their power level, market penetration, usage time, etc.. These products, that have low impact, should not require limits. Products that have medium impact on the network should have limits that are less restrictive than high impact products. REG_P1495_Comments 02/12/16 2 R. E. Gardinier Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 Purpose(1.2) If we want “To establish equipment harmonic limits, much like IEC 6100-3-2”, we should align the effort with the IEC such that the limits that we establish can become a subset of the IEC 61000-3-2 limits for those products that require limits. Our objective should be “One set of Limits, One measurement method, One label” Worldwide. Product manufacturers are already burdened with an endless list of requirements, measurement standards, and labeling requirements. We should not be adding to this costly burden by creating a unique set of requirements. The existing 519 standard does provide guidelines for harmonic levels and can be used to determine mitigation requirements at the premise level. Loads covered in this standard(4.0) The guide should limit its coverage to non-linear loads that use technology topologies that have the potential to have a high impact on the network and where network field data has demonstrated that these loads will cause an unacceptable increase in the harmonic levels of the network. Background(5.0) This section presents expressions that can be used to determine the approximate amount of harmonic current present and expressions used to determine the total harmonic distortion in percentage. There does not appear to be need for this information in this document. Existing Related Industry Standards and Practices(6) IEEE 519(6.1) No Comments IEC 61000-3-2 and IEC 61000-3-4(6.2) IEC 61000-3-2 is currently undergoing a complete revision with a completion target of 2004. In addition, key amendments[13} are being voted on at this time that enhance the measurement method and modify the classification of products that are subject to proportional limits when this standard goes into effect on 1/1/2001. This standard is an example of what can happen when manufacturers are not involved and the concerns of manufacturers are not properly taken into consideration throughout the development of the standard. Any standard that sets requirements for the product manufacturers must have participation by the manufacturers. The measurement detail required by these standards is also unacceptable. Individual harmonic current levels are required up through the 39th harmonic. The approach suggested in this draft guide is to use the total harmonic distortion(THD) as a limit method. This has merit and should be considered. It allows for more flexibility in individual harmonic levels, which will allow manufacturers more design freedom in meeting the limits. Individual harmonic limits may be required in some unique situations. Recommended Distortion Limits(7) Although there have been studies done on specific load types, there has not been a significant number of studies done that use a diverse set of loads that might represent typical loads on a low voltage network when servicing residential, commercial, or industrial installations. The impact factors of all the loads on a given network including power level, harmonic content,, usage (time of day, hours per day, etc.), market penetration and the respective interaction of the REG_P1495_Comments 02/12/16 3 R. E. Gardinier Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 loads must be considered when setting limits. This includes attenuation, cancellation, current division, and diversity. Differences in Distribution Design(7.1) Definition of the equivalent impedance of the U.S. power distribution network is important to setting harmonic limits. Task Force 5b of TC77A/WG1 has been given the responsibility of defining the network impedance in North America(U.S., Canada, Mexico) and Japan. The findings to date indicate that the impedance(Z) relationship between locations has the following relationship: ZEurope>ZJapan>ZNorth America at the point of common coupling(PCC). These findings are in disagreement with what is stated in this draft. This area obiviously needs further study and definition to make certain that we are all reading from the same page. The findings of TF5b also indicate that the network impedance is primarily a function of the network architecture and system design strategy. The U.S. and Canadian networks appear to be more robust in general and therefore will have a lower impedance which will make them less susceptible to harmonic loads. This is also in disagreement with statements made in this section of the draft. Consideration of Multiple Nonlinear Loads(7.2) The considerations outlined in this section are a good starting point for determining what products may warrant no limits, medium limits, or more severe limits. All of the effects of multiple non-linear loads combined with linear loads must be considered when establishing limits. The draft has outlined some of these effects. In addition to diversity effects[3] and cancellation effects[2,6,10], current division effects[10] and attenuation effects[2,3,4,7,11] most be considered. Diversity Effects(7.3) Agree/No Comments Cancellation Effects(7.4) Agree/No Comments Load Levels and Harmonics(7.5) Agree. Fluctuating loads can have a large dynamic power level and diverse harmonic current content. The measurement procedure contained within the original draft of IEC 61000-3-2 was inadequate to handle these types of loads. A major improvement has been defined and is included in the current amendments[13] to IEC 61000-3-2. Limits(7.6) Before limits can be established we must establish network compatibility levels/network susceptibility levels, current network distortion levels and trends, mitigation alternatives in the network that may be more cost effective, as well as a network model that considers all of the network effects. There is absolutely no justification given in this draft document for the maximum recommended distortion levels given in Table 7-1. These levels are extremely low and can not be justified from either a technical need or the overall cost to society[1]. Testing Requirements(8.0) The measurement of harmonic voltages and currents can become very complex when considering all of the possible load characteristics from quasi-steady state to fluctuating loads. Sophisticated, and expense, instrumentation is required to make many of these measurements. Our goal should be to establish measurement parameters that will provide the required level of control of the harmonic distortion needed to protect the network and which can be measured REG_P1495_Comments 02/12/16 4 R. E. Gardinier Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 most economically. The consideration of using THD is a step in this direction and should be explored further. Background(8.1) The product information that is required is provided by product manufacturers. Today, worldwide regulations require an almost endless list of information and labeling of products. We need to be careful not to ask for more unique regulations and information than is absolutely needed in order to connect a given product to the public low voltage network. Most manufacturers do have information on the non-linear characteristics of their products. This information may not have been taken from a statistically valid sample size, or production level products, and therefore should not be used as a public statement of the product’s characteristics. However, to require manufacturers to provide such information would add another set of measurement sampling plans, which would add significant manufacturing cost to a product. It should be sufficient to state that a product meets a given limit, if a limit is required. There may be a need to have more detailed information for high power loads that represent a very large point source but not for low power consumer products. The voltage supply & Harmonic Analyzer(8.2 & 8.3) It is important to control the source impedance(reference impedance) and the linearity of the voltage supply when making harmonic voltage and current measurements. Most product manufacturers have such sources and analyzers available to do harmonic testing as well as other required test. Considerable work has been done by IEC committees in regard to harmonic test requirements measurement techniques[14]. This work should be consulted as a starting point. Transducers(8.4-8.4.4) No Comments Suggested Protocol(8,5) No Comments / Suggest that reference [14] be used as a starting point. Respectfully submitted, R. E. Gardinier, 7/10/00 References: 1. United States National Committee- Power Line Harmonics Position Paper USCCEMC 99-01 ( May 19, 1999) 2. “Analysis of Compensation Factors Influencing the Net Harmonic Current Produced by Single-Phase Non-Linear Loads”, International Conference on Harmonics and Quality of Power(ICHQP) ’98, October 14-16, 1998, A. Mansoor, W. M. Grady 3. “An Investigation of Harmonics Attenuation and Diversity Among Distributed Single-Phase Power Electronic Loads”, IEEE Transactions on Power Delivery, Vol. 10, No. 1, January 1995, A. Mansoor, W. M. Grady, A. H. Chowdhury, M. J. Samotyjbb REG_P1495_Comments 02/12/16 5 R. E. Gardinier Comment on the “Draft Guide for Harmonic Limits for Single-Phase Equipment”, P1495/D1, 01-28-00 4. “Predicting the Net Harmonic Currents Produced by Large Numbers of Distributed Single-Phase Computer Loads”, IEEE Transactions on Power Delivery, Vol. 10, No. 4, October 1995, A. Mansoor, W. M. Grady, P. T. Staats, R. S. Thallam, M. T. Doyle, M. J. Samotyj 5. “A Statistical Analysis of the Effect of Electric Vehicle Battery Charging on Distribution System Harmonic Voltages”, IEEE Transactions on Power Delivery, November 25, 1996, P. T. Staats, W. M. Grady, A. Arapostathis, R. S. Thallan. 6. “Harmonic Cancellation by Mixing Non-Linear Single-phase and Three-phase Loads”, IEEE Transactions on Power Delivery, January , 1998, S. Hansen, P. Nielsen, F. Blaabjerg; Danfoss Drives/Denmark 7. “Mains Harmonics Analysis of the contribution of TV Receivers”, European Association of Consumer Electronics Manufacturers(EACEM), EACEM Technical Report No. 20, October, 1996 8. “Light Dimming Controls – Justification Supporting Continued Exemption from Harmonic Limits in IEC 61000-3-2”, Lutron Electronics Co., Inc, 17 September, 1999, D. G. Luchaco, R. S. Spehalski 9. “An Evaluation of Energy Storage Techniques for Improving Ride-Through Capability for Sensitive Customers on Underground Networks”, IEEE Transactions on Industry Applications, Vol. 33, No. 4, July/August, 1997, C. J. Melhorn, A. Braz, P. Hofmann, R. J. Mauro 10. “An Examination of the Rationale for Limiting Harmonic Emissions from LowVoltage Equipment”, IEEE Symposium, 1999, A. Mansoor, J. McKim 11. “Analysis of Harmonic Distortion Levels in Commercial Buildings”, Proceedings of the First International Conference on Power Quality, PQA, 1991, R. Zavadil, G. Hensley, K. Johnson. 12. “THOMSON MultiMedia Input – A Collection of Comments, Data Reports, Memorandums, and Analysis on Harmonics and the Cancellation effects of TV receivers.”, Harald Grellmann, 1996 13. “Electromagnetic Compatibility(EMC)-Part 3-2: Limits – Limits for harmonic current emissions(equipment input current up to and including 16A per phase”, EN 61000-32 : 1995/prA14:2000 14. “Testing and measurement techniques – Section 7: General guide on harmonics and inter-harmonics measurements and instrumentation, for power supply systems and equipment connected thereto”, EN 61000-4-7 : 1993 REG_P1495_Comments 02/12/16 6 R. E. Gardinier