There is an existing 240D service, it is proposed to install a 240D-208Y120 transformer to supply a bunch of 120v loads. There is an existing conduit and conductors (3xH+1xG) from the service to the location where the transformer would go (about 100ft away). Does there need to be a seperate GEC from the transformer back to the service in addition to the EGC? There is no building steel to bond it to.