# 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. EERE

2010

- 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 belie ve 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) wi th 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 mi nimum 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 econo mic, 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 custo mer 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 envi sion 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

- ProlecDepartment of EnergyDocket No. EERE-2010-BT-CE-0014GE-Prolec CCE Meeting10/19/2010Distribution TransformersCommercialResidential

Products CustomersInvestor Owned UtilitiesRural Electric CoopsMunicipal Electric SystemsIndustrialsCovered Products

Market (1)Typical Price Range:$4,500 to $35,000Typical Lot Size:1 to 10 unitsIndustrialIndustrialsInvestor Owned UtilitiesRural Electric CoopsMunicipal Electric SystemsTypical Price Range:$18,000 to $65,000Typical Lot Size:1 to 5 unitsInvestor Owned UtilitiesRural Electric CoopsMunicipal Electric SystemsTypical Price Range:$600 to $1,800Typical Lot Size:1 to 250 unitsTypical Price Range:$1,000 to $3,000Typical Lot Size:1 to 200 units

Variety (1)Designs Quoted(2):1000 – 2000Typical Weight (lb):6400 – 14000Single Phase Poletype Single Phase Padmounted Three Phase Padmounted Substation Transformer (SST)Designs Quoted(2):8000 – 9000Typical Weight (lb):280 – 1450Designs Quoted(2):2000 – 3000Typical Weight (lb) :690 –1600Designs Quoted(2):9000 – 10000Typical Weight (lb):2500 – 1350025 33 29 36 14 24Typical DimensionsA (in) B (in) C (in)ABCABCABCABC40 60 23 35 26 45A (in) B (in) C (in)Typical Dimensions Range64 87 46 88 65 96A (in) B (in) C (in)Typical Dimensions90 95 50 65 60 80A (in) B (in) C (in)Typical Dimensions(1) Representative of Transformer Industry.(2) Represents a 1 year period.Distribution TransformersSubpart C—Certification,§429.19 Certification, (b) Certification report.To avoid confusion, we suggest paragraph (6) of this section be revised to add words displayed inred:(6)For each brand,the basic model number and the individual manufacturer’s model numbers covered by that basicmodel; in the case of external power supplies, when themanufacturer is certifying using a design family, the individualmanufacturer’s model numbers covered by the design family;in the case of distribution transformers, the individualmanufacturer’sleast efficient basicmodel numbers covered by the kilovolt ampere (kVA) grouping;[75FR179, p.56819]This revision in wording supports the additional Distribution Transformer related requirement in paragraph (13),(xlix) of this same section[75FR179, p.56821]which reads:(13) For . . . (xlix) For theleast efficient basic model of distribution transformerwithin each “kilovolt ampere (kVA)grouping”for which part 431 prescribes an efficiency standard, the kVA rating, the insulation type (i.e.,low-voltage drytype, medium-voltage dry-type or liquid-immersed), thenumber of phases (i.e.,single-phase or three-phase), and thebasic impulse insulation level (BIL) group rating (formedium-voltage dry-types). As used in this section, a “kVA grouping”is a group of basic models which all have the same kVA rating, have the same insulation type (i.e.,low-voltage dry-type,medium-voltage dry-type or liquid-immersed), have the same number of phases (i.e.,single-phase or three-phase), and,for medium-voltage dry-types, have the same BIL group rating (i.e.,20–45 kV BIL, 46–95 kV BIL or greater than 96 kVBIL).Thus, the requirement for Distribution Transformercertification reporting will be:•For each brand, the Least Efficient Basic Model in each kVA Grouping – the unique combination of insulation (liquidfilled), 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 proliferation ofdesigns;• Similar to the way Motors are handled;•Consistent with the industry characterizations and resulting proposals and rules published in 71FR142 (7/25/2006),72FR197 (10/12/2007), and 75FR2 (1/05/2010).Issue 1: Certification ReportDistribution TransformersIssue 2: Discontinued Model FilingSubpart C—Certification,§429.19 Certification, (g) Discontinued model filing[75FR179, p. 56822]• For Distribution Transformers, we interpret this paragraph to apply to a discontinuance of a Least EfficientBasicModel(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 volume custom-engineering and made-to-order industry.• It recognizes that basic models are designed for specific transactions, most with a relatively short period of timeassociated with those transactions.• While not discontinued per se, basic models designed fora given customer/transaction are typically not producedagain after the initial transaction(s) are completed due to changes in customer requirements, materials, processes,etc.Distribution TransformersIssue 3: Certification of Test SystemsSubpart C—Certification,§429.23 Alternative Methods for Determining Efficiency or Energy Use[75FR179, p. 56822]• Distribution Transformer electrical testing can be extremely complicated and requires test systems that use veryspecial, precise, and sensitive equipment and knowledgeof internal and external transformer connections and hookups for the test equipment. In addition, to test perDOE requirements on many transformer designs, access to thetransformer internals must be made and transformer leads reconnected through unbolting and repositioning leads,and rebolting. While the requirements of accuracy and equipment basics are covered in DOE documents, webelieve more refinement is necessary.• Most manufacturers test all (100%) transformers made using test methods defined in ANSI standards, which differbut are very similar to DOE requirements. Such test records are maintained for years so ANSI tested loss valuesare available for all transformers made. They could bechecked by DOE at any time and provide a good indicator ofDOE efficiency. This 100% testing provides a very good assurance of manufacturers knowing if they are meetingefficiency requirements. Transformer loss information has been supplied to customers for many years as part of thecontract performance terms and is another confirmation ofmeeting efficiency requirements.• In order to adequately test transformers, both for DOEcompliance via the test method or AEDM, and to provideaccurate ANSI loss test results, there must be assurance thatthe test equipment is properly checked and calibrated.Since this equipment is used extensively as 100% of unitsare tested and the test systems used rely on interactionbetween a great number of elements, we believe it is imperative that the test system be well calibrated and certified.•Therefore, we believe that DOE should change the regulations to require that all transformer manufacturershave their test systems certified to be in compliance with DOE regulations and that this certificationbeperformed by a third party that is knowledgeable insuch equipment. Due to the high volume of usage andthe importance of this issue, such 3rdparty certification should be performed annually and included in theCertification Report sent to DOE annually as part of the requirement in§429.29 (c ).Distribution TransformersIssue 4: Enforcement TestingSubpart E—Enforcement[75FR179, p. 56825]• We agree that DOE should do enforcement and verification testing of all products including Distribution Transformers.The issue for Distribution Transformers however is that the testing for losses is very complicated and requires theuse ofspecial, precise test equipment systems and connections. Italso requires the reconnection of internal hook-ups andtherefore whomever is doing the testing must know how toopen a transformer, make re-connections, and close andseal the transformer. Once testing is completed, the transformer must be opened again, reconnections made back tooriginal state, and the transformer resealed. The transformer should also have some tests performed to assure itsquality. The transformer manufacturer could no longersell the transformer as new if this work was performed bysomeone that does not have the equipment necessary to perform all these steps. Also, most manufacturers might beunwilling to warrant this work if performed by others.• There is an assumption that any test lab can accurately measure losses in transformers, which requires a very sensitivesystemof test equipment for accurate measurement; high accuracy components by themselves are not enough.• Manufacturers of distribution transformers should have some ability to challenge the results of an independent test labthat does not have proven established experience with the particular product tested. A lab that tests low voltage drytype transformers may not be able to accurately assess the losses in a large medium-voltage product. The processmay take longer, but it is a necessary step to assure accurateresults.• Once distribution transformer manufacturers have their own certified test labs, it would then provide for an environmentwhere DOE could have transformers tested, using the manufacturers own equipment.• Distribution Transformers are made-to-order products and manufacturers generally do not have inventory availablyforenforcement testing (or verification testing). However,current production units of similar types would be available as themanufacturer would be testing transformers every day. DOEcould chose units at random for enforcement (orverification) testing and could be assured that the testdata is reliable. DOE or its representatives could observe andeven be a part of the testing at the manufacturers location.• Finally, most if not all manufacturers have test data byunit serial number for the ANSI based loss testing doneon aproduction basis. These ANSI loss values can be used toclosely approximate the DOE efficiency values and can be anexcellent starting point for any verification or enforcement inquiry.Distribution TransformersIssue 5: Importing and ExportingSubpart D —General Provisions,§429.25 Imported products.[75FR179, p. 56824]• All Prolec GE brand Distribution Transformers for theUS market are imported into the US. Assuring a smoothand timelyborder crossing is critical to our ability to meet customer requirements.We are concerned that the nature of thedistribution transformer products make compliance applicability and determination at the border by Customs impractical.• All Prolec GE brand covered distribution transformer products imported forsale and usein the US are compliant andhave a designation to that effect on the transformer nameplate. An example of a nameplate designator is:DOE 10 CFRPART 431 10/12/07 COMPLIANT.• For many distribution transformers, the nameplate is not visible from the outside of the unit – e.g., for mostpadmountedtransformers, single and three phase, the nameplate is attached inside the low voltage compartment.• Distribution transformers that fall outside the rangeof units covered by the ruling may look similar to others that arecovered products. Those units willnothave a compliance designation even if they have an efficiency that meets thestandards since they fall outside of the regulation. However, to a Customs inspector, these facts may not be clear, norwill the differences in transformers be apparent (e.g,a 2500 kVA Wind Farm unit – a step-up distribution transformer).• We therefore recommend that DOE provideadditional documentation guidelinesfor import reviews by Customs.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 imported into the US forsale to a US based exporter for subsequent consolidation and shipment to an export non-covered location. Thesetransshipment units would be forsalein the US, but not forusein the US. Such transformers would again not have acompliance 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 shipping documentsalsoprovide similar notation.• We recommend that the requirement for a stamp or label in paragraph (b)of this section be changed to:“NOT FOR USE IN THE UNITED STATES”. . .to reflect the situations where units are imported andsold for subsequent export outside the US.