Remarks on EPD Immersed transformers - Environmental Product Declarations

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Oil immersed power transformers (under development)

Remarks on EPD Immersed transformers

by: MICHEL SACOTTE 30 March 2018, 10:24:00 AM (GMT +1)

Following my understanding of the document my conclusions are:
• This document is representing a set of constraints for the manufacturer because we have to declare for each transformers a certain number of chemical and environmental data that should be calculated and entered in the EPD system
To summarize the main issues are:
o In most of the case we don't know the use of the transformers (load factor leading to the emission of substance)
o There are not standardized method to calculate all parameters requested that keep difficult the check
o This document will if adopted a big increase of work for all companies
o There are nothing indicated in case of dysfunction of the transformer

• We will talk about this topic in the WG Sub-technical group in T&D Europe to see which actions we should do.

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Here the remarks on the text by section and paragraph that should be added or complementary to the GE comments

I have read the EPD document and I have a lot of comments regarding this document that you can find below.
PARAGRAPH 1.2.1
Page 3
The date for open consultation written is 2017.12.06 ? Do this date has been changed?
Page 6
In the bottom of the page the definition given for Medium and large Power transformers are under revision by the commission
Closed or sealed gaz insulation system should be excluded
The last line indicating the “In this group the following oil immersed….furnace transformers.” Must be partially deleted because it is not relevant to evaluate some device in term of impact. See exclusion of European regulation directive for transformers ECO DESIGN
Page 7
On the top
Some data cannot not always have been given like environmental working conditions that are not always known by the manufacturer
It the same issue for other points like Main application services supported, Main market sector ,Main geographical area, …. Which are not known because this device can be resold through some distributor? And install by contractor,…..
Above
Most of the standards and particularly the most important European standard are missing in the list given
PARAGRAPH 2.6
It is not possible to give the result of one year operation as the load of the transformer sold is not known (Use and also location in the network of the customer when final customer is known
PARAGRAPH 2.7
Large studies have been undertaken under the control of the Eu commission with the same methodology that have leaded to the Eco-design directive which categorise today the transformers efficiency and oblige to have limits
PARAGRAPH 2.8
Use phase of 35Years are not in line with Eco-design
Average load assumed is not in line with Eco-design directive .The advertised average load is well above current and future current practices
PARAGRAPH 3.3.3.1
The value of Tl(Load) are not in line with the current use of the transformers and well above
-IEC standard is not the only standard given a method to measure the efficiency of the transformers (IEEE,….)
4.1
A clear standardized calculation method shall be established and approved to give the different data required by EPD
4.1.1
Same remarks that 4.1
5.1.2
Nothing concern the impact of the product in case of dysfunction or failure of the transformers (leakage of liquid,, explosion, fire….
6.2
A transformer is not a product because each device delivered is different. The weight of each components, the size of the device , and all dimensions are in most of the case not the same
Transformers is a device to adapt the voltage between 2 different networks (MV/LF or HV/MV or some other combinations)
Many rated power are sold from 50kVA up to 1000MVA representing already more than 35 types of transformers.
Many combinations of voltage are needed according to the primary of the transformers (5,5/ 6/10/11/12/13,8/15/17,3/17,5/20/22/30/33/36/40/63/66/90/….and double and dual voltage representing more than 40 possibilities
Many combinations of voltage according to the secondary of the transformers (0,4/0,410/,0,420/0,433/0,690/5,5/ 6/10/11/12/13,8/15/17,3/17,5/20/22/30/33/36/40/ and double and dual voltage representing also more than 40 possibilities
Some other parameters, like frequency, taps, impedance, temperature of use, ambient, altitude, humidity, environmental conditions, standard dedicated to countries lead to also other design
To summarize each transformer is different as each parameter given above change the design of the transformer and then the environmental impact. That is the reason why in Eu it has been decide to give a regulation for the efficiency and therefore for the environmental impact in use.
The document seems to request in 6.3 information for each transformers device that seems to be not realistic.

Re: Remarks on EPD Immersed transformers

by: TESSIE GARAN 07 August 2018, 9:16:18 AM (GMT +1)

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