From: Hirsch, Bruce R [mailto:Bruce.R.Hirsch@bge.com]

Sent: Wednesday, September 28, 2011 11:12 AM

To: 'Millure, Dave'; Kenneth Winder; Rosenstock, Steven

Cc: Richard Parker; Corkran, Jerry L; Caitlin Johnson; rick.anderson@faypwc.com;

tballo@earthjustice.org; ScottB@lvmetals.com; john.caskey@nema.org; jo hn.cymbalsky@ee.doe.gov;

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com;

rgreeson@federalpacific.com; mhyland@appanet.org; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetal s.com; rroy@nrdc.org; ro bert.saint@nreca.coop;

chuck.simmons@pgnmail.com; mark.stoering@xcelener gy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov;

Brian Coffey; gjrosenquist@lbl.gov; Michae l Rivest; Jerry Hodge; jrossetti@mlgw.org;

Jim.creevy@nema.org; Meyers, Aaron; Daniel.C ohen@hq.doe.gov; jmau er@standardsasap.org;

greg.coulter405@gmail.com; bsmith@federalpacific.c om; pkumar@publicpower.org; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com; Ryan, Paul;

jerry.schoen@aksteel.com; mwaltner@nrdc.org; chad.kennedy@us.schneider-electric.com;

eduardorobles@eaton.com; vijay.tendulkar@on yxpower.com; carlosgsiqueiros@eaton.com;

thomas.patzner@us.schneider-electric.com; Marusine c, Richard M; Schneider, Jeffrey A; Loomans,

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee reques ted areas for the DOE to Investigate before

final rules are selected.

Dave,

Hopefully Kenneth will get back to you with your request for more details.

My understanding was that his comments on transformer failures are based solely on the experienced

failure rates of amorphous core transformers vs. silicon steel core units. He evidently has a number of

the amorphous core units installed on his system givi ng hi m a good opportunity to compare failure

rates. We understand that this conclusion is valid only if the entire population has seen the same service

experiences. It is great, however, that we have some experience to guide us.

As for pole issues, weight is indeed a co ncern for utili ties. In the Baltimore area, we find our poles

heavily loaded with facilities from other utilities (phone, cable TV

, etc.) thus any change in weight of the

transformer being replaced may cause us to have to increase the pole size to handle the load. As you

can i magine this drives up the cost trem endously for our customers.

Equally important is the size of the transformer. We are bound by strict clearance requirements for

safety reasons and as such often find ourselves having to increase height of the pole to meet those

requirements. This is especially a problem in areas wh ere other utilities are on our poles and will only

getting worse with the push to allow antennas on our poles.

I will try to get some information on the number of required pole change

‐ outs since the July 1, 2010 law

went into effect due to transformer wei ght a nd/or size (excluding increases in the kVA rating). Maybe

some of the other utilities on this distribution list have some numbers they can share.

Bruce

From: Millure, Dave [ mailto:Dave.Millure@metglas.com ]

Sent: Friday, September 23, 2011 12:19 PM

To: Kenneth Winder; Rosenstock, Steven

Cc: Richard Parker; Corkran, Jerry L; Caitlin Johnson; rick.anderson@faypwc.com ;tballo@earthjustice.org ; ScottB@lvmetals.com ; john.caskey@nema.org ; john.cymbalsky@ee.doe.gov ;

adelaski@standardsasap.org ; Teckman@nwcouncil.org ; gbf1@pge.com ; carlos.gaytan@ge.com ;

rgreeson@federalpacific.com ; Hirsch, Bruce R; mhyland@appanet.org ; snadel@aceee.org ;

wes.patterson@us.abb.com ; Eric.Petersen@aksteel.com ; Raymond.Polinski@atimetals.com ;

rroy@nrdc.org ; robert.saint@nreca.coop ; chuck.simmons@pgnmail.com ; mark.stoering@xcelenergy.com ;

cabolduc@lbl.gov ; kcoughlin@lbl.gov ; Brian Coffey; gjrosenquist@lbl.gov ; Michael Rivest; Jerry Hodge;

jrossetti@mlgw.org ; Jim.creevy@nema.org ; Meyers, Aaron; Daniel.Cohen@hq.doe.gov ;

jmauer@standardsasap.org ; greg.coulter405@gmail.com ; bsmith@federalpacific.com ;

pkumar@publicpower.org ; Trujillo, Antonio; Phil Hopkinson; ahofmann@publicpower.org ;

BermanEconomics@gmail.com ; Ryan, Paul; jerry.schoen@aksteel.com ; mwaltner@nrdc.org ;

chad.kennedy@us.schneider-electric.com ; eduardorobles@eaton.com ; vijay.tendulkar@onyxpower.com ;

carlosgsiqueiros@eaton.com ; thomas.patzner@us.schneider-electric.com ; Marusinec, Richard M;

Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer

Subject: RE: Distribution Transformers Committee reques ted areas for the DOE to Investigate before

final rules are selected.

Dear Mr. Winder



### Comments about the effects of transformer loading on a distribution pole : We look forward to

seeing the basis for your statements below concerning pole loading.



### Comments about Amorphous core transformers : As for your brief comments that attempt to cast

doubt on durability of amorphous

‐ core transformers, please be advised that there are over 2 million

amorphous distribution transformers installed worldwide and popularity is increasing. I assume that

you are saying that you have test data before installation and identically

‐ measured test da ta on the

same units after some time in service or in storage. Your claims are counter to our experience, and I

believe that if you are to make such claims about higher “failure” rates, it is incumbent upon Moon Lake

Electric to disclose those data and we look forward to seeing th em. Amorphous cores have been tested

in both field tests and in accelerated aging tests and the conclusion is that core loss will not increase

over the lifetime of any transformer with the accelerated aging predicting no core loss increase for

hundreds of years. Again, we look forward to seei ng details of your analysis incl uding a comparable

“steel

‐ core” analysis and a definition of what you term as “failure.”

Best regards

Dave Millure

Metglas Inc. (most likely provider of the amorphous metal for your 1,700 amorphous transformers)

From: Kenneth Winder [ mailto:kwinder@mleainc.com ]

Sent: Thursday, September 22, 2011 7:36 PM

To: Rosenstock, Steven

Cc: Richard Parker; Corkran, Jerry L; Caitlin Johnson; rick.anderson@faypwc.com ;

tballo@earthjustice.org ; ScottB@lvmetals.com ; john.caskey@nema.org ; john.cymbalsky@ee.doe.gov ;

adelaski@standardsasap.org ; Teckman@nwcouncil.org ; gbf1@pge.com ; carlos.gaytan@ge.com ;

rgreeson@federalpacific.com ; bruce.r.hirsch@bge.com ; mhyland@appanet.org ; Millure, Dave;

snadel@aceee.org ; wes.patterson@us.abb.com ; Eric.Petersen@aksteel.com ;

Raymond.Polinski@atimetals.com ; rroy@nrdc.org ; robert.saint@nreca.coop ;

chuck.simmons@pgnmail.com ; mark.stoering@xcelenergy.com ; cabolduc@lbl.gov ; kcoughlin@lbl.gov ;

Brian Coffey; gjrosenquist@lbl.gov ; Michael Rivest; Jerry Hodge; jrossetti@mlgw.org ;Jim.creevy@nema.org ; Meyers, Aaron; Daniel.Cohen@hq.doe.gov ; jmauer@standardsasap.org ;

greg.coulter405@gmail.com ; bsmith@federalpacific.com ; pkumar@publicpower.org ; Trujillo, Antonio; Phil

Hopkinson; ahofmann@publicpower.org ; BermanEconomics@gmail.com ; Ryan, Paul;

jerry.schoen@aksteel.com ; mwaltner@nrdc.org ; chad.kennedy@us.schneider-electric.com ;

eduardorobles@eaton.com ; vijay.tendulkar@onyxpower.com ; carlosgsiqueiros@eaton.com ;

thomas.patzner@us.schneider-electric.com ; Marusinec, Richard M; Schneider, Jeffrey A; Loomans,

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer

Subject: Re: Distribution Transformers Committee reques ted areas for the DOE to Investigate before

final rules are selected.



### On 9/22/2011 5:11 PM, Kenneth Winder wrote:

Mr. Parker and others,

Below are comments for the modeling, studies and considerations to help in this negotiated

Rulemaking process.

Comments about the effects of transformer loading on a distribution pole : A statement of

record was made in the September Rulemaking Committee meeting that vertical weight on a pole

(from a transformer) can be ignored.

I believe this is incorrect and have found some engineering data and calculations concerning the

effects of the application of transformers as a tran sverse and vertical load on a pole. It sets forth

the calculation methods of the fo rces involved and eventu ally arrives at allo wable loads that can

be attached to a distribution pole of various heights and classes. The work shown and

conclusions reached in that paper need to be modified to represent an amorphous core

transformer since that type of tr ansformer is larger physically and is offset further from the pole

than the calculations found, they need to be recalculated for the amorphous transformer

application.

I believe this information should become part of the public record. I need to look further into

any copyright on the information be fore it can be sent to the group.

Comments about Amorphous core transformers : We have reviewed th e failure of pole-mounted

amorphous core transformers over a twenty year period for our utility. We purchased over 1,700

of them during the early to mid-1990's. We have looked at the amorphous transformers

purchased compared to those that are still in service (includes those that are on the warehouse

docks and in the field). We have tried to simila rly compare the same for steel-core transformers.

Failure rates appear to differ signi ficantly (higher for Amorphous core units). Is this represented

properly in the DOE/Navigant model?

Kenneth A. Winder

Moon Lake Electric Assn., Inc.

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