From: Eric.Petersen@aksteel.com [mailto:Eric.Petersen@aksteel.com] 

Sent: Tuesday, December 13, 2011 1:56 PM 

To: Richard Parker 

Cc: Meyers, Aaron; Alex Hofmann; Andrew Delaski; Aris Marantan; Art Rosenfeld; Bob Saint; Bob Smith; 

Brenda Edwards; Brian Coffey; Caitlin Johnson; Carlos Gaytan; Caskey, John; Charlie Drexler; Charlie 

Stevens; Chris Bolduc; Chris Brown; Clark Silcox; Creevy, Jim; Dan Cohen; Daniel Young; David Flaten; 

Emily Marchetti; Eric Peterson; Freeman, Jeremiah; Gary Fernstrom; Greg Coulter; Greg Rosenquist; 

Hirsch, Bruce R; James Lass; Jennifer Tiedeman; Corkran, Jerry L; Jerry Hodge; Jerry Schoen; Jim Raba; 

Joanna Mauer; John Cymbalsky; John Rossetti; Ken Winder; Mahesh P. Sampat; Matthew Nardotti; 

Maxine Savitz; Meg Waltner; Michael Hyland; Michael Rivest; Millure, Dave; Pamela Costello; Phil Harter; 

Phil Hopkinson; Polinski, Raymond; Puesh Kumar; Rick Anderson; Rob Greeson; Robert Berman; Robert 

van Buskirk; Robin Roy; Ryan, Paul; Scott Beck; Simmons, Chuck; Steve Nadel; Steve Rosenstock; Ted 

Johnstone; Thomas Petrosino; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo; Katie Coughlin 

Subject: Summary of Refurbishment Industry 

Mr. Parker and Committee Members, 

Jerry Schoen spent some time yesterday afternoon surveying the internet to get a feel for the transformer 

refurbishment industry. As you can see from the attached summary, a service and support industry 

clearly exists separate from the manufacturers. 

I would continue to encourage the committee to consider the very real concern of establishing an EL that 

pushes the industry towards refurbishment. I recognize there have been comments that we should not 

concern ourselves with this issue as we'll be able to identify a means of regulating a refurbishment 

industry; however, I am concerned about the viability of passing regulations considering the impact of 

such regulations on the existing businesses in this industry. 

Here is a summary of some 14 of these firms. 

Firm Date Established OEM GE check with Mr. Edison yes Sunbelt 1981 yes Solomon 1971 no Lakeport [unknown] no Brandon & Clark 1987 no T&R Electric 1961 no Southeastern 1974 no EMSCO 1948 no Uptegraff 1926 no Virginia 1971 yes Garrett 1974 no Cam Tran pre-1996 [expansion project then] yes Moloney 1909 yes Jerry's Electric 1976 yes 

Notable points Page 7 -- Sunbelt's comment with link to the EERE final rule stating that while its newly manufactured 

transformers comply with DOE efficiency standards, remanufactured transformers are exempt, 

Page 11 -- Solomon's comment on its recycling numbers (150,000 transformers per year) 
Page 19 -- R. E. Uptegraff statement about "why repair?: Our experience has shown that the majority of transformer failures can be traced to the introduction of 

some foreign matter (usually water) into the unit. It is imperative that the unit seal be maintained. This 

requires periodic inspection/maintenance of gaskets, weld integrity, paint integrity etc. - This task can be 

cumbersome for the user that is not in the business of building transformers. Liquid filled transformers are 

generally heavy, and require heavy equipment for disassembly. Handling and temporary storage of the 

insulating fluid can also present a unique problem. Being a new transformer manufacturer, the Uptegraff 

factory is specifically equipped to handle units as large as 15mVA. Our familiarity with transformer 

component suppliers makes accessory acquisition a snap. Our intimate knowledge of national standards 

regarding construction and test of transformers allows us to update your unit to current standards. For a 

minimum cost, you can extend the life of your unit. Page 22 -- Virginia Transformer statement about buying a reconditioned transformer: Cost can be 30-40% less than the price of a new transformer Standard warranty is superior to industry standard for new equipment Page 31 -- Moloney Electric statement about buying a reconditioned transformer: Minor repair is 20-40% of new [transformer] Refurbishment is 75% of new [transformer] 

I do not believe we should expect that implementing regulations on this industry is a foregone conclusion. 

 Increasing transformer efficiency levels to a point that the economics favor refurbishment needs to be 

recognized as a likely outcome of our effort and expecting that we can pass a regulation to ensure our 

savings remain intact should not be considered as an accomplished task. 

Regards, 

Eric Petersen Director Customer Technical Services and Research AK Steel Corporation 

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