LET’S BE June 2012 PACIFIC ™ Volume 12 Number 2 DOE Mandated Minimum Efficiencies For Distribution Transformers Medium Voltage Dry, Medium Voltage Liquid, Low Voltage Dry At this moment almost everyone associated with The DOE decided that they would include the Low Voltage Distribution Transformers, including transformer Ventilated Dry Transformers also in their evaluation of manufacturers, end users, suppliers of raw materials whether new mandated efficiency levels were needed. environmental petitioners (advocates), is anxiously Higher efficiency levels prescribed by the DOE are awaiting the final ruling of the U.S. Department of Energy DOE Medium Voltage Dry Efficiencies 46-95 KV BIL required by law to be (1) technologically feasible; (2) (DOE) on the new minimum efficiency levels that will be Proposed Present economically justifiable; and (3) provide a significant Pre-2010 DOE 2010 DOE 2016 KVA required of both liquid filled and dry type Distribution Efficiency Efficiency Efficiency energy savings and an overall benefit to preservation of Transformers. 112.5 96.7%environment 98.3% 98.4% and natural resources. the 150 97.1% 98.4% 98.5% We are all aware that the first DOE mandated efficiency225 97.5% 98.6% 98.7% Exhibits 1 and 300 97.6% 98.7% 98.8%2 provide a graphical representation of levels, known as TP-1, were required for low voltage500 97.9% 98.8% 99.0% how dry type 750 98.3% the99.0% 99.1%transformer efficiencies have been raised ventilated dry type transformers beginning in January of1000 98.5% 99.0% 99.2% to higher levels 2007. Next the DOE implemented minimum efficiency1500 98.6% 99.1% 99.3%starting in 2007 for Low Voltage and in 2010 for Medium 2000 98.7% 99.2% 99.4% Voltage, then will move to recommended levels for Medium Voltage Distribution Transformers in the2500 99.0% 99.2% 99.4% higher levels effective in 2016. The left bar, colored blue, categories of both liquid filled and dry-type transformers DOE Medium Voltage Dry 3 Phase Efficiencies 46-95 KV BIL (ventilated and CAST) that became effective in January of 2010. These new efficiency levels for %Efficiency medium voltage are sometimes called TSL-2 or 99.5% more correctly referenced: “MEETS EFFICIENCY 99.0% 98.5% LEVELS AS REQUIRED BY DOE 10 CFR 431 Pre-2010 Efficiency 98.0% SECTION 196”. Present DOE 2010 Efficiency 97.5% Brief Background The new 2010 Medium Voltage mandated efficiencies were finalized by DOE in October 2007. Right after this final rule was published certain parties, called petitioners or advocates, filed petitions for review in the United States Courts of Appeals in the Second and Ninth Circuits, challenging this final rule by alleging that the DOE did not comply with certain provisions of the 1975 Energy Policy Conservation Act (EPCA). In other words the DOE had not set the newly mandated efficiencies at a high enough level to suit the petitioners. Under the aegis of the courts the petitioners entered into a settlement that directed the DOE to review the mandated energy efficiency standards for Medium Voltage Dry and Liquid Distribution Transformers and publish their final findings by October 1, 2012. Proposed DOE 2016 Efficiency 97.0% 96.5% 96.0% 95.5% 95.0% 112.5 150 225 300 500 750 1000 1500 2000 KVA 2500 Exhibit 1 DOE Low Voltage Dry 3 Phase Efficiencies % Efficiency 99.5% 99.0% 98.5% 98.0% 97.5% 97.0% 96.5% 96.0% 95.5% 95.0% 94.5% 94.0% 93.5% 93.0% Pre-2007 TP-1 Efficiency 2007 TP-1 Efficiency Proposed 2016 Efficiency 15 30 45 75 112.5 150 225 300 500 750 1000 KVA Exhibit 2 1 This document contains proprietary information of Electro-Mechanical Corporation or its operating divisions in whom title remains. Any reproduction, distribution, disclosure or use not otherwise expressly approved in writing is strictly prohibited. Designated trademarks and brands are the property of their respective owners. represents the efficiency prior to the implementation of any of the DOE mandated efficiencies. The middle bar, shown in red, is the present efficiency level for both the Low Voltage and the Medium Voltage Dry Types. Finally the bar on the far right, colored green, represents the DOE proposed new efficiencies in its February 2012 NOPR (Notice of Proposed Rule Making). DOE engaged an analytical consultant, Navigant, who interviewed major stakeholders and compiled a lot of design data from the manufacturers. Navigant used the services from Lawrence Berkley National Labs (LBNL) for macroeconomic and transformer design data analyses. In addition a prominent software transformer design engineering company, Optimized Program Services, Inc.(OPS), was hired to provide transformer design data. In this newsletter the graphical representation of the rising efficiencies is shown for only the three phase units, as the single phase units are basically not changing from the present levels in 2016. While the steps may seem small when presented graphically, the actual reduction in losses required to meet the proposed levels for 2016 represent a 50% to 60% reduction in wasted energy from transformer losses before being regulated. Obviously there wasn’t time to analyze all of the liquid and dry designs, so representative designs as shown in Exhibit 3 were employed with the idea that other designs in similar categories would be scaled accordingly using a convention known as the 3/4 scaling factors. During the analyses many different varieties of core steels were analyzed for the best efficiency performance as shown in Exhibit 4. Not only were there many core steel alternatives considered, but also the manufacturers Negotiated Rulemaking Activity In the early part of 2011 the DOE decided that a team comprised of the transformer manufacturers and all Exhibit 3. Rob pasted a better other interested stakeholders, including transformer Design users, petitioners, and raw material suppliers, plus others version in the Word Document. Best option like economists and NEMA representatives, would work 6 kVA the Excel for this. 125phase toward reaching consensusIondid newfind transformer efficiency dry 10kV BIL Alternatives minimum levels.This “negotiated rulemaking” procedure had beenDistribution used successfully in the major appliance and oltage Dry-Type Transformers electric motor industries. 7 Best option 75 kVA 3 phase dry 10kV BIL Dry-Type, Medium Voltage, Three-Phase kVA EC 6 Low BIL 20-45kV EC 8 Med BIL 46-95kV EC 10 High BIL >96kV - 30 - 45 - DL 9 DL 11 15 75 112.5 150 8 300 kVA 3 phase dry 10kV BIL 9 300 kVA 3 phase dry 45kV BIL 10 1,500 kVA 3 phase dry 45kV BIL - 11 300 kVA 3 phase dry 45kV BIL - 225 Rep Unit Rep Unit Rep Unit 500 1500 2000 Rep Unit Rep Unit DL 12 1000 DL 10 750 12 1,500 kVA 3 phase dry 95kV BIL DL 13 (A & B) 300 Rep Unit 2500 Exhibit 3 ormers t Class 4 ow Voltage Design Line 2 Alternatives Best option CSL-0 (current) CSL-1 CSL-2 CSL-3 CSL-4 M-6 M-0H laser M-3 SA1 M-0H laser M-3 M-0H laser M-3 M-0H laser M-6 M-12 M-12 M-6 M-5 M-5 M-3 M-4 M-6 M-3 M-4 M-3 M-0H laser M-5 M-5 M-3 M-6 M-3 M-0H laser M-6 M-0H laser M-3 M-4 M-6 M-6 Alternatives Best option Alternatives Best option M-5 M-4 M-6 M-5 Alternatives Best option Alternatives Best option Alternatives M-4 M-6 M-5 M-3 M-5 SA1 SA1 CSL-5 CSL-6 CSL-7 M-3 M-6 M-0H laser M-4 M-0H laser SA1 M-3 SA1 SA1 M-0H laser SA1 SA1 SA1 SA1 SA1 SA1 M-4 M-3 M-4 M-0H laser M-3 SA1 SA1 SA1 SA1 SA1 SA1 SA1 SA1 SA1 M-0H laser M-5 M-5 M-4 M-0H laser M-0H laser SA1 SA1 M-4 M-3 M-0H laser M-3 M-4 M-5 M-0H laser M-3 M-4 SA1 M-0H laser M-0H laser M-3 M-4 M-4 M-0H SA1 M-3 M-4 M-3 M-4 M-0H laser SA1 SA1 M-4 Exhibit 4 SA1 like Federal Pacific most likely will be forced to invest in new core cutting and forming equipment that will yield higher efficiency core performance. An example of this conversion is shown in Exhibit 5 where the wound core may replace the traditional stacked core. Certainly the step-lap miter core (a stacked core) requiring expensive core cutting equipment, will replace in most cases the often used butt-lap core construction. were also several teleconferences that included the negotiating team members. The result of all of this effort yielded a lot of excellent information on possible more efficient transformer designs; however only one of the transformer segments, the Medium Voltage Dry-Type, MVDT, reached consensus on the new efficiency levels.This situation left the DOE without consensus recommendations to develop NOPR (Notice of Proposed Rulemaking) proposing new efficiencies for 2016 published in the Federal Register on February 10, 2012. This NOPR does an excellent job of explaining how the DOE arrived at the new efficiency levels. Most of this analytical activity was done and presented in six separate three-day meetings in Washington, D.C. by usually 20-30 participants, that were part of the 24 member rule-making negotiating team or their alternates, and the consultants engaged by the DOE. During this approximate six month time period there Stacked Core Wound Core Exhibit 5 3 Summarizing graphically the complexity of evaluating designs and trying to get consensus by all stakeholders Exhibit 6 illustrates many of the different interests and possibilities associated with this effort. transformers. Federal Pacific, a NEMA Premium® participant, was especially pleased with the support and leadership shown by NEMA toward working for a consensus position on higher transformer efficiencies. Exhibit 7 illustrates the savings that the NEMA Premium® transformer offers over a 20 year period relative to the presently regulated TP-1 designs. Federal Pacific is proud to have been a major participant in the negotiated rule making activity, and is publishing in this newsletter a graphical summary in Exhibit 7 of the end user benefits of installing higher efficiency 3-Phase LVDT NOPR Efficiency Levels 50.00% Advocates EL4 (47% loss reduction) 45.00% Advocates EL4 (40% loss reduction) 40.00% NOPR Average (35%) 35.00% % Loss Reduction NEMA Position (30%) 30.00% NEMA Position (24%) 25.00% NOPR Average (22.3%) 20.00% 15.00% 10.00% 5.00% 0.00% 15 30 45 75 112.5 150 225 300 500 750 1000 KVA NOPR Values .75 Scaling Exhibit 6 ® Projected Energy Savings Dollars Over 20 Years $14,000 $12,000 $10,000 $8,000 $6,000 $4,000 $2,000 $0 15 30 45 75 112.5 150 225 300 500 KVA NOTE - Actual savings are subject to energy rates over time. Numbers shown based on national average energy cost of $0.0967/kwhr and 35% average load. Exhibit 7 4 NP30 PAYBACK CHECK 3/27/2012