From: Greg Coulter

Sent: Friday, October 29, 2010 4:13 PM

To: Barhydt, Laura

Cc: Armstrong, Ashley; Leon Chapa Ismael Ricardo (GE Infra Energy

Subject: GE-Prolec CCE Meeting October 19,2010

Ms. Barhydt,

This e-mail documents the GE-Prolec CCE meeting of October 19, 2010 concerning Docket No. EERE2010-BT-CE-0014. Mr. Ismael Leon and myself met with Ms. Ashley Armstrong, Ms. Celia Sher, Ms. 

Stephanie Weiner, and Ms. Laura Barhydt in your offices and discussed the attached charts concerning 

this NOPR. 

We appreciated the opportunity to meet with you and share a dialogue on the existing rule and changes 

outlined in the latest NOPR. You had specifically asked us to provide additional comments on our Issue 

#1. After further review, we continue to believe that the variety in ratings and designs needed to serve 

the US Distribution Transformer market supports a different approach for these covered products. 

While we do understand DOE’s desires for complete model submittals, we continue to believe that such

reporting requirements would be unmanageable by both the manufacturers and DOE.

Our US customer base consists of mainly larger entities (investor owned utilities, rural electric 

cooperatives, municipal electric systems, and some industrial companies) with knowledgeable technical 

personnel who specify and evaluate their distribution transformer requirements. They understand the 

range of efficiencies available, from those that meet the standards at lowest first cost to those that far 

exceed the current minimum efficiencies. Our customers provide specific guidelines on what they want, 

including economic evaluation factors for transformer electrical losses which we and other 

manufacturers use to offer our best match to these needs.

The wide range of economic, loading, and fundamental electrical system configurations in the US 

electric system drives thousands of basic models. For example, with liquid-immersed distribution 

transformers, the fundamental electrical rating elements alone (number of phases, kVA rating, high 

voltage rating, high voltage BIL, high voltage tap configuration, and low voltage rating), without 

including other features or efficiency, result in more than 25,000 possible combinations, many of which 

are purchased by one or more customers in a year. This variety is a result of differences in electrical 

systems as they evolved over the last 130 years and the wide range of end user applications served by 

our utility customers. The addition of other features and efficiencies, driven by customer loading and 

economic evaluations of the no load and load loss characteristics of the unique designs, takes the 

resulting estimate of design variety (e.g., basic models) well beyond the 25,000 estimate. Finally, 

manufactures are adjusting their designs through the year to take advantage of material costs changes, 

which could drive even more model variations. The number of basic models actually created and sold by 
a single manufacturer in a given year might be 10-20% of the total configurations required for the 

market – still a very large number of unique models for each product type. 

As we reviewed the existing CCMS templates for other products, it is clear that input process is designed 

for products and equipment with limited variety. We cannot envision how such a system would work 

with thousands of models entered annually.

If you have any questions or would like further information, please feel free to contact us.

Greg Coulter

Ph 704-762-1009 

Representing GE-Prolec
Department of Energy

Docket No. EERE-2010-BT-CE-0014

GE-Prolec CCE Meeting

10/19/2010
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Residential Commercial

Products Customers Investor Owned Utilities Rural Electric Coops Municipal Electric Systems Industrials

Covered Products 

Market 

(1)Typical Price Range:

$4,500 to $35,000

Typical Lot Size:

1 to 10 units

In

Mu

T

Investor Owned Utilities

Rural Electric Coops

Municipal Electric Systems

Typical Price Range:

$600 to $1,800

Typical Lot Size:

1 to 250 units

Typical Price Range:

$1,000 to $3,000

Typical Lot Size:

1 to 200 units

Variety

(1)

Single Phase Poletype Single Phase Padmounted Three Phase Padmounted Subs

Designs Quoted (2):

8000 – 9000

Typical Weight (lb):

280 – 1450

Designs Quoted(2):

2000 – 3000

Typical Weight (lb) :

690 –1600

Designs Quoted(2):

9000 – 10000

Typical Weight (lb):

2500 – 13500

25 33 29 36 14 24

Typical Dimensions

A (in) B (in) C (in)

A

B

C

C 

A

B

C

A

B

C

40 60 23 35 26 45

A (in) B (in) C (in)

Typical Dimensions Range

64 87 46 88 65 96

A (in) B (in) C (in)

Typical Dimensions

90 

A 

(1) Representative of Transformer Industry.(2) Represents a 1 year period.
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Subpart C—Certification, §429.19 Certification, (b) Certification report. 

To avoid confusion, we suggest paragraph (6) of this section be revised to add words displaye

(6) For each brand, the basic model number and the individual manufacturer’s model numbers covere

model; in the case of external power supplies, when the manufacturer is certifying using a design fammanufacturer’s model numbers covered by the design family; in the case of distribution transformers, 

manufacturer’s least efficient basic model numbers covered by the kilovolt ampere (kVA) grouping; [7

This revision in wording supports the additional Distribution Transformer related requirement (xlix) of this same section [75FR179, p.56821] which reads:(13) For . . . (xlix) For the least efficient basic model of distribution transformer within each “kilovolt am

grouping” for which part 431 prescribes an efficiency standard, the kVA rating, the insulation type (i.e.

type, medium-voltage dry-type or liquid-immersed), the number of phases (i.e., single-phase or three-

basic impulse insulation level (BIL) group rating (for medium-voltage dry-types). As used in this sectio

is a group of basic models which all have the same kVA rating, have the same insulation type ( i.e., lo

medium-voltage dry-type or liquid-immersed), have the same number of phases ( i.e., single-phase or 

for medium-voltage dry-types, have the same BIL group rating ( i.e., 20–45 kV BIL, 46–95 kV BIL or gBIL). Thus, the requirement for Distribution Transformer certification reporting will be:•For each brand, the Least Efficient Basic Model in each kVA Grouping – the unique combination of infilled), phases (1 or 3), and kVA rating;•As currently required by the existing regulations;• Appropriate for the custom-designed, made-to-order Distribution Transformer industry with a prolife• Similar to the way Motors are handled;•Consistent with the industry characterizations and resulting proposals and rules published in 71FR1472FR197 (10/12/2007), and 75FR2 (1/05/2010).

Issue 1: Certification Report
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Issue 2: Discontinued Model Filing 

Subpart C—Certification, §429.19 Certification, (g) Discontinued model filing [75FR179, p. 568

• For Distribution Transformers, we interpret this paragraph to apply to a discontinuance of a Least E

Model(s) for a kVA group or for discontinuance of a kVA group itself. 

• This interpretation is consistent with the kVA grouping of basic models for reporting in such a high 

engineering and made-to-order industry.

• It recognizes that basic models are designed for specific transactions, most with a relatively short p

associated with those transactions.

• While not discontinued per se, basic models designed for a given customer/transaction are typicall

again after the initial transaction(s) are completed due to changes in customer requirements, mateetc.
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Issue 3: Certification of Test Systems

Subpart C—Certification, §429.23 Alternative Methods for Determining Efficiency or Energy Us

[75FR179, p. 56822]

• Distribution Transformer electrical testing can be extremely complicated and requires test systems 

special, precise, and sensitive equipment and knowledge of internal and external transformer conn

ups for the test equipment. In addition, to test per DOE requirements on many transformer design

transformer internals must be made and transformer leads reconnected through unbolting and repo

and rebolting. While the requirements of accuracy and equipment basics are covered in DOE docbelieve more refinement is necessary. 

• Most manufacturers test all (100%) transformers made using test methods defined in ANSI standa

but are very similar to DOE requirements. Such test records are maintained for years so ANSI tesare available for all transformers made. They could be checked by DOE at any time and provide a 

DOE efficiency. This 100% testing provides a very good assurance of manufacturers knowing if thefficiency requirements. Transformer loss information has been supplied to customers for many yecontract performance terms and is another confirmation of meeting efficiency requirements.

• In order to adequately test transformers, both for DOE compliance via the test method or AEDM, a

accurate ANSI loss test results, there must be assurance that the test equipment is properly checkSince this equipment is used extensively as 100% of units are tested and the test systems used rebetween a great number of elements, we believe it is imperative that the test system be well calibra

• Therefore, we believe that DOE should change the regulations to require that all transforme

have their test systems certified to be in compliance with DOE regulations and that this certperformed by a third party that is knowledgeable in such equipment. Due to the high volumthe importance of this issue, such 3rd party certification should be performed annually and 

Certification Report sent to DOE annually as part of the requirement in §429.29 (c ).
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Issue 4: Enforcement Testing

Subpart E—Enforcement [75FR179, p. 56825]• We agree that DOE should do enforcement and verification testing of all products including Distribu

The issue for Distribution Transformers however is that the testing for losses is very complicated a

special, precise test equipment systems and connections. It also requires the reconnection of intetherefore whomever is doing the testing must know how to open a transformer, make re-connectionseal the transformer. Once testing is completed, the transformer must be opened again, reconnecoriginal state, and the transformer resealed. The transformer should also have some tests performquality. The transformer manufacturer could no longer sell the transformer as new if this work was 

someone that does not have the equipment necessary to perform all these steps. Also, most manunwilling to warrant this work if performed by others. 

• There is an assumption that any test lab can accurately measure losses in transformers, which req

system of test equipment for accurate measurement; high accuracy components by themselves ar

• Manufacturers of distribution transformers should have some ability to challenge the results of an i

that does not have proven established experience with the particular product tested. A lab that testype transformers may not be able to accurately assess the losses in a large medium-voltage prodmay take longer, but it is a necessary step to assure accurate results.

• Once distribution transformer manufacturers have their own certified test labs, it would then provide 

where DOE could have transformers tested, using the manufacturers own equipment.

• Distribution Transformers are made-to-order products and manufacturers generally do not have inv

enforcement testing (or verification testing). However, current production units of similar types woumanufacturer would be testing transformers every day. DOE could chose units at random for enfoverification) testing and could be assured that the test data is reliable. DOE or its representatives ceven be a part of the testing at the manufacturers location. 

• Finally, most if not all manufacturers have test data by unit serial number for the ANSI based loss t

production basis. These ANSI loss values can be used to closely approximate the DOE efficiency 

excellent starting point for any verification or enforcement inquiry.
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Issue 5: Importing and Exporting

Subpart D —General Provisions, §429.25 Imported products. [75FR179, p. 56824]• All Prolec GE brand Distribution Transformers for the US market are imported into the US. Assurin

border crossing is critical to our ability to meet customer requirements. We are concerned that the 

distribution transformer products make compliance applicability and determination at the border by 

• All Prolec GE brand covered distribution transformer products imported for sale and use in the US 

have a designation to that effect on the transformer nameplate. An example of a nameplate designa

PART 431 10/12/07 COMPLIANT.

• For many distribution transformers, the nameplate is not visible from the outside of the unit – e.g., fo

transformers, single and three phase, the nameplate is attached inside the low voltage compartmen

• Distribution transformers that fall outside the range of units covered by the ruling may look similar to 

covered products. Those units will not have a compliance designation even if they have an efficien

standards since they fall outside of the regulation. However, to a Customs inspector, these facts m

will the differences in transformers be apparent (e.g, a 2500 kVA Wind Farm unit – a step-up distrib

• We therefore recommend that DOE provide additional documentation guidelines for import revie

Subpart D —General Provisions, §429.26 Exported products. [75FR179, p. 56825]• Some distribution transformers that fall into the range of designs that would be covered may be imp

sale to a US based exporter for subsequent consolidation and shipment to an export non-covered lo

shipment units would be for sale in the US, but not for use in the US. Such transformers would agacompliance designation on their nameplate, regardless of efficiency. 

• Our current practice is to label such units and/or packaging “NOT FOR USE IN THE US”. The ship

provide similar notation.

• We recommend that the requirement for a stamp or label in paragraph (b) of this section be change

“NOT FOR USE IN THE UNITED STATES”

. . . to reflect the situations where units are imported and sold for subsequent export outside the US