Energy Conservation Program: Test Procedure for Commercial and Industrial Pumps
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Abstract
The U.S. Department of Energy ("DOE") proposes to amend the test procedure for commercial and industrial pumps ("pumps") to harmonize with updated industry standards, to expand the scope of clean water pumps covered by this test procedure, and to revise calculation methods for pumps sold with motors and controls to better represent field energy use. DOE is seeking comment from interested parties on the proposal and announcing a public meeting to collect comments and data on its proposal.
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[Federal Register Volume 87, Number 69 (Monday, April 11, 2022)]
[Proposed Rules]
[Pages 21268-21331]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-06142]
[[Page 21267]]
Vol. 87
Monday,
No. 69
April 11, 2022
Part II
Department of Energy
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10 CFR Parts 429 and 431
Energy Conservation Program: Test Procedure for Commercial and
Industrial Pumps; Proposed Rule
Federal Register / Vol. 87, No. 69 / Monday, April 11, 2022 /
Proposed Rules
[[Page 21268]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 431
[EERE-2020-BT-TP-0032]
RIN 1904-AC54
Energy Conservation Program: Test Procedure for Commercial and
Industrial Pumps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and announcement of public
webinar.
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SUMMARY: The U.S. Department of Energy (``DOE'') proposes to amend the
test procedure for commercial and industrial pumps (``pumps'') to
harmonize with updated industry standards, to expand the scope of clean
water pumps covered by this test procedure, and to revise calculation
methods for pumps sold with motors and controls to better represent
field energy use. DOE is seeking comment from interested parties on the
proposal and announcing a public meeting to collect comments and data
on its proposal.
DATES: DOE will accept comments, data, and information regarding this
proposal no later than June 10, 2022. See section V, ``Public
Participation,'' for details. DOE will hold a webinar on April 26,
2022, from 1:00 p.m. to 4:00 p.m. See section V, ``Public
Participation,'' for webinar registration information, participant
instructions, and information about the capabilities available to
webinar participants. If no participants register for the webinar, it
will be cancelled.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at <a href="http://www.regulations.gov">www.regulations.gov</a>, under docket
number EERE-2020-BT-TP-0032. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments by
email to <a href="/cdn-cgi/l/email-protection#1f6f6a726f6c2d2f2d2f6b6f2f2f2c2d5f7a7a317b707a31787069"><span class="__cf_email__" data-cfemail="b1c1c4dcc1c283818381c5c181818283f1d4d49fd5ded49fd6dec7">[email protected]</span></a>. Include docket number EERE-2020-
BT-TP-0032 in the subject line of the message. No telefacsimiles
(``faxes'') will be accepted. For detailed instructions on submitting
comments and additional information on this process, see section V of
this document.
Although DOE has routinely accepted public comment submissions
through a variety of mechanisms, including postal mail and hand
delivery/courier, the Department has found it necessary to make
temporary modifications to the comment submission process in light of
the ongoing COVID-19 pandemic. DOE is currently suspending receipt of
public comments via postal mail and hand delivery/courier. If a
commenter finds that this change poses an undue hardship, please
contact Appliance Standards Program staff at (202) 586-1445 to discuss
the need for alternative arrangements. Once the COVID-19 pandemic
health emergency is resolved, DOE anticipates resuming all of its
regular options for public comment submission, including postal mail
and hand delivery/courier.
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts (if a public meeting is held),
comments, and other supporting documents/materials, is available for
review at <a href="http://www.regulations.gov">www.regulations.gov</a>. All documents in the docket are listed
in the <a href="http://www.regulations.gov">www.regulations.gov</a> index. However, some documents listed in the
index, such as those containing information that is exempt from public
disclosure, may not be publicly-available.
The docket web page can be found at <a href="http://www.regulations.gov/docket/EERE-2020-BT-TP-0032">www.regulations.gov/docket/EERE-2020-BT-TP-0032</a>. The docket web page contains instructions on how
to access all documents, including public comments, in the docket. See
section V for information on how to submit comments through
<a href="http://www.regulations.gov">www.regulations.gov</a>.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-2J,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 586-9870. Email <a href="/cdn-cgi/l/email-protection#f2b382829e9b939c9197a186939c9693809681a3879781869b9d9c81b29797dc969d97dc959d84"><span class="__cf_email__" data-cfemail="b5f4c5c5d9dcd4dbd6d0e6c1d4dbd1d4c7d1c6e4c0d0c6c1dcdadbc6f5d0d09bd1dad09bd2dac3">[email protected]</span></a>.
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 586-8145. Email: <a href="/cdn-cgi/l/email-protection#6924000a01080c054722000d06290118470d060c470e061f"><span class="__cf_email__" data-cfemail="1d50747e757c787133567479725d756c33797278337a726b">[email protected]</span></a>.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the webinar, contact
the Appliance and Equipment Standards Program staff at (202) 287-1445
or by email: <a href="/cdn-cgi/l/email-protection#a7e6d7d7cbcec6c9c4c2f4d3c6c9c3c6d5c3d4f6d2c2d4d3cec8c9d4e7c2c289c3c8c289c0c8d1"><span class="__cf_email__" data-cfemail="e8a99898848189868b8dbb9c89868c899a8c9bb99d8d9b9c8187869ba88d8dc68c878dc68f879e">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION: DOE proposes to update a previously approved
standard by incorporating by reference the following industry standard
into part 431: HI 40.6-2021, ``Methods for Rotodynamic Pump Efficiency
Testing.''
Copies of HI 40.6-2021 can be obtained from the Hydraulic Institute
at 6 Campus Drive, First Floor North, Parsippany, NJ, 07054-4406, or by
going to <a href="http://www.pumps.org">www.pumps.org</a>.
DOE proposes to maintain previously approved standards incorporated
by reference into part 431, except for the following, which DOE
proposes to remove from part 431:
ANSI/HI 1.1-1.2-2014, ``American National Standard for Rotodynamic
Centrifugal Pumps for Nomenclature and Definitions.''
ANSI/HI 2.1-2.2-2014, ``American National Standard for Rotodynamic
Vertical Pumps of Radial, Mixed, and Axial Flow types for Nomenclature
and Definitions.''
For a further discussion of these standards, see section IV.M of
this document.
Table of Contents
I. Authority and Background
A. Authority
B. Background
II. Synopsis of the Notice of Proposed Rulemaking
III. Discussion
A. Scope of Applicability
1. Pumps Not Designed for Clean Water Applications
2. Small Vertical Inline Pumps
3. Other Clean Water Pump Categories
a. Between-Bearing Pumps
b. Vertical Turbine Pumps
c. Radially-Split Multi-Stage Horizontal Pumps
d. End-Suction Pumps Similar to ESFM and ESCC Pumps
e. Line Shaft and Cantilever Pumps
4. Scope Limitations
a. Submersible Turbine Pumps With Bowl Diameter Greater Than 6
Inches
b. Pumps Designed To Be Operated at 1,200 RPM
c. Pump Horsepower and Design Speed
d. Horsepower and Number of Stages for Testing
e. Design Temperature Range
B. Definitions
1. Removing Certain References to Volute
2. HI Pump Class References
3. Bowl Diameter
4. Small Vertical Inline Pumps
5. Between-Bearing Pumps
6. Vertical Turbine Pump
7. Radially-Split, Multi-Stage Horizontal Pumps
8. Close-Coupled and Mechanically-Coupled Pumps
9. Tangential Discharge
10. Pump
C. Updates to Industry Standards
1. ANSI/HI 40.6
2. ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014
D. Metric
E. Proposed Amendments to Test Method
1. Nominal Speed
2. Testing of Multi-Stage Pumps
3. Best Fit Curve
4. Load Profile
5. Pumps With BEP at Run-Out
[[Page 21269]]
6. Calibration of Measurement Equipment
7. Calculations and Rounding
8. Test Procedure Credits
F. Calculation-Based and Testing-Based Options According to Pump
Configuration (Table 1)
1. Calculation Method for Pumps Sold With Induction Motors and
Controls
2. Calculation Method for Pumps Sold With Inverter-Only Motors
(With or Without Controls)
3. Pumps Sold With Submersible Motors
G. Test Procedure for SVIL Pumps
H. Test Procedure for Other Expanded Scope Pumps
I. Sampling Plan, AEDMs, Enforcement Provisions, and Basic Model
1. Sampling Plan for Determining Represented Values
2. Alternative Efficiency Determination Methods
a. Background
b. Basic Criteria Any AEDM Must Satisfy
c. Validation
d. Records Retention Requirements
e. Additional AEDM Requirements
f. AEDM Verification Testing
3. Enforcement Provisions
4. Basic Model Definition
J. Representations of Energy Use and Energy Efficiency
K. Labeling Requirements
L. Test Procedure Costs and Harmonization
1. Test Procedure Costs and Impact
a. Scope Expansions
b. Calculation Method for Testing Pumps With Inverter-Only
Motors
c. Updated Calculation Method for Testing Pumps With Induction
Motors
d. Additional Amendments
2. Harmonization With Industry Standards
M. Compliance Date
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations
Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
M. Description of Materials Incorporated by Reference
V. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
Commercial and industrial pumps (collectively, ``pumps'') are
included in the list of ``covered equipment'' for which DOE is
authorized to establish and amend energy conservation standards and
test procedures. (42 U.S.C. 6311)(1)(A)) DOE's energy test procedures
for pumps are currently prescribed at title 10 of the Code of Federal
Regulations (``CFR''), Sec. 431.464, and 10 CFR part 431 subpart Y
appendix A (``appendix A''). The following sections discuss DOE's
authority to establish test procedures for pumps and relevant
background information regarding DOE's consideration of test procedures
for this equipment.
A. Authority
The Energy Policy and Conservation Act, as amended (``EPCA''),\1\
authorizes DOE to regulate the energy efficiency of a number of
consumer products and certain industrial equipment. (42 U.S.C. 6291-
6317) Title III, Part C of EPCA, added by Public Law 95-619, Title IV,
section 441(a), established the Energy Conservation Program for Certain
Industrial Equipment, which sets forth a variety of provisions designed
to improve energy efficiency. This equipment includes pumps, the
subject of this document. (42 U.S.C. 6311(1)(A))
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
Parts A and A-1 of EPCA.
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The energy conservation program under EPCA consists essentially of
four parts: (1) Testing, (2) labeling, (3) Federal energy conservation
standards, and (4) certification and enforcement procedures. EPCA
include definitions (42 U.S.C. 6311), test procedures (42 U.S.C. 6314),
labeling provisions (42 U.S.C. 6315), energy conservation standards (42
U.S.C. 6313), and the authority to require information and reports from
manufacturers (42 U.S.C. 6316).
The Federal testing requirements consist of test procedures that
manufacturers of covered equipment must use as the basis for: (1)
Certifying to DOE that their equipment complies with the applicable
energy conservation standards adopted pursuant to EPCA (42 U.S.C.
6316(a); 42 U.S.C. 6295(s)), and (2) making other representations about
the efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE
must use these test procedures to determine whether the equipment
complies with relevant standards promulgated under EPCA. (42 U.S.C.
6316(a); 42 U.S.C. 6295(s))
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a) and 42 U.S.C. 6316(b); 42 U.S.C. 6297) DOE may, however,
grant waivers of Federal preemption for particular State laws or
regulations, in accordance with the procedures and other provisions of
EPCA. (42 U.S.C. 6316(a))
Under 42 U.S.C. 6314, EPCA sets forth the criteria and procedures
DOE must follow when prescribing or amending test procedures for
covered equipment. EPCA requires that any test procedures prescribed or
amended under this section must be reasonably designed to produce test
results which reflect energy efficiency, energy use or estimated annual
operating cost of a given type of covered equipment during a
representative average use cycle and requires that test procedures not
be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2))
EPCA also requires that, at least once every 7 years, DOE evaluate
test procedures for each type of covered equipment, including pumps, to
determine whether amended test procedures would more accurately or
fully comply with the requirements for the test procedures to not be
unduly burdensome to conduct and be reasonably designed to produce test
results that reflect energy efficiency, energy use, and estimated
operating costs during a representative average use cycle.\2\ (42
U.S.C. 6314(a)(1))
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\2\ EPCA also requires after DOE first prescribes a test
procedure for regulated industrial equipment, to conduct an
evaluation of that test procedure not later than three years after
the prescribing of that test procedure--and from time to time
thereafter. See 42 U.S.C. 6314(c). DOE considers this rulemaking to
be in satisfaction of this initial evaluation requirement.
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In addition, if the Secretary determines that a test procedure
amendment is warranted, the Secretary must publish proposed test
procedures in the Federal Register, and afford interested persons an
opportunity (of not less than 45 days' duration) to present oral and
written data, views, and arguments on the proposed test procedures. (42
U.S.C. 6314(b)) If DOE determines that test procedure revisions are not
appropriate, DOE must publish its determination not to amend the test
procedures. (42 U.S.C. 6314(a)(1)(A)(ii)) DOE is publishing this Notice
of Proposed Rulemaking (NOPR) in satisfaction of the 7-year review
requirement specified in EPCA.
B. Background
DOE's established its test procedure for pumps in a final rule
published on January 25, 2016. 81 FR 4086 (``January
[[Page 21270]]
2016 Final Rule'').\3\ The January 2016 Final Rule established
definitions for the terms ``pump,'' \4\ ``driver,'' \5\ and
``controls,'' \6\ and identified several categories and configurations
of pumps. The pumps test procedure currently incorporates by reference
the Hydraulic Institute (``HI'') Standard 40.6-2014, ``Methods for
Rotodynamic Pump Efficiency Testing'' (``HI 40.6-2014''), along with
several modifications to that testing method related to measuring the
hydraulic power, shaft power, and electric input power of pumps,
inclusive of electric motors and any continuous or non-continuous
controls.\7\
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\3\ On March 23, 2016, DOE published a correction to the January
2016 Final Rule to correct the placement of the product-specific
enforcement provisions related to pumps under 10 CFR 429.134(i). 81
FR 15426.
\4\ A ``pump'' means equipment designed to move liquids (which
may include entrained gases, free solids, and totally dissolved
solids) by physical or mechanical action and includes a bare pump
and, if included by the manufacturer at the time of sale, mechanical
equipment, driver, and controls.
\5\ A ``driver'' provides mechanical input to drive a bare pump
directly or through the use of mechanical equipment. Electric
motors, internal combustion engines, and gas/steam turbines are
examples of drivers. (10 CFR 431.462)
\6\ A ``control'' is used to operate a driver. (10 CFR 431.462)
\7\ A ``continuous control'' is a control that adjusts the speed
of the pump driver continuously over the driver operating speed
range in response to incremental changes in the required pump flow,
head, or power output. A ``non-continuous control'' is a control
that adjusts the speed of a driver to one of a discrete number of
non-continuous preset operating speeds, and does not respond to
incremental reductions in the required pump flow, head, or power
output. 10 CFR 431.462.
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On September 28, 2020, DOE published an early assessment review
request for information (``RFI'') to determine whether to proceed with
a rulemaking to amend the test procedure for commercial and industrial
pumps. 85 FR 60734 (``September 2020 Early Assessment RFI''). Following
review of the comments received in response to the September 2020 Early
Assessment RFI, on April 16, 2021, DOE published an RFI in which it
sought data and information pertinent to whether amended test
procedures would (1) more accurately or fully comply with the
requirement that the test procedure produces results that measure
energy use during a representative average use cycle for the equipment
without being unduly burdensome to conduct, or (2) reduce testing
burden. 86 FR 20075 (``April 2021 RFI''). In response to requests from
stakeholders,\8\ on May 5, 2021, DOE published an extension of the
comment period for an additional 30 days. (86 FR 23875) DOE received
comments in response to the April 2021 RFI from the interested parties
listed in Table I.1.\9\ A parenthetical reference at the end of a
comment quotation or paraphrase provides the location of the item in
the public record.\10\
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\8\ Price Pump, EERE-2020-BT-TP-0032, No. 10 at p. 1; Hydraulic
Institute EERE-2020-BT-TP-0032, No. 11 at p. 1; Grundfos, EERE-2020-
BT-TP-0032, No. 12, at p. 1; Xylem, EERE-2020-BT-TP-0032, No. 13 at
p. 1.
\9\ In addition to the comments listed in Table I.1, DOE also
received one comment from an individual, which was unrelated to the
test procedures for pumps.
\10\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
test procedures for pumps (Docket No. EERE-2020-BT-TP-0032, which is
maintained at <a href="http://www.regulations.gov/#!docketDetail">www.regulations.gov/#!docketDetail</a>;D=EERE-2020-BT-TP-
0032). The references are arranged as follows: (Commenter name,
comment docket ID number, page of that document).
[GRAPHIC] [TIFF OMITTED] TP11AP22.000
In their comments, Summit asserted that the industry as a whole has
become more aware of DOE's energy standards for pumps since January
2020 when the pumps standards went into effect. (Summit, No. 16 at p.
7) Grundfos suggested that DOE consider eliminating multiple open
notices that affect a given industry to ensure proper stakeholder
engagement. (Grundfos, No. 17 at p. 1)
As noted, EPCA requires DOE to periodically review the test
procedures of covered equipment, including pumps, to determine whether
amended test procedures would more accurately or fully comply with the
requirements for the test procedures to not be unduly burdensome to
conduct and be reasonably designed to produce test results that reflect
energy efficiency, energy use, and estimated operating costs during a
representative average use cycle. (42 U.S.C. 6314(a)(1)) In order to
provide stakeholders opportunities to engage as part of DOE's decision
making, DOE provided opportunity for stakeholder comment to the
September 2020 Early Assessment RFI and the April 2021 RFI. This NOPR
provides further opportunity for comment on
[[Page 21271]]
proposed amendments to the test procedure for pumps, which are
discussed in the following sections. DOE acknowledges that it has
multiple open notices that may inordinately impact a given industry at
any time. However, DOE notes that the purpose of the rulemaking process
is to engage stakeholders. While notices have specific comment dates by
which comments are due, stakeholders may submit material to the
rulemaking docket at any time during the course of the rulemaking by
contacting the DOE program manager.
II. Synopsis of the Notice of Proposed Rulemaking
In this NOPR, DOE is proposing to:
(1) Expand the scope of the test procedure to include additional
clean water pumps, specifically:
(a) Between-bearing (``BB'') pumps;
(b) radially-split, multi-stage, horizontal,
(c) in-line diffuser casing (``RSHIL'') pumps;
(d) radially-split, multi-stage, horizontal, end-suction diffuser
casing (``RSHES'') pumps;
(e) small vertical in-line (``SVIL'') pumps;
(f) vertical turbine (``VT'') pumps;
(g) pumps sold with 6-pole induction motors or motors with design
speeds between 960 rpm and 1,440 rpm;
(h) submersible turbine (``ST'') pumps with bowl diameters larger
than 6 inches; and
(i) end-suction pumps not covered by the current test procedure;
(2) Clarify the applicability of the design temperature range scope
limitation and modify the range parameters;
(3) Add and modify certain definitions in 10 CFR 431.462 to
accommodate the expansion of scope and clarify existing definitions;
(4) Incorporate by reference HI 40.6-2021 into 10 CFR 431.463 and
make minor revisions to the test procedure to address provisions in the
current DOE test procedure that have been added to HI 40.6-2021;
(5) Remove the incorporations by reference of ANSI/HI 1.1-1.2-2014
and ANSI/HI 2.1-2.2-2014;
(6) Add specifications for stages for testing for expanded scope
multi-stage pumps;
(7) Clarify test provisions for pumps with BEP at run-out;
(8) Clarify test provisions for calibration of measurement
equipment;
(9) Update part-load loss factor equation coefficients in the
calculation method for pumps sold with induction motors and controls;
(10) Provide a calculation method for pumps sold with inverter-only
motors;
(11) Update the test procedure for submersible pumps to address
proposed DOE coverage of submersible motors;
(12) Update the test procedure to address SVIL pumps;
(13) Add provisions for testing and rating pumps sold with a 6-pole
induction motor or with design speeds between 960 rpm and 1,440 rpm;
and
(14) Allow use of Alternative Efficiency Determination Methods
(``AEDMs'').
DOE's proposed actions are summarized in Table II.1 compared to the
current test procedure as well as the reason for the proposed change.
BILLING CODE 6450-01-P
[[Page 21272]]
[GRAPHIC] [TIFF OMITTED] TP11AP22.001
[[Page 21273]]
[GRAPHIC] [TIFF OMITTED] TP11AP22.002
BILLING CODE 6450-01-C
DOE has tentatively determined that the proposed amendments
described in section III of this NOPR would not alter the measured
efficiency of commercial and industrial pumps that are currently
included in the scope of DOE's energy conservation standards for pumps.
Therefore, DOE does not expect that retesting or recertification would
be necessary for currently certified pumps as a result of DOE's
adoption of the proposed amendments to the test procedures, if made
final. Additionally, DOE has tentatively determined that the proposed
amendments, if made final, would not increase the cost of testing for
these pumps. As such, for pumps currently within the scope of DOE's
energy conservation standards, any representations regarding the energy
consumption of a pump or the cost of energy consumed by a pump would
have to be made in accordance with the amended test procedure beginning
180 days after publication of the final rule. (42 U.S.C. 6314(d))
For pumps that are not currently within the scope of the test
procedure and are not currently required to certify pump energy use,
DOE is proposing that the test requirements proposed in appendix A, if
adopted, would take place on the compliance date of amended energy
conservation standards for pumps that DOE may ultimately decide to
adopt as part of a separate rulemaking assessing the technological
feasibility and economic justification for such standards. In other
words, for pumps that DOE is proposing to include in the scope of the
proposed test procedure, manufacturers would need to use the results of
testing under appendix A to determine compliance with any new energy
conservation standards that DOE may establish for these pumps.
Discussion of DOE's proposed actions are addressed in detail in
section III of this NOPR.
III. Discussion
In the following sections, DOE proposes certain amendments to its
test procedures for pumps. For each proposed amendment, DOE provides
relevant background information, explains why the amendment merits
consideration, discusses relevant public comments, and proposes a
potential approach.
A. Scope of Applicability
The current DOE test procedure for pumps applies to five categories
of ``clean water pumps'' with specific defined characteristics, and
excludes certain defined categories \11\ of pumps. 10 CFR
431.464(a)(1).
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\11\ The excluded categories of pumps are fire pumps; self-
priming pumps; prime-assist pumps; magnet driven pumps; pumps
designed to be used in a nuclear facility subject to 10 CFR part 50,
``Domestic Licensing of Production and Utilization Facilities''; and
pumps meeting the design and construction requirements set forth in
Military Specifications: MIL-P-17639F, ``Pumps, Centrifugal,
Miscellaneous Service, Naval Shipboard Use'' (as amended); MIL-P-
17881D, ``Pumps, Centrifugal, Boiler Feed, (Multi-Stage)'' (as
amended); MIL-P-17840C, ``Pumps, Centrifugal, Close-Coupled, Navy
Standard (For Surface Ship Application)'' (as amended); MIL-P-
18682D, ``Pump, Centrifugal, Main Condenser Circulating, Naval
Shipboard'' (as amended); and MIL-P-18472G, ``Pumps, Centrifugal,
Condensate, Feed Booster, Waste Heat Boiler, And Distilling Plant''
(as amended). 10 CFR 431.464(a)(1)(iii).
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DOE defines ``clean water pump'' as a pump that is designed for use
in pumping water with a maximum non-absorbent free solid content of
0.016 pounds per cubic foot, and with a maximum dissolved solid content
of 3.1 pounds per cubic foot, provided that the total gas content of
the water does not exceed the saturation volume, and disregarding any
additives necessary to prevent the water from freezing at a minimum of
14 [deg]F. 10 CFR 431.462.
The five categories of clean water pumps to which the current test
procedure applies are: End-suction close-coupled (``ESCC''); end-
suction frame mounted/own bearings (``ESFM''); in-line (``IL'');
radially-split, multi-stage, vertical, in-line diffuser casing
(``RSV''); and submersible turbine (``ST''). 10 CFR 431.464(a)(1)(i).
The defined characteristics specify limits on flow rate, maximum head,
design temperature range, motor type, bowl diameter, and speed.\12\ 10
CFR 431.464(a)(1)(ii). In the context of the energy conservation
standards, pumps are further delineated into equipment classes based on
nominal speed of rotation and operating mode (i.e., constant load or
variable load). 10 CFR 431.465.
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\12\ More specifically, these characteristics include: (A) flow
rate of 25 gpm or greater at BEP and full impeller diameter; (B)
maximum head of 459 feet at BEP and full impeller diameter and the
number of stages required for testing; (C) design temperature range
from 14 to 248 [deg]F; (D) designed to operate with either (1) a 2-
or 4-pole induction motor, or (2) a non-induction motor with a speed
of rotation operating range that includes speeds of rotation between
2,880 and 4,320 revolutions per minute (rpm) and/or 1,440 and 2,160
rpm, and in either case, the driver and impeller must rotate at the
same speed; (E) For ST pumps, a 6-inch or smaller bowl diameter; and
(F) For ESCC and ESFM pumps, a specific speed less than or equal to
5,000 when calculated using U.S. customary units. 10 CFR
431.464(a)(1)(ii).
---------------------------------------------------------------------------
In the April 2021 RFI, DOE requested comment on the percentage of
pump models that fall within the scope of DOE's current test procedure.
86 FR 20075, 20079. Additionally, DOE also sought information regarding
how manufacturers communicated performance in catalogs and other
related literature for out-of-scope pumps. Id. DOE also requested
shipment and market performance data for SVIL pumps, pumps operating
with motors at speeds different than 1,800 rpm or 3,600 rpm,
submersible turbine pumps with a bowl diameter greater than 6 inches,
and other pumps that are currently excluded from scope based on the
pump characteristics provided at 10 CFR 431.464(a)(1)(ii). Id.
In response, Grundfos generally recommended that an expansion to
the
[[Page 21274]]
pumps test procedure scope should be addressed through a negotiated
rulemaking process. (Grundfos, No. 17 at p. 3) Similarly, HI commented
that manufacturers and other stakeholders should be involved in
creating new pump categories. (HI, No. 20 at p. 3) HI also stated that
significant changes to the test procedure and scope may lead to market
confusion and result in additional testing burden (HI, No. 20 at p. 1)
DOE notes that it published a notice on October 29, 2021 announcing a
meeting of the Appliance Standards and Rulemaking Federal Advisory
Committee (``ASRAC'') held on December 14, 2021 to discuss and
prioritize topic areas for which ASRAC can assist the Appliance and
Equipment Standards Program. 86 FR 60020. At this meeting, pumps
themselves were not suggested as a category for negotiation, but
extended equipment systems (i.e., motor, drive, and driven load)
inclusive of the pump were discussed for possible negotiation.
Summit responded that eight percent of their models are within
scope of the DOE test procedure and that pump performance information
is published in catalogs, pump curves, and brochures. (Summit, No. 16
at p. 3) Additionally, Summit stated that all in-scope pumps are
labeled as meeting the DOE standard. Id. Grundfos stated that it has 27
basic models that it does not certify based on the scope limitations in
the DOE test procedure. (Grundfos, No. 17 at p. 2) HI estimated that
approximately 14 percent of manufacturer basic models would not be
included in the scope of the current DOE standards because they are
SVILs or because of the limitations included in 10 CFR
431.464(a)(1)(ii). (HI, No. 20 at p. 3) HI also stated that for
products not within scope, manufacturers generally do not make
representations of the pump energy index (``PEI'') value. (HI, No. 20
at p. 3) NEEA stated that it found that 16 percent of pumps reported by
distributors (which are typically heating, ventilation, and air
conditioning (``HVAC'') and domestic water equipment companies) are not
included in DOE's current test procedure scope. (NEEA, No. 21 at p. 3)
NEEA asserted that nearly all of the pumps sold by these distributors
pump clean water and therefore should be in scope. Id.
Although stakeholders did not respond to DOE's request for data on
pumps operating with motors at speeds other than 1,800 rotations per
minute (``rpm'') or 3,600 rpm in the April 2021 RFI, DOE did receive
comments on this issue in response to the August 9, 2021 pumps energy
conservation standards early assessment review RFI (``August 2021 ECS
RFI'', Docket EERE-2021-BT-STD-0018, No. 1). 86 FR 43430. Specifically,
the CA IOUs stated that for one pump distributor, 27 percent of its
commercial pump sales were either pumps with motors running at 1,200
rpm or double suction pumps \13\ (both of which are not included in the
scope of DOE's current test procedure). (CA IOUs, Docket EERE-2021-BT-
STD-0018, No. 10 at p. 3)
---------------------------------------------------------------------------
\13\ A double-suction pump is one whose impeller is designed to
draw flow from both sides, as opposed to a single-suction pump whose
impeller only draws flow from one side.
---------------------------------------------------------------------------
DOE considered expanding scope to the following pump categories:
Chemical process and wastewater pumps, small vertical inline pumps,
certain additional clean water pumps (between-bearing, vertical
suction, radially-split, multi-stage horizontal, line shaft and
cantilever pumps), and pumps sold with motors that operate at 1,200
rpm. The following sections provide additional information and
responses to stakeholder comments specific to the pumps that DOE
considered for inclusion in the test procedure scope.
DOE notes that it is proposing changes to the current test
procedure applicable to currently regulated pumps. Any representations
regarding the energy consumption of these pumps or the cost of energy
consumed by these pumps would have to be made in accordance with the
amended test procedure beginning 180 days after publication of the
final rule. (42 U.S.C. 6314(d)) The proposed changes to the test
procedure would also apply to those pumps that DOE is proposing to
include in its scope; however, for these pumps, the revised test
procedure would be required in conjunction with the compliance date of
any future amended energy conservation standards that DOE may set.
1. Pumps Not Designed for Clean Water Applications
The scope of the current DOE test procedure, as described
previously, excludes both chemical process and wastewater pumps. See 10
CFR 431.464(a)(1)(i). Chemical process pumps are designed to pump
fluids other than water, and wastewater pumps are designed for water
with a higher level of free solids than clean water pumps.
In response to the April 2021 RFI, NEEA stated that there is
functional overlap between pumps that are within the scope of the
current DOE test procedure and those pumps that are excluded because
they are certified under ASME/ANSI B73. (NEEA, No. 21 at p. 6) NEEA
also stated that distributors report that a ``significant portion'' of
ASME/ANSI B73 pumps are installed in clean water applications and that
without this certification designation these pumps would be included in
the scope for the DOE test procedure. Id. Summit stated that if DOE
were to include ASME/ANSI B73 pumps within scope of the DOE test
procedure, 80 percent of their pumps would be covered rather than the
eight percent currently covered. (Summit, No. 16 at p. 4) ASAP and NRDC
recommended that DOE consider how the DOE test procedure could
facilitate greater market adoption of wastewater pumps with variable-
speed drives, similar to what has been done for clean water pumps.
(ASAP and NRDC, No. 18 at p. 2)
DOE also received comments pertaining to non-clean water pumps in
the August 2021 ECS RFI. HI stated that the current definition of clean
water pumps and the exclusion of non-clean water pumps from the test
procedure scope aligns with regulations in both Canada and the EU. (HI,
Docket EERE-2021-BT-STD-0018, No. 8 at p. 2) HI asserted that
maintaining harmonization between the United States, Canada and the EU
is important to minimize burden for manufacturers that distribute their
pumps outside of the U.S. Id. HI stated that a large number of
additional pump categories would need to be added to the DOE test
procedure in order to appropriately characterize non-clean water pumps.
Id. HI explained that there is not a clear distinction between a pump
being designed for clean water or for wastewater or chemicals. Instead,
HI explained that pump designs constitute a range of operation based on
a liquid's chemical compatibility and containment requirements, in
addition to the concentration, and hardness of the solids being pumped.
Id. HI stated that it was not aware of any established definitions that
characterize non-clean water pumps into unique groupings, and that any
definitions would need to define each pump group and include distinct
design features that affect their efficiency. Id. HI stated that DOE
would need to establish many definitions and classes for non-clean
water pumps to accurately develop standards. Id. HI also commented that
the specificity necessary to group pumps with similar design options
and loss characteristics would leave little data in each category to
develop C-values, making it difficult to develop energy conservation
standards. Id. Finally, HI stated that
[[Page 21275]]
ASME/American Petroleum Institute, solids handling, slurry, positive
displacement, and magnet driven pumps could not be tested with the HI
40.6 standard. (HI, Docket EERE-2021-BT-STD-0018, No. 8 at p. 4)
Also in response to the August 2021 ECS RFI, Grundfos recommended
against expanding the DOE scope beyond clean water pumps, asserting
that uses for pumping other fluids are too varied. (Grundfos, Docket
EERE-2021-BT-STD-0018, No. 9 at p. 2)
DOE acknowledges that certain non-clean water pumps may be used in
clean water applications; however, DOE expects the number of non-clean
water pumps used in the clean water applications to be relatively
small. DOE notes that the scope of HI 40.6-2014, which is currently
incorporated by reference into the DOE test procedure, includes clean
water pumps only. The scope of the HI 40.6 standard changed in the 2016
version to state that the standard covers pumps that are included in
DOE's energy conservation standards and therefore does not provide
requirements for testing pumps designed for non-clean water
applications. The scope of HI 40.6-2021 is identical to that of HI
40.6-2016. To test non-clean water pumps, DOE would need to reference
or develop an alternate test procedure. While this test procedure might
enable comparison between non-clean water pumps, it is unlikely that a
clean water and non-clean water test procedure would provide comparable
results.
Additionally, DOE notes that non-clean water pumps, specifically
wastewater pumps, must meet specific performance requirements to ensure
the health of the U.S. population. DOE would need to carefully evaluate
how the performance of non-clean water pumps could be impacted by
energy conservation standards and ensure that public health and safety
would not be negatively affected. As such, additional investigation is
needed to understand the market, energy savings potential, test
procedure implications, and performance requirements of non-clean water
pumps (i.e., chemical process and wastewater). DOE notes that because
``C-value'' is specified in the energy conservation standard (see 10
CFR 431.465(b)(4)) and C-value is required for determining
PEI<INF>CL</INF> and PEI<INF>VL</INF>, there would be limited use of
the test procedure without corresponding standards. Therefore, DOE has
determined that it will continue to limit the applicability of this
test procedure to clean water pumps at this time.
2. Small Vertical Inline Pumps
As discussed, the scope of the current DOE test procedure is
limited to five categories of pumps designed for clean water
applications. 10 CFR 431.464(a)(1)(i). One of these categories is in-
line (IL) pumps, which are limited to shaft input power greater than or
equal to 1 hp and less than or equal to 200 hp at BEP and full impeller
diameter, and in which liquid is discharged in a plane perpendicular to
the impeller shaft. 10 CFR 431.462. In 2016, a Circulator Pump Working
Group \14\ recommended a test procedure and energy conservation
standard for circulator pumps, which DOE is addressing in a separate
rulemaking, and also made recommendations for SVIL pumps. SVIL pumps
have characteristics identical to those for in-line pumps but SVIL
pumps have shaft input power of less than 1 hp. The Circulator Pump
Working Group recommended that (1) SVIL pumps be evaluated using the
PEI<INF>CL</INF> or PEI<INF>VL</INF> metric, and (2) SVIL pumps should
be tested using the DOE pump test procedure, with any needed
modifications determined by DOE. (Docket No. EERE-2016-BT-STD-0004, No.
58 Recommendation #1B at pp. 1-2)
---------------------------------------------------------------------------
\14\ On February 3, 2016, DOE published its intention to
establish a working group under the Appliance Standards and
Rulemaking Federal Advisory Committee (``ASRAC'') to negotiate a
test procedure and energy conservation standards for circulator
pumps. 81 FR 5658. Throughout this document this working group shall
be referred to as ``the Circulator Pumps working Group''.
---------------------------------------------------------------------------
In response to the April 2021 RFI, NEEA, Grundfos, ASAP and NRDC,
the CA IOUs, and HI recommended that DOE address SVIL pumps in the
commercial and industrial pumps test procedure and energy conservation
standards rulemakings, rather than in a rulemaking for circulator pumps
(NEEA, No. 21 at p.7; Grundfos, No. 17 at p. 3; ASAP and NRDC, No. 18
at p. 2; CA IOUs No. 19 at p. 11; HI, No. 20 at p. 3) NEEA stated that
there is confusion in the market as to whether SVIL pumps are subject
to the DOE test procedure and energy conservation standards, and that
SVIL pumps may be in the same family as, or have overlapping pump
curves with, larger pumps that are currently subject to the test
procedure and standards. (NEEA, No. 21 at p. 6) NEEA also stated that
there is a trend in the HVAC industry to move away from distributing
large central pumps to distributing smaller pumps, and that therefore
unregulated SVIL pumps compete with larger regulated pumps. Id.
DOE also received comments relative to SVIL pumps in the August
2021 ECS RFI. The CA IOUs stated that in discussions with distributors,
one recommended adding fractional SVIL pumps to the scope of regulated
equipment. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 5)
According to the CA IOUs, this distributor stated that the lack of
coverage currently causes confusion since some pumps within a given
product line are covered and some are not. Id . For example, 7 percent
of Taco's SVIL pump sales are fractional horsepower (``hp'') and are
therefore uncovered.\15\ Id. The CA IOUs also reported that SVIL pump
use in hydronic HVAC systems is increasing and asserted that this means
that SVIL pumps are competing with larger regulated pumps. Id.
---------------------------------------------------------------------------
\15\ The use of the term SVIL here implies such pumps can be
over 1 horsepower. The current DOE definition of in-line (``IL'')
pumps, and the proposed definition of SVIL in section I.B.6 clarify
that IL pumps under one horsepower are SVIL pumps. DOE assumes that
the comment may have intended that 7 percent of IL pumps are SVIL
pumps.
---------------------------------------------------------------------------
Finally, DOE received comments relative to SVIL pumps in the May 7,
2021 Circulator Pumps Test Procedure and Energy Conservation Standard
RFI (``May 2021 Circulator Pumps RFI''). 86 FR 24516, 24521. The CA
IOUs supported NEEA's comments on SVIL pumps from the April 2021 RFI.
(CA IOUs, Docket EERE-2016-BT-STD-0004, No. 116 at p. 6) The CA IOUs
supported the incorporation and development of SVIL pump standards
based on the PEI metric. Id.
In the April 2021 RFI, DOE also requested shipment and market
performance data for SVIL pumps. 86 FR 20075, 20079. In response,
Grundfos and HI recommended that DOE conduct manufacturer interviews to
obtain specific market performance data. (Grundfos, No. 17 at p. 3; HI,
No. 20 at p. 4)
Issue 1: Consistent with the Circulator Pump Working Group
recommendation and based on the concerns expressed in the comments
summarized above regarding SVILs being a part of the same model family
as IL pumps and serving as an unregulated alternative to pumps
currently subject to DOE test procedures and energy conservation
standards, DOE proposes to include SVIL pumps within the test
procedure's scope. DOE has tentatively determined that SVIL pumps can
be tested using the current DOE pumps test procedure with certain
additional modifications. The proposed test procedure and metric for
SVIL pumps are discussed in sections III.G
[[Page 21276]]
and III.D of this NOPR. Moreover, DOE expects that including SVIL pumps
within the scope of the pumps test procedure would reduce confusion
over which inline pumps are and are not regulated. DOE requests comment
on its proposal to expand the scope of the test procedure to cover SVIL
pumps.
3. Other Clean Water Pump Categories
In the April 2021 RFI, DOE requested comment on whether the five
pump categories currently included in DOE's regulations sufficiently
represent the market and technology available for clean water pumps;
whether these categories are sufficiently defined in order to ensure
that the categories are mutually exclusive; or whether any of these
categories or descriptions should be amended. 86 FR 20075, 20078.
In response to DOE's request for comment in the April 2021 RFI,
Grundfos and HI supported the current pump equipment categories, and
Grundfos stated that these pump categories represent the current
market. (Grundfos, No. 17 at p. 1; HI, No. 20 at p. 2) NEEA and ASAP
and NRDC recommended that DOE expand the scope of the pumps test
procedure to cover additional pumps used in clean water applications.
(ASAP and NRDC, No. 18 at p. 1; NEEA, No. 21 at p. 2) NEEA identified
four categories of pumps that it stated may have overlapping uses and
therefore may compete with pumps that are currently within scope of DOE
regulations; specifically: Single and two stage axially-split pumps,
end-suction multi-stage pumps, vertical turbine pumps, and American
Society of Mechanical Engineers (``ASME'')/ANSI B73 certified
pumps,\16\ (NEEA, No. 21 at p. 2) NEEA stated that having similar pumps
that compete in the market but that do not use PEI as a performance
metric is confusing for distributors and end users. (NEEA, No. 21 at p.
3) NEEA reiterated its points about pump scope expansion in its
comments to the August 2021 ECS RFI. (NEEA, Docket EERE-2021-BT-STD-
0018, No. 11 at p. 2)
---------------------------------------------------------------------------
\16\ Pumps certified under the ASME B73 designation include:
B73.1 (``Specification for Horizontal End-suction Centrifugal Pumps
for Chemical Process''), B73.2 (``Specification for Vertical In-Line
Centrifugal Pumps for Chemical Process''), B73.3 (``Specification
for Sealless Horizontal End-suction Centrifugal Pumps for Chemical
Process''), and B73.5 (``Thermoplastic/thermoset Polymer Material
Horizontal End-suction Centrifugal Pumps Chemical Process''). All
B73 pumps are designed for use as chemical process pumps, which have
specific design requirements related to reliability and performance
such as maximum shaft deflections, bearing frame lubrication,
sealing requirements, and vibration limits.
---------------------------------------------------------------------------
Similarly, ASAP and NRDC recommended adding double suction pumps,
multi-stage end-suction pumps, vertical turbine pumps, and pumps tested
at a nominal speed of 1,200 rpm. (ASAP and NRDC, No. 18 at p. 2) ASAP
and NRDC stated that this would ensure consistent pump efficiency
information is available for purchasers. (ASAP and NRDC, No. 18 at p.
1) ASAP and NRDC additionally commented that some unregulated pumps can
be used in the same applications as some regulated pumps. Id. ASAP and
NRDC contended that including additional pump categories in the test
procedure scope would provide a more level playing field for
manufacturers. Id. In response to the August 2021 ECS RFI, ASAP and
NRDC reiterated the points they made in response to the April 2021 RFI.
(ASAP and NRDC, Docket EERE-2021-BT-STD-0018, No. 7 at pp. 1-2)
In response to the August 2021 ECS RFI, the CA IOUs supported
NEEA's recommendation to expand the scope of the pumps test procedure
to the four categories listed above. (CA IOUs, Docket EERE-2021-BT-STD-
0018, No. 10 at p. 2) Grundfos stated that DOE should limit its focus
of scope expansion to radially-split multi-stage horizontal pumps; and
that positive displacement, axial/mixed flow, double suction, multi-
stage axially-split, multi-stage radial split vertical immersible, non-
submersible vertical turbine, and VS4/VS5 pumps \17\ should remain
excluded from the DOE scope. (Grundfos, Docket EERE-2021-BT-STD-0018,
No. 9 at pp. 1-2) HI commented that DOE should not expand the scope of
its regulation to either non-clean water pumps or to clean water pumps
that may serve diverse markets and applications and therefore may have
multiple design variants within each pump type. (HI, Docket EERE-2021-
BT-STD-0018, No. 8 at p. 1). Additionally, HI stated that significant
changes to the scope would cause market confusion since current
standards and labeling requirements for pumps went into effect only
recently in early 2020. Id.
---------------------------------------------------------------------------
\17\ VS4 and VS5 are pump categories defined in HI 14.1-14.2-
2019 that both refer to vertically separate discharge pumps. VS4
pumps are line shaft pumps and VS5 pumps are cantilever pumps.
---------------------------------------------------------------------------
The following sections discuss DOE's consideration of additional
categories of clean water pumps within the scope of the test procedure,
including the specific categories suggested by commenters.
a. Between-Bearing Pumps
Section 1.2.9.2 of ANSI-HI 14.1-14.2-2019 describes between-bearing
(``BB'') pumps as pumps that are one- or two-stage, axially-split,
mounted to a baseplate, driven by a motor via a flexible coupling, and
with bearings on both ends of the rotating assembly.
In the April 2021 RFI, DOE requested comment on whether pumps that
meet the description of BB pumps might fall within the current test
procedure scope and if BB pumps could be tested with the current DOE
test procedure. 86 FR 20075, 20079. In response, ASAP and NRDC and NEEA
recommended evaluating double suction pumps for inclusion in the test
standards, and stated that most of these pumps are BB1 pumps,\18\ many
are used in chilled clean water applications, and these pumps are often
below 200 hp. (ASAP and NRDC, No. 18 at p. 1; NEEA, No. 21 at p. 2) In
addition, DOE understands that NEEA's recommendation that DOE cover
single and two-stage axially-split pumps to also refer to BB1 pumps.
The CA IOUs also seemed to offer support for NEEA's comments. (CA IOUs,
No. 19 at pp. 10-11)
---------------------------------------------------------------------------
\18\ BB1 pumps are a pump class defined by HI 14.1-14.2-2019
that are 1 and 2 stage, axially-split pumps with the impeller(s)
mounted between bearings at either end. BB1 pumps are a specific
sub-category of BB pumps.
---------------------------------------------------------------------------
Summit and Grundfos recommended a new category of double suction
pumps/between-bearing pumps if DOE decides to expand its scope beyond
clean water pumps. (Summit, No. 16 at p. 2; Grundfos, No. 17 at p. 4)
Additionally, Grundfos specifically stated that BB1 pumps have
different inlet/outlet configurations and losses when compared to IL
pumps that are currently within the scope of the DOE test procedure.
(Grundfos, No. 17 at p. 4) Summit stated that although they supply BB
pumps, none are used in clean water applications, and that testing
these pumps would be burdensome. (Summit, No. 16 at p. 3) Grundfos and
HI commented that some BB1 pumps are designed for clean water
applications and may be rated under 200 hp. (Grundfos, No. 17 at p. 3-
4; HI, No. 20 at p. 4) Grundfos agreed that BB1 pumps can be tested
according to the current DOE test procedure. (Grundfos, No. 17 at p. 4)
While HI also agreed that BB1 pumps can be tested according to the DOE
test procedure, they stated that BB1 pumps do not share the same
physical and functional characteristics affecting energy consumption of
any pump category currently defined by DOE. (HI, No. 20 at p. 4)
[[Page 21277]]
DOE also received comments on the August 2021 ECS RFI relevant to
BB pumps. The CA IOUs stated that in discussions with distributors, two
distributors suggested that split case and double suction pumps should
be included in the scope of the pumps rulemaking. (CA IOUs, Docket
EERE-2021-BT-STD-0018, No. 10 at p. 3) It is DOE's understanding that
the recommendations to include split case and double suction pumps
refer to BB pumps, since these two characteristics synonymous with
between-bearing pumps.
Based on a review of the market, BB pumps tend to generally be
larger than the pumps currently subject to the DOE test procedure. Many
BB pumps exceed the head and horsepower limits in the current DOE test
procedure. Additionally, BB pumps are not typically designed for clean
water applications. Despite these generalities, DOE has identified
certain clean water BB pumps under 200 hp and 459 feet of head that
could be viewed as potentially interchangeable with those pumps that
fall within the scope of the current DOE test procedure.
In order to address the potential for pumps that provide
unregulated alternatives to the pumps currently subject to the DOE test
procedure, DOE proposes to include BB pumps within the scope of the DOE
test procedure. However, DOE does not propose to expand beyond clean
water pumps and does not propose to expand the head or horsepower
limitations currently listed in 10 CFR 431.464(1)(ii). Additional
investigation is needed to understand the market, energy savings
potential, test procedure implications, and performance requirements of
non-clean water pumps. DOE has determined that it will continue to
limit the applicability of this test procedure to clean water pumps at
this time. An expansion of the head and horsepower restrictions has the
potential to increase test burden by requiring larger laboratory
equipment to test pumps according to the DOE test procedure. Through
its literature review DOE has found few BB pumps that exceed the head
and horsepower limits and are designed for clean water, leading DOE to
tentatively determine that the burden of expanding head and horsepower
restrictions outweigh the benefits of expanded scope.
Based on stakeholder comments, literature reviews, and reviews of
pump schematics, DOE has tentatively determined that BB pumps can be
tested using the methodology in HI 40.6-2021; therefore, DOE is not
proposing any modifications specific to testing BB pumps in this test
procedure NOPR.
Specific proposals for a definition of BB pumps are detailed in
section III.B.5 of this document.
Issue 2: DOE requests comment on its proposal to expand the current
test procedure's scope to include BB pumps. Additionally, DOE requests
comment on the repeatability and representativeness of testing BB pumps
using the current DOE test procedure. DOE also requests comment on any
additional burdens associated with testing BB pumps that are different
from those burdens associated with pumps currently covered by the DOE
test procedure.
b. Vertical Turbine Pumps
Section 1.3.3.1.2 of HI 14.1-14.2-2019 defines VS1 and VS2 pumps as
vertically suspended, wet pit pumps with a single casing and discharge
through the suspension column. VS1 pumps use a diffuser, while VS2 use
a volute.\19\ VS1 and VS2 pumps are generally known as vertical turbine
pumps. These pumps are generally not designed for clean water
applications, and often exceed head and horsepower limits laid out in
the current test procedure.
---------------------------------------------------------------------------
\19\ Both diffusers and volutes diffuse velocity energy into
pressure as the flow exits a pump's impeller. A volute is a one or
two scroll shaped diffusing passageway, while a diffuser is
characterized by many radially-symmetric diffusing passageways.
---------------------------------------------------------------------------
In response to the April 2021 RFI, DOE received comments from ASAP
and NRDC and NEEA recommending the inclusion of vertical turbine pumps
in the scope of the current DOE test procedure. (ASAP and NRDC, No. 18
at pp. 1-2; NEEA, No. 21 at p. 2) NEEA stated that these pumps present
a compliance loophole in DOE's pump regulations and create market
confusion. (NEEA, No. 21 at pp. 2-3) The CA IOUs encouraged DOE to
evaluate vertical turbine pumps for inclusion in the test procedure.
(CA IOUs, No. 19 at p. 11)
Based on a review of literature, DOE has tentatively determined
that ST pumps and vertical turbine pumps have similar end uses.
Additionally, DOE has tentatively determined that ST and vertical
turbine pumps have similar bowl and impeller assemblies, and that
vertical turbine pumps may even share an identical assembly with an ST
pump produced by the same manufacturer. To address the potential of
pumps that provide unregulated alternatives to the pumps currently
subject to the DOE test procedure, DOE proposes to include vertical
turbine pumps within the scope of the DOE test procedure. However, as
discussed previously, DOE does not propose to expand beyond clean water
pumps and does not propose to expand the head or horsepower limitations
currently listed in 10 CFR 431.464(1)(ii). An expansion of the head and
horsepower restrictions has the potential to increase test burden by
requiring larger laboratory equipment to test pumps according to the
DOE test procedure. Through its literature review, DOE has found few
vertical turbine pumps that exceed the head and horsepower limits and
are designed for clean water. Therefore, DOE has tentatively determined
that the burden of expanding head and horsepower restrictions outweigh
the benefits of expanded scope.
Based on literature reviews and reviews of pump schematics, DOE has
tentatively determined that vertical turbine pumps can be tested using
the methodology in HI 40.6-2021; therefore, DOE is not proposing any
modifications specific to testing vertical turbine pumps in this test
procedure NOPR.
Specific proposals for a definition of VT pumps are detailed in
section III.B.6 of this document.
Issue 3: DOE requests comment on its proposal to expand the current
test procedure's scope to include VT pumps. Additionally, DOE requests
comment on the repeatability and representativeness of testing VT pumps
using the current DOE test procedure. DOE also requests comment on any
additional burdens associated with testing VT pumps that differ from
those burdens associated with pumps currently covered by the DOE test
procedure.
c. Radially-Split Multi-Stage Horizontal Pumps
The current scope of the DOE test procedure includes radially-
split, multi-stage, vertical, in-line casing diffuser (RSV) pumps, but
does not include radially-split horizontal pumps, which are also
multistage pumps used primarily in heating, cooling, and pressure
boosting applications. In response to the April 2021 RFI, NEEA and ASAP
and NRDC recommended that multi-stage end-suction pumps (specifically
OH1j, OH7j, and OH13j) \20\ should be included in the scope of the
pumps test procedure. (NEEA, No. 21 at p. 2; ASAP and NRDC, No. 18 at
p. 1) The CA IOUs supported NEEA's comment and recommended that DOE
evaluate multi-stage end-suction pumps
[[Page 21278]]
for inclusion in the pumps test procedure. (CA IOUs, No. 19 at p. 10-
11) NEEA additionally stated that multi-stage end-suction pumps are
often in direct competition with RSV pumps in pressure boosting
applications. (NEEA, No. 21 at p. 3) NEEA also provided a list of
applications for multi-stage end-suction pumps to demonstrate the
similarities between these pumps and those that are included in the
scope of the current test procedure. (NEEA, No. 21 at p. 4)
---------------------------------------------------------------------------
\20\ OH1J, OH7J, and OH13J are HI 14.1-14.2-2019 pump class
definitions that refer to the multi-stage versions of OH1, OH7, and
OH13 end-suction pumps. OH pumps are generally classified as
overhung meaning the impeller shaft is only supported by bearings on
one side of the impeller. OH1 pumps are horizontal, flexibly
coupled, and have a centerline mount. OH7 pumps are horizontal and
close coupled. OH13 pumps are horizontal and rigidly/short coupled.
---------------------------------------------------------------------------
DOE also received comments in response to the August 2021 ECS RFI
relevant to multi-stage end-suction pumps. The CA IOUs stated that many
distributors sell water booster pumps, which are often multi-stage end-
suction pumps. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 3)
Grundfos recommended that DOE focus its scope expansions on radially-
split multi-stage horizontal pumps. (Grundfos, Docket EERE-2021-BT-STD-
0018, No. 9 at p. 2) Grundfos also suggested that, like RSV pumps, RSH
pumps should be limited to in-line flow, and that DOE should consider
new categories for multi-stage products that do not have in-line
connections. Id.
DOE has surveyed materials and product literature available online
and has tentatively determined that the multi-stage end-suction pumps
discussed by NEEA, ASAP and NRDC, and the CA IOUs would be classified
as radially-split, multi-stage, horizontal, (``RSH'') end-suction
pumps. DOE's literature survey also tentatively concluded that RSV and
RSH pumps were marketed for similar applications, and that RSH could
therefore serve as an unregulated loophole to RSV pumps. In addition,
through reviews of product literature and HI 14.1-14.2-2019 pump
schematics, DOE has tentatively determined that RSH pumps can be tested
using the current DOE test procedure. Based on DOE's research, DOE
proposes to include RSH pumps with both in-line and end-suction flow
configurations in its test procedure scope. Specific proposals for
definitions or RSH pump categories are detailed in section III.B.7 of
this document.
Issue 4: DOE requests comment on its proposal to expand scope to
include RSH pumps. Additionally, DOE requests comment on the
repeatability and representativeness of testing RSH pumps using the
current DOE test procedure. DOE also requests comment on any additional
burdens associated with testing RSH pumps which are different from
those burdens associated with pumps currently covered by the DOE test
procedure.
d. End-suction Pumps Similar to ESFM and ESCC Pumps
DOE defines a ``close-coupled pump'' as a pump having a motor shaft
that also acts as the impeller shaft, and defines a ``mechanically-
coupled pump'' as a pump that has its own impeller shaft and bearings
separate from the motor shaft. 10 CFR 431.462. As discussed in the
April 2021 RFI, DOE is aware that certain pumps may have their own
shaft, but with no bearings to support that shaft. 86 FR 20075, 20078.
Additionally, while the close-coupled pump definition describes a pump
in which the motor shaft also serves as the pump shaft, the definition
does not provide detail on how the motor and pump shaft may be
connected. DOE has observed that some manufacturers describe close-
coupled pumps as using an adapter to mount the impeller directly to the
motor shaft. The coupling type is the only differentiator between ESCC
pumps, which are ``close-coupled pumps,'' and ESFM pumps, which are
``mechanically-coupled pumps.'' In the January 2016 Final Rule, DOE
noted that it intended for ESFM and ESCC pumps to be mutually exclusive
in order to ensure that pumps that are close-coupled to the motor and
have a single impeller and motor shaft would be part of the ESCC
equipment category, while all other end-suction pumps that are
mechanically-coupled to the motor and for which the bare pump and motor
have separate shafts would be part of the ESFM equipment category. 81
FR 4086, 4096. Despite this intention DOE is aware that these
definitions may have left some end-suction pumps out of scope.
In the April 2021 RFI, DOE requested comment on whether there are
pumps being sold in commerce that may not meet the ``close-coupled'' or
``mechanically-coupled'' definitions but would otherwise meet the
definition for an ``end-suction'' pump. 86 FR 20075, 20078.
HI stated that there are currently pumps that have impellers not
directly connected to the motor shaft, with all pump loads supported by
the motor bearings, which do not meet either the definition of close-
coupled or mechanically-coupled pumps. (HI, No. 20 at p. 3)
Based on HI's response and DOE's review of ESCC and ESFM pumps, DOE
has tentatively determined that there is a group of end-suction pumps
that do not currently fall into either the ESFM or ESCC definition, but
which may be competitors to the currently regulated pumps. Therefore,
DOE proposes to include all end-suction pumps within the coverage of
this test procedure by modifying the definitions of ESFM and ESCC
pumps. The details of this proposal are outlined in section III.B.8 of
this document. DOE has tentatively determined that no test procedure
revisions would be needed to accommodate these additional end-suction
pumps.
Issue 5: DOE requests comment on its tentative determination that
there are certain ends suction pumps excluded from the current test
procedure due to the ESFM and ESCC definitions. DOE also requests
comment on the number of pump models that may fall into this category
and whether they are currently being tested according to the DOE test
procedure.
e. Line Shaft and Cantilever Pumps
ANSI/HI 14.1-14.2-2019 includes design criteria for different pump
configurations, and section 14.1.3.3.1.3 describes vertically separate
discharge sump pumps, a category of pump that includes line shaft
(``VS4'') pumps and cantilever (``VS5'') pumps. Both VS4 and VS5 pumps
are vertically-suspended pumps with a single casing and with a
discharge column that is separate from the shaft column. The pump
equipment categories defined by DOE do not explicitly reference VS4 or
VS5 pumps, and some pumps may be covered by both the DOE definition of
an ESFM pump and the HI definition of a VS4 or VS5 pump. 86 FR 20075,
20079.
In the April 2021 RFI, DOE requested comment on whether the test
procedure should be amended to explicitly address line shaft and
cantilever pumps as described in the ANSI/HI 14.1-14.2-2019. 86 FR
20075, 20079. In response, Grundfos stated that line shaft pumps and
cantilever pumps have designs similar to ESFM and ESCC pumps and that
some are sold for clean water applications. (Grundfos, No. 17 at p. 3)
Grundfos also commented that if DOE were to include line shaft and
cantilever pumps within its scope, DOE should create a new equipment
class since these pumps have different losses, and DOE would need to
define a standard sump depth for testing since these products have a
wide variance in sump depth. Id. HI stated that VS4 and VS5 are not
clean water pumps and therefore there is no need to address their
potential test procedures. (HI, No. 20 at p. 4)
Consistent with the comments from HI, DOE's literature survey
indicates all cantilever pumps are primarily designed for non-clean
water applications including liquids and slurries containing large
solids. Therefore, DOE
[[Page 21279]]
has tentatively determined that it will not expand the scope of its
test procedure to include line shaft or cantilever pumps at this time.
This proposed approach is consistent with DOE's tentative decision not
to expand the current test procedure's scope to pumps designed for non-
clean water applications. DOE agrees that a standard sump depth must be
defined for testing of these products but a representative sump depth
could be determined for the purpose of this test procedure. DOE has
not, however, assessed what a representative depth would be as it is
not proposing a test procedure for line shaft and cantilever pumps.
4. Scope Limitations
Within the categories of clean water pumps included in the current
DOE test procedure and proposed for inclusion in this notice, DOE also
considered potential expansion to scope limitations related to bowl
diameter, nominal speed, horsepower, and design temperature range.
a. Submersible Turbine Pumps With Bowl Diameter Greater Than 6 Inches
As discussed previously, the scope of the current DOE test
procedure includes submersible turbine pumps with a bowl diameter of 6
inches or smaller. 10 CFR 431.464(a)(1)(i)(E) and (a)(1)(ii)(E). In
response to the September 2020 Early Assessment RFI, NEEA listed
submersible turbine (ST) pumps with a bowl diameter greater than 6
inches as an example of pumps that DOE should consider including as
part of an expanded scope. (NEEA, No. 7 at p. 8) NEEA's reasoning was
that pumps within a regulated family may not be rated because they have
a bowl diameter greater than 6 inches.\21\ (NEEA, No. 7 at p. 8) In the
April 2021 RFI, DOE requested shipment data for submersible turbine
pumps with a bowl diameter greater than 6 inches. 86 FR 20075, 20079.
DOE received no shipment information on submersible turbine pumps with
bowl diameters greater than 6 inches.
---------------------------------------------------------------------------
\21\ ST pumps with a bowl diameter greater than 6 inches are
currently excluded from the scope of the DOE test procedure.
---------------------------------------------------------------------------
However, in response to the April 2021 RFI, HI stated that
submersible turbine pumps with a flow rate less than 25 gpm at BEP are
used in residential well applications and should remain out of scope
since they have limited operating time. (HI, No. 20 at p. 3) DOE is not
considering expanding scope to pumps with a flow rate less than 25 gpm
at this time, due to the limitations leading to the current scope
provision. However, DOE understands that flow rate typically increases
with bowl diameter, so it is DOE's understanding that HI's comment is
unrelated to a potential scope expansion to pumps with a bowl diameter
greater than 6 inches.
As discussed in section III.A.3.b, DOE is proposing to include
vertical turbine pumps within the scope of the DOE test procedure.
These pumps are similar in design to ST pumps and commenters have
indicated that the two pump categories can be used in overlapping
applications. Stakeholder comments about the addition of vertical
turbine pumps did not indicate a suggested bowl diameter limitation. As
such DOE is not proposing one. To maintain consistency across pump
categories, and in response to NEEA's early assessment RFI comments,
DOE is proposing to remove the 6-inch bowl diameter limitations for ST
pumps.
Issue 6: DOE requests comment on its proposal to remove the 6-inch
maximum bowl diameter restriction from ST pumps, including whether
there are any testing limitations for larger bowl diameters.
b. Pumps Designed To Be Operated at 1,200 RPM
As discussed, DOE limits the scope of pumps under the current test
procedure to those designed to operate with a 2- or 4-pole induction
motor, or a non-induction motor with an operating range that includes
speeds of rotation between 2,880 and 4,320 rpm and/or 1,440 and 2,160
rpm. 10 CFR 431.464(a)(1)(ii). In either case, the driver and impeller
must rotate at the same speed. 10 CFR 431.464(a)(1)(ii)(D). The current
DOE test procedure does not include pumps designed to operate with 6-
pole induction motors or with non-induction motors that have a speed of
rotation operating range exclusively outside the ranges defined.
In response to the April 2021 RFI, ASAP and NRDC recommended
evaluating pumps sold with 6-pole, 1,200 rpm motors and pumps designed
to be operated at 1,200 rpm. (ASAP and NRDC, No. 18 at pp. 1-2) Summit
stated that if DOE were to expand the nominal motor speeds included in
its test procedure, 1,200 rpm would be the best nominal speed to add.
(Summit, No. 16 at p. 5)
In addition, DOE received comments in response to the August 2021
ECS RFI pertaining to this topic. The CA IOUs stated that it contacted
several distributors, two of whom recommended adding pumps designed to
operate at 1,200 rpm. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at
p. 3) The CA IOUs added that one of these distributors stated that
1,200 rpm pumps have a longer life than higher rpm pumps, while the
other stated that not including them within the test procedure's scope
is confusing to customers. Id.
Based on a review of pump performance curves available online, DOE
has tentatively determined that unregulated pumps tested with a nominal
speed of 1,200 rpm are part of the same pump families as those pumps
that currently fall within the scope of the DOE test procedure.\22\ To
ensure equitable treatment among these pumps, DOE is proposing to
extend the scope of this test procedure to cover pumps designed to
operate with 6-pole induction motors, and pumps designed to operate
with non-induction motors with an operating range that includes speeds
of rotation between 960 rpm and 1,440 rpm.\23\ DOE proposes test
provisions to accommodate these pumps in sections III.E.1 and III.H of
this document.
---------------------------------------------------------------------------
\22\ See <a href="https://www.regulations.gov/document/EERE-2020-BT-TP-0032-0024">https://www.regulations.gov/document/EERE-2020-BT-TP-0032-0024</a>. (Docket No. EERE-2020-BT-TP-0032-0024.)
\23\ 960 and 1440 rpm are <plus-minus> 20 percent of 1,200 rpm.
The acceptable non-induction motor ranges for 1800 and 3600 rpm
pumps are also <plus-minus> 20 percent of the nominal value.
---------------------------------------------------------------------------
Issue 7: DOE requests comment on its proposal to expand the scope
of the test procedure to include pumps designed to operate with a 6-
pole induction motor, and pumps designed to operate with non-induction
motors with an operating range that includes speeds of rotation between
960 rpm and 1,440.
c. Pump Horsepower and Design Speed
As discussed, the current DOE test procedure's scope is limited to
covered pump categories with a 2- or 4-pole induction motor; or a non-
induction motor with an operating range that includes speeds of
rotation between 2,880 and 4,320 rpm and/or between 1,440 and 2,160
rpm, and for which the driver and impeller rotate at the same speed. 10
CFR 431.464(a)(1)(ii)(D). In addition, DOE's definitions for the five
pump categories are limited to pumps with shaft input power greater
than or equal to 1 hp and less than or equal to 200 hp at BEP and full
impeller diameter. 10 CFR 431.462.
DOE received comments on the August 2021 ECS RFI from the CA IOUs,
who stated that in discussions with distributors one stated that some
pumps sold with electronically commutated motors (``ECMs'') and
intended to run at higher speeds, such as 4,320 rpm, must be normalized
to rate at 3,600 rpm and this adjustment causes the power of the
[[Page 21280]]
motor to fall below 1 hp. (CA IOUs, Docket EERE-2021-BT-STD-0018, No.
10 at p. 4) The CA IOUs asserted that this limits purchasers from
comparing PEI<INF>VL</INF> values across product lines. Id. The CA IOUs
argued that this exclusion of ECM pump products from the DOE test
procedure is caused by adjusting operation to the BEP operating point
and does not consider the real-world use of this product, which is
expected to provide similar head and flow as many IL pumps that are
within the scope of the current DOE test procedure. (CA IOUs, Docket
EERE-2021-BT-STD-0018, No. 10 at p. 7) The CA IOUs commented that ECM
pumps would be considered a highly efficient pump, and the
aforementioned test issue limits consumer comparison of these pumps
with non-ECM pumps, which in turn creates a market distortion that will
slow the adoption of more efficient technologies and makes it difficult
for PEI pump rebate programs to include this product subset. Id. The CA
IOUs recommended that DOE revise the inclusion and exclusion criteria
for these products to be based on the driver horsepower of the full
operating window of the unit. Id. The CA IOUs also stated that this
issue might be addressed if SVIL pumps are included in the pumps test
procedure. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 6)
As stated previously, the definitions of the pump categories within
the scope of the test procedure reference horsepower limitations based
on shaft input power at BEP and full impeller diameter. 10 CFR 431.462.
DOE defines ``BEP'' as the pump hydraulic power operating point
(consisting of both flow and head conditions) that results in maximum
efficiency and defines ``full impeller diameter'' as the maximum
impeller diameter with which a given pump basic model is distributed in
commerce. 10 CFR 431.462. DOE's test procedure for pumps at appendix A
to subpart Y of part 431 also includes test provisions for determining
both BEP and pump input power (also known as shaft input power), as
well as provisions for normalizing all measured data to the specified
nominal speed of rotation. As such, while the definitions themselves do
not specify that shaft input power is determined at nominal speed, DOE
understands the CA IOUs concern that the pump definitions could be read
to exclude pumps with shaft input power greater than or equal to 1 HP
at BEP at their design speed, but less than 1 HP when tested and
corrected to nominal speed. In addition, DOE understands that the value
of maximum efficiency varies little with speed, and is often assumed to
be constant, and as such the definition of BEP alone would not be
sufficient to assume that it must be determined at a certain speed
different from that in the test procedure. For these reasons, DOE
believes there could be value in clarifying the current scope
limitations regarding horsepower that are embedded in the pump category
definitions.
However, DOE also notes that, as previously discussed, it is
proposing to expand the current test procedure's scope to include SVIL
pumps, which the CA IOUs noted might address this issue. Specifically,
the proposed inclusion of SVIL pumps would be for fractional horsepower
pumps, so even when corrected to nominal speed, the pumps in question
would be included in scope. DOE understands that use of high frequency
(circa 4,000 rpm) ECMs is likely more prevalent on SVILs than on other
pumps in this horsepower range, particularly as a result of their
applications and competition with the circulator market. This means
that including SVILs in this proposed test procedure would include
most, if not all, pumps where motor power decreases below 1 hp when
rated at BEP. For these reasons, DOE is not proposing to change the
specified horsepower limitations within the pump category definitions
at this time.
Issue 8: DOE requests comment on its tentative determination that
incorporating SVILs into the test procedure will largely eliminate the
issue of higher speed 1 hp pumps falling out of scope when they rate at
a nominal speed of 3600 rpm.
d. Horsepower and Number of Stages for Testing
In response to the April 2021 RFI, Grundfos urged DOE to clarify
how to handle certification of equipment where some equipment is
regulated while others are not and provided the example of an RSV basic
model sold with a 1 horsepower (``hp'') motor tested at 3 stages.
Grundfos continued that if a similar pump is 2-stage and uses a 0.75 hp
motor, it's partially out of scope. Grundfos recommended that equipment
that straddles the scope of the test procedure should be considered to
be out of scope. (Grundfos, No. 17 at p. 10-11)
DOE understands that the same model of RSV pump may be sold with
two stages, three stages, or some other number of stages. DOE's RSV
pump definition includes those pumps that have a shaft input power
greater than or equal to 1 hp and less than or equal to 200 hp at BEP
and full impeller diameter and at the number of stages required for
testing. 10 CFR 431.462. DOE's testing provisions for RSV in section
C.2 of appendix A to subpart Y of part 431 specify that the number of
stages required for testing is three--or, if the basic model is only
available with fewer than three stages, to test the basic model with
the maximum number of stages with which it is distributed in commerce
in the United States. Therefore, the RSV pump model sold with 2 or 3
stages would be included in the scope of the test procedure (and
standards) if it has a shaft input power greater than or equal to 1 hp
when tested at 3 stages, and the resulting PEI would apply to all
stages with which the pump model is sold. For this reason, DOE is not
making any changes to the scope of the test procedure.
e. Design Temperature Range
The current scope for the pumps test procedure is limited to pumps
with a design temperature range between and including 14 to 248 [deg]F.
This range was derived from the original negotiation term sheet for
pumps, which recommended limiting the scope to pumps with a design
range from -10 [deg]C to 120 [deg]C. (Docket EERE-2013-BT-NOC-0039-
0092). For the purposes of its regulations, DOE translated this range
to Fahrenheit. DOE has received inquires as to whether a pump marketed
for temperatures up to 250 [deg]F is outside of the current test
procedure's scope. DOE has reviewed marketing materials for a number of
pumps and found that common upper limits of temperature are 212, 225,
248, 250, and 300 [deg]F. Some marketing materials state that standard
seals may have one high temperature limit while optional seals provide
a higher limit (typically 250 or 300 [deg]F). DOE understands the
original intent of the scope limitation was to exclude pumps designed
exclusively for low or high temperatures from the test procedure.
However, if a manufacturer is offering a pump model across all
temperature ranges in order to minimize SKUs, rather than offering
separate low temperature and high temperature models, DOE considers
that such a pump model should be subject to the regulations. Only pumps
designed and marketed for temperatures exclusively outside the range of
DOE's scope would be excluded from the test procedure and energy
conservation standards. DOE has also recognized that rounding to a
temperature limit of 250 [deg]F when translating from [deg]C to [deg]F
would be preferable to using the exact value of 248 [deg]F since
manufacturers commonly use rounded temperature values in their
marketing materials. Similarly, DOE
[[Page 21281]]
proposes rounding the lower temperature limit from 14 [deg]F to 15
[deg]F.
To clarify the scope of the pumps test procedure and to improve the
enforceability of the regulation, DOE is proposing to change the
wording and the values, such that the scope would include pumps with a
design temperature inclusive of any part of the range from 15 to 250
[deg]F.
Issue 9: DOE seeks comment on its proposal to clarify the scope of
the pumps test procedure with respect to design temperature.
Specifically, DOE requests comment on whether 15 [deg]F and 250 [deg]F
are more appropriate than 14 [deg]F and 248 [deg]F, or whether other
minor adjustments could be made to the range to assist with clarity and
enforceability.
B. Definitions
1. Removing Certain References to Volute
Pumps generally have one of two common discharge types, either a
volute or a diffuser. A volute is made up of one or two scroll-shaped
channels, whereas a diffuser has 3 or more passages that diffuse the
liquid that is being pumped. The current definitions for end-suction
and in-line pumps use the term ``volute,'' when in practice either
volutes or diffusers may be used for these categories of pumps. For
example, DOE's current definition for end-suction pump includes the
following: ``The liquid is discharged through a volute in a plane
perpendicular to the shaft,'' while the definition for ESCC pump, which
is an end suction pump, specifically references OH7 pumps. 10 CFR
431.462. However, Table 14.1.3.7 of HI 14.1-14.2-2019 specifies a
diffuser as the standard casing for OH7 pumps. Similarly, DOE's current
definition for IL pump includes the following: ``in which liquid is
discharged through a volute in a plane perpendicular to the shaft,''
and specifically references OH4 and OH5 pumps as examples of end-
suction pumps. Id. In contrast, Table 14.1.3.7 of HI 14.1-14.2-2019
specifies a diffuser as the standard casing for OH4 and OH5 pumps. DOE
notes that HI 1.1-1.2-2014 did not make these casing distinctions.
DOE interprets the term ``volute'' in its definitions for ``end-
suction pump'' and ``in-line pump'' to mean the part of the pump casing
through which liquid is discharged generally, rather than to reference
a specific type of discharge. To avoid this unintentional inconsistency
between DOE's terminology and the terminology used by the updated
industry standard, DOE proposes to amend the definitions of in-line
pump and end-suction pump to remove the distinction that liquid is
discharged ``through a volute in a plane perpendicular to the shaft''
[emphasis added] by specifying instead that liquid is discharged ``in a
plane perpendicular to the shaft.''
Issue 10: DOE requests comment on the proposed changes to the
definitions for ``in-line pump'' and ``end-suction pump'' to remove the
distinction that liquid is discharged ``through a volute''.
2. HI Pump Class References
The current DOE definitions for ESCC pump, ESFM pump, IL pump, RSV
pump, and ST pump all include references to ANSI/HI 2.1-2.2-2014 pump
configurations as examples of pumps that would meet the given
definition. DOE has tentatively determined that it will be beneficial
if the definitions are self-contained, and that these examples may have
been causing confusion as to which pumps the definitions applied to.
Therefore, DOE proposes to remove references to specific pump
configurations as defined in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-
2014 in the definitions for ESCC, ESFM, IL, RSV, and ST pumps.
Issue 11: DOE requests comment on the proposed changes to the
definitions for ESCC, ESFM, IL, RSV, and ST pumps to remove references
to ANSI/HI 1.1-1.2-2014 pump classes. Specifically, DOE requests
comment on the ability of the modified definitions to clearly
communicate the intended pump categories to industry stake holders.
3. Bowl Diameter
The current DOE definition for ``bowl diameter'' references the
definition of ``intermediate bowl'' in ANSI/HI 2.1-2.2-2014. This is
the sole remaining reference to ANSI/HI 2.1-2.2-2014 in the test
procedure if the proposed changes to eliminate the HI pump class
references are adopted. DOE has tentatively determined it would be more
helpful for readers if the bowl diameter definition was self-contained,
particularly since HI 2.1-2.2-2014 would not be referenced elsewhere.
To disassociate the definition of ``bowl diameter'' from ANSI/HI 2.1-
2.2-2014, DOE is proposing to define ``bowl diameter'' as referring to
``the maximum dimension of an imaginary straight line passing through,
and in the plane of, the circular shape of the intermediate bowl of the
bare pump that is perpendicular to the pump shaft and that intersects
the outermost circular shape of the intermediate bowl of the bare pump
at both of its ends.'' With respect to ``intermediate bowl,'' DOE
proposes to define this term as ``the enclosure within which the
impeller rotates and which serves as a guide for the flow from one
impeller to the next.''
The proposed definitions would be added to 10 CFR 431.462.
Issue 12: DOE requests comment on the proposed change to the
definition of bowl diameter to include a more specific definition of
intermediate bowl instead of referring to the term as defined in ANSI/
HI 1.1-1.2-2014.
4. Small Vertical Inline Pumps
As discussed in section III.A.2, DOE is proposing to expand the
scope of the test procedure to include SVIL pumps, which are identical
to IL pumps except for having a shaft input power less 1 hp. The
Circulator Pump Working Group recommended the following definition for
SVIL pumps:
``Small vertical in-line pump means a single stage, single-axis
flow, dry rotor, rotodynamic pump that: (1) Has a shaft input power
less than 1 hp at best efficiency point at full impeller diameter, (2)
is distributed in commerce with a motor that does not have to be in a
horizontal position to function as designed, and (3) discharges the
pumped liquid through a volute in a plane perpendicular to the shaft.''
(Docket No. EERE-2016-BT-STD-0004, No. 58 Recommendations #3C at p. 3)
In the May 2021 Circulator Pumps RFI, DOE requested comment on the
suitability of the above definition. 86 FR 24516, 24522. In response,
HI and NEEA supported the circulator pumps working group definition of
SVILs. (HI, Docket EERE-2016-BT-STD-0004, No. 112 at p. 4; NEEA, Docket
EERE-2016-BT-STD-0004, No. 115 at p. 4)
The recommended definition would distinguish SVIL pumps from DOE's
current IL pump definition \24\ in that SVIL pumps have a reduced shaft
power input range (IL pump is constrained to greater than or equal to 1
hp and less than or equal to 200 hp; SVIL must be less than 1 hp) and a
different maximum pump power output limitation (IL pump has a limit of
5 hp at BEP; SVIL pumps have no hp limitation). The change to
[[Page 21282]]
shaft input power is the primary distinction between IL and SVIL pumps.
DOE has tentatively determined this distinction is necessary to
adequately separate the two categories. The pump power output is a
consequence of the shaft power limitations. DOE has tentatively
determined that SVIL pumps do not require a 5 hp pump power output
limitation as their shaft input power is already capped below 1 hp.
---------------------------------------------------------------------------
\24\ An ``in-line (IL) pump'' means a pump that is either a
twin-head pump or a single-stage, single-axis flow, dry rotor,
rotodynamic pump that has a shaft input power greater than or equal
to 1 hp and less than or equal to 200 hp at BEP and full impeller
diameter, in which liquid is discharged through a volute in a plane
perpendicular to the shaft. Such pumps do not include pumps that are
mechanically-coupled or close-coupled, have a pump power output that
is less than or equal to 5 hp at BEP at full impeller diameter, and
are distributed in commerce with a horizontal motor. Examples of in-
line pumps include, but are not limited to, pumps within the
specified horsepower range that comply with ANSI/HI nomenclature
OH3, OH4, or OH5, as described in ANSI/HI 1.1-1.2-2014. 10 CFR
431.462.
---------------------------------------------------------------------------
Another difference is that the IL definition includes a group of
three parameters to exclude circulator pumps--namely that they are
either mechanically-coupled or close-coupled, have a pump power output
that is less than or equal to 5 hp at BEP at full impeller diameter,
and are distributed in commerce with a horizontal motor. In contrast,
the recommended SVIL definition is meant to exclude circulator pumps
through clause (2)--i.e., ``related to distribution in commerce with a
motor that does not have to be in a horizontal position to function as
designed.'' On December 20, 2021, DOE published a notice of proposed
rulemaking to establish a test procedure for circulator pumps
(``Circulator Pumps TP NOPR''). 86 FR 72096. In the NOPR, DOE proposed
to define a circulator pump as consisting of a wet rotor circulator
pump; dry rotor, two-piece circulator pump; or dry rotor, three-piece
circulator pumps. The NOPR also included proposed definitions for these
subcategories of circulator pumps. Id. at 86 FR 72139. For clarity, DOE
proposes that for the SVIL definition, rather than including the
recommendation in clause (2), to instead exclude circulator pumps.
Should a test procedure not be finalized for circulator pumps, DOE
could instead finalize an SVIL definition using clause (2). For
consistency, DOE also proposes to revise the IL pump definition to
explicitly include circulator pumps instead of including the clauses
meant to implicitly exclude them. Should a test procedure not be
finalized for circulator pumps, DOE would retain the existing relevant
clauses of the IL definition.
DOE notes that clause (3) of the recommended SVIL definition
(``discharges the pumped liquid through a volute in a plane
perpendicular to the shaft'') refers to a volute. For the reasons
discussed in section III.B.1 of this document, DOE proposes excluding
this reference from the proposed SVIL definition.
The recommended SVIL pump definition, through clause (2), also
requires that these pumps be distributed into commerce with a motor,
meaning SVIL pumps cannot be sold as a bare pump. Based on a literature
search, DOE has tentatively determined that all SVIL pumps are sold
with a motor. However, by proposing to replace clause (2) with an
exclusion for circulator pumps, this requirement would be eliminated.
Although not addressed in the recommendation from the Working
Group, the defined term ``twin-head pump'' (10 CFR 431.462) would be
applicable to SVIL pumps. Specifically, in the January 2016 Final Rule,
DOE adopted a test procedure for ``twin-head pumps'', where a twin-head
pump is defined as a: ``dry rotor, single-axis flow, rotodynamic pump
that contains two impeller assemblies, which both share a common
casing, inlet, and discharge, and each of which (1) Contains an
impeller, impeller shaft (or motor shaft in the case of close-coupled
pumps), shaft seal or packing, driver (if present), and mechanical
equipment (if present); (2) Has a shaft input power that is greater
than or equal to 1 hp and less than or equal to 200 hp at best
efficiency point (BEP) and full impeller diameter; (3) Has the same
primary energy source (if sold with a driver) and the same electrical,
physical, and functional characteristics that affect energy consumption
or energy efficiency; (4) Is mounted in its own volute; and (5)
Discharges liquid through its volute and the common discharge in a
plane perpendicular to the impeller shaft.'' 81 FR 4086, 4095-4096 and
4115-4116 (Jan. 25, 2016).
Since SVIL pumps are similar to IL pumps but operate at a smaller
horsepower, and also are available in twin-head configurations DOE
proposes to define a new term--``small vertical twin-head pump''--and
to extend the twin-head pump test procedure adopted in the January 2016
Final Rule to small vertical twin-head pumps. Accordingly, the proposed
definition would read as: ``small vertical twin-head pump'' as a dry
rotor, single-axis flow, rotodynamic pump that contains two equivalent
impeller assemblies, each of which:
(1) Contains an impeller, impeller shaft (or motor shaft in the
case of close-coupled pumps), shaft seal or packing, driver (if
present), and mechanical equipment (if present); and
(2) Has a shaft input power that is less than or equal to 1 hp at
BEP and full impeller diameter; and
(3) Has the same primary energy source (if sold with a driver) and
the same electrical, physical, and functional characteristics that
affect energy consumption or energy efficiency; and
(4) Is mounted in its own volute; and
(5) Discharges liquid through its volute and the common discharge
in a plane perpendicular to the impeller shaft.
To summarize, DOE is proposing to define SVIL pumps based on the
recommended definition from the Circulator Pump Working Group with
modifications to include SVILs that are small vertical twin-head pumps;
to exclude pumps that are circulator pumps; and to remove the current
reference to a volute. Specifically, DOE is proposing to define a
``small vertical in-line pump'' as a small vertical twin-head pump or a
single stage, single-axis flow, dry rotor, rotodynamic pump that: (1)
Has a shaft input power less than 1 hp at best efficiency point at full
impeller diameter, (2) in which liquid is discharged in a plane
perpendicular to the shaft; and (3) is not a circulator pump.
Issue 13: DOE also proposes to revise the IL definition to
explicitly exclude circulator pumps. DOE requests comment on its
proposed definitions for ``small vertical in-line pumps'' and ``small
vertical twin-head pump.''
Issue 14: DOE requests comment on the percentage of SVIL pumps, if
any, that are not sold with a motor, and whether the definition of SVIL
pump should be limited to those sold with a motor.
Issue 15: DOE requests comment on its proposed revision to the IL
pump definition to explicitly exclude circulator pumps.
5. Between-Bearing Pumps
As discussed in section III.A.3.a, DOE is proposing to add between-
bearing pumps to the scope of this test procedure and is therefore
proposing a definition for this pump category.
ANSI/HI 14.1-14.2-2019 defines between-bearing pump as a
rotodynamic pump with the impeller(s) mounted on a shaft between-
bearings on either end. In addition, all between-bearing pumps
described in ANSI/HI 14.1-14-2-2019 are mechanically-coupled and dry
rotor. Through a literature review, DOE has tentatively determined that
the between-bearing pumps that are most similar to the pumps currently
regulated by DOE have axially-split casings and 1 or 2 stages.
Accordingly, using ANSI/HI 14.1-14.2-2019 as the basis for its
approach, DOE is proposing to use the defined terms ``dry rotor pump'',
rotodynamic pump'', and ``mechanically-coupled pump'' to define a
between-bearing pump,--i.e., ``an axially-split, mechanically-coupled,
one- or two-stage, dry rotor, rotodynamic pump with bearings on both
ends of the rotating assembly that has a shaft input power greater than
or equal to 1 hp and less than or equal to 200 hp at BEP and full
impeller
[[Page 21283]]
diameter and at the number of stages required for testing.''
Issue 16: DOE requests comment on its proposed definition for
between-bearing pumps, specifically if it is sufficient to identify the
intended scope.
In addition to proposing a definition for between-bearing pump, DOE
is also proposing to define the associated term ``axially-split pump.''
The term ``axially-split'' refers to a design of pump casing that can
be separated, for maintenance and assembly, in a plane parallel to the
impeller shaft. DOE proposes to define an ``axially-split pump'' based
on ANSI/HI 14.1-14.2-2019 as ``a pump with a casing that can be
separated or split in a plane that is parallel to and which contains
the axis of the impeller shaft.''
Issue 17: DOE request comment on the proposed definition for
axially-split pump.
6. Vertical Turbine Pump
As discussed in section III.A.3.b, DOE is proposing to add vertical
turbine pumps to the scope of its test procedure and is therefore
proposing a definition for this pump category. ANSI/HI 14.2-14.2 -2019
defines vertical turbine pumps as ``single-casing, non-submersible,
pumps with impellers mounted in a vertically suspended shaft, that
discharge liquid through the column.'' Based on this definition and
existing DOE defined terms and proposed defined terms, DOE is proposing
to define the term ``vertical turbine pump'' as a vertically-suspended,
single-stage or multi-stage, dry rotor, rotodynamic pump:
(1) That has a shaft input power greater than or equal to 1 hp and
less than or equal to 200 hp at BEP and full impeller diameter and at
the number of stages required for testing;
(2) For which no external part of such a pump is designed to be
submerged in the pumped liquid;
(3) That has a single pressure containing boundary (i.e., is single
casing), which may consist of but is not limited to bowls, columns, and
discharge heads; and
(4) That discharges liquid through the same casing in which the
impeller shaft is contained.
Issue 18: DOE requests comment on the proposed definition for
vertical turbine pump.
7. Radially-Split, Multi-Stage Horizontal Pumps
DOE currently defines a RSV pump as a vertically-suspended, multi-
stage, single axis flow, dry rotor, rotodynamic pump:
(1) That has a shaft input power greater than or equal to 1 hp and
less than or equal to 200 hp at BEP and full impeller diameter and at
the number of stages required for testing; and
(2) In which liquid is discharged in a place perpendicular to the
impeller shaft; and
(3) For which each stage (or bowl) consists of an impeller and
diffuser;
(4) For which no external part of such a pump is designed to be
submerged in the pumped liquid; and
(5) Examples include, but are not limited to, pumps complying with
ANSI/HI nomenclature VS8, as described in ANSI/HI 2.1-2.2-2014.
As discussed in section III.A.3.c, DOE is proposing to include
within the scope of the DOE test procedure RSH pumps with both end-
suction and in-line flow configurations. RSH pumps are nearly identical
to RSV pumps except for the mounting orientation and flow
configurations. In their comments to the August 2021 ECS RFI, Grundfos
recommended that DOE consider new categories for products similar to
RSV and RSH with connections that are not in line. (Grundfos, Docket
EERE-2021-BT-STD-0018, No. 9 at p. 2) As discussed in section
III.A.3.c, RSH pumps may have different flow configurations that are
expected to impact pump efficiency; therefore, DOE is proposing three
definitions for RSH pumps based on the existing DOE definition for
pumps: One for an overarching category of RSH pumps, which does not
characterize flow; one for in-line RHS pumps; and one for end-suction
RSH pumps. The three definitions would be modified to read as follows:
Radially-split, multi-stage, horizontal, diffuser casing (RSH) pump
means a horizontal, multi-stage, dry rotor, rotodynamic pump:
(1) That has a shaft input power greater than or equal to 1 hp and
less than or equal to 200 hp at BEP and full impeller diameter and at
the number of stages required for testing; and
(2) In which liquid is discharged in a plane perpendicular to the
impeller shaft; and
(3) For which each stage (or bowl) consists of an impeller and
diffuser; and
(4) For which no external part of such a pump is designed to be
submerged in the pumped liquid.
Radially-split, multi-stage, horizontal, in-line diffuser casing
(``RSHIL'') pump means a single-axis flow RSH pump in which the liquid
enters the pump in a plane perpendicular to the impeller shaft.
Radially-split, multi-stage, horizontal, end-suction diffuser
casing (``RSHES'') pump means a RSH pump in which the liquid enters the
bare pump in a direction parallel to the impeller shaft and on the side
opposite of the bare pump's driver-end.
Issue 19: DOE requests comment on the proposed definitions for RSH,
RSHIL, and RSHES pumps--particularly whether they are sufficient to
identify the intended scope of such pumps as discussed in section
III.A.3.c of this document.
8. Close-Coupled and Mechanically-Coupled Pumps
As discussed in section III.A.3.d, DOE defines a close-coupled pump
as a pump having a motor shaft that also acts as the impeller shaft,
and defines a mechanically-coupled pump as a pump that has its own
impeller shaft and bearings separate from the motor shaft. DOE has
tentatively determined that these definitions leave a gap in the end-
suction pump category and is proposing to modify the definitions to
eliminate that gap.
In the April 2021 RFI, DOE requested comment on the definitions of
``close-coupled pump'' and ``mechanically-coupled pump'' and whether
the terms should be revised. 86 FR 20075, 20078.
Summit stated that it has no concerns with the current definitions
for ESCC and ESFM and that they are definitive enough. (Summit, No. 16
at p. 3) Summit's comments also addressed energy conservation standards
topics, which DOE will address in the pumps standards rulemaking. HI
suggested the following change to the definitions: (1) A close-coupled
pump, for the purposes of this regulation, is defined as a pump in
which the driver's bearings absorb the pump axial load; and (2) A
mechanically-coupled pump, for the purposes of this regulation, is
defined as a pump in which bearings external to the driver absorb the
pump axial load. (HI, No. 20 at p. 3) Grundfos agreed with HI's
recommendation to modify the definitions for close-coupled pump and
mechanically-coupled pump and emphasized that products that do not have
bearings and have an impeller that is not on the motor shaft should be
covered by these definitions. (Grundfos, No. 17 at p. 2) Grundfos
additionally stated that the definitions for these products should
utilize how the axial loads are handled as a differentiating factor for
these terms. Id. Grundfos added that DOE's definitions are not
necessarily aligned with standard industry definitions, and therefore
recommended that DOE preface its definitions with the phrase, ``For the
purposes of this regulation, [product] pump means . . .''. Id.
DOE acknowledges that a definition that addresses how the axial
load is
[[Page 21284]]
absorbed may better differentiate close-coupled and mechanically-
coupled pumps. DOE notes that regardless of whether its definitions
align with industry definitions, the text in the CFR takes precedence
over definitions in industry standards that may be incorporated by
reference. See 10 CFR 431.462. Based on responses received from
stakeholders and DOE's review of ESCC and ESFM pumps, DOE has
tentatively determined that there is a group of end-suction pumps that
do not currently fall within the ESFM or ESCC definitions. To address
this issue, DOE proposes revising its definitions for ``close-coupled
pump'' and ``mechanically-coupled pump'' as follows:
A close-coupled pump means a pump in which the driver's bearings
absorb the pump's axial load.
A mechanically-coupled pump means a pump in which bearings external
to the driver absorb the pump's axial load.
In DOE's view, these revised definitions should capture all end-
suction pumps whose axial loads are supported with bearings. This
change should encompass the previously uncovered end-suction pumps and
clarify the definitions sufficiently to avoid future confusion.
Issue 20: DOE requests comment on the proposed definitional changes
to ESFM and ESCC pumps in defining both categories based on the
location of the bearings which bear the axial load of the pump.
Specifically, DOE seeks comment on whether these proposed changes will
capture the end-suction pumps identified by stakeholders as not
currently meeting the ESCC or ESFM definitions.
9. Tangential Discharge
The definition for IL pump applies to pumps for which the liquid is
discharged from the pump in a plane (i.e., direction) perpendicular to
the impeller shaft, and for which the entering and exiting flows are
along the same axis (i.e., single-axis flow). See 10 CFR 431.462. The
definition for end-suction pump applies to pumps for which the liquid
enters the pump in a direction parallel to the impeller shaft and exits
the pump in a plane perpendicular to the shaft. Id. DOE also currently
defines the term ``single axis flow pump'' as ``a pump in which the
liquid inlet of the bare pump is on the same axis as the liquid
discharge of the bare pump.'' Id. As discussed in the April 2021 RFI,
the ``single axis flow pump'' definition does not explicitly state
whether the axis is defined by the suction opening to the volute or the
suction opening at the perimeter of the pump. 86 FR 20075, 20078.
Close-coupled pumps can be designed with a perpendicular discharge
volute which is also tangential (i.e., a design in which the suction
and discharge openings do not share a common axis). See 10 CFR 431.462
(defining ``single axis flow pump'').
In the April 2021 RFI, DOE requested comment on how manufacturers
are currently categorizing close-coupled pumps with tangential
discharge volutes relative to the five pump categories defined at 10
CFR 431.464 and whether DOE should provide additional detail in the
definitions for single-axis flow pump and/or end-suction pump regarding
tangential discharge volute configurations. 86 FR 20075, 20078. Summit,
Grundfos, and HI all commented that the existing definitions of end-
suction pump and IL pump are sufficient. (Summit, No. 16 at p. 3;
Grundfos, No. 17, at p. 2; HI, No. 20 at p. 3) Summit additionally
stated that it assumes end-suction was relative to suction and parallel
to the shaft, and that tangential discharge pumps are included in end-
suction type pumps (Summit, No. 16 at p. 3) DOE interpreted this to
mean Summit interprets end-suction as suction parallel to the impeller
shaft. HI and Grundfos stated that tangential discharge is not a
concern for IL pumps and RSV pumps because of the requirement for
single axis flow included in the definitions for IL pump and RSV pump.
(HI, No. 20 at p. 3; Grundfos, No. 17 at p. 2) HI and Grundfos
additionally stated that tangential discharge is not a design
characteristic for ST pumps, since this would imply a pump discharge
perpendicular to the pump shaft, and that tangential discharge is
already covered in both the ESCC pump and ESFM pump definitions. Id.
Grundfos recommended that DOE specify whether tangential discharge is
the location of the discharge outlet or the discharge exit from the
volute. Id.
After further reviewing the definitions for single axis flow pump,
ESCC pump, ESFM pump, IL pump, and RSV pump, and taking into account
stakeholder comments, DOE has tentatively determined that the current
definitions are sufficient and is not proposing to revise the
definitions for end-suction pump or in-line pump at this time.
10. Pump
DOE currently defines a ``pump'' as ``equipment designed to move
liquids (which may include entrained gases, free solids, and totally
dissolved solids) by physical or mechanical action and includes a bare
pump and, if included by the manufacturer at the time of sale,
mechanical equipment, driver, and controls.'' 10 CFR 431.462. DOE
currently defines ``bare pump'' as ``a pump excluding mechanical
equipment, driver, and controls.'' Id. As discussed in the April 2021
RFI, some manufacturers distribute kits of unassembled components that
customers (including end users or distributors) may purchase and
assemble into finished equipment that meets the definition of a pump or
a bare pump. 86 FR 20075, 20078 DOE requested comment on the
definitions of ``pump'' and its components and whether any of the terms
should be amended, and if so, how the terms should be amended. Id. In
particular, DOE requested comment on whether the terms are sufficient
to identify which equipment is subject to the test procedure and
whether any test procedure amendments are required to ensure that all
such equipment can be appropriately tested in accordance with the test
procedure. Id.
In response to the April 2021 RFI, Grundfos and HI supported the
definition of a pump as written. (Grundfos, No. 17 at p. 1; HI, No. 20
at p. 2) Summit commented that the pump definition could better
describe what pump parts are subject to regulation. (Summit, No. 16 at
p. 2) Specifically, Summit stated that it interpreted the definition
such that if the parts in a kit alone will only be used to make a pump,
with no other kits or parts needed, such a kit would be considered a
pump. Id. Summit stated that determining the end use of a pump kit can
be extremely burdensome. Id. Summit additionally commented that if a
pump does not meet the PEI standard, Summit will no longer distribute
its impeller/casing kit; however, Summit does not consider these spare
parts to be covered by the DOE regulation. Id.
DOE acknowledges that determining the end use of a pump kit, or a
pump part can be burdensome. DOE currently interprets the term ``bare
pump'' to include any kit that contains all the parts necessary for an
operating pump, barring mechanical equipment, driver, and controls.
Replacement parts are not the subject of this regulation.
C. Updates to Industry Standards
The current DOE test procedure for pumps incorporates the following
industry test standards: HI 40.6-2014, ANSI/HI 1.1-1.2-2014, and ANSI/
HI 2.1-2.2-2014. 10 CFR 431.463. The following sections describe
updates to these industry standards and discuss what industry standards
DOE is proposing to incorporate by reference in
[[Page 21285]]
the NOPR and the relevant provisions of those industry standards that
DOE is proposing to reference.
1. ANSI/HI 40.6
As discussed in the April 2021 RFI, the DOE test procedure for
pumps generally incorporates HI 40.6-2014. 86 FR 20075, 20080. Since
publication of the January 2016 Final Rule, the Hydraulics Institute
updated HI 40.6-2014 with the publication of HI Standard 40.6-2016,
``Methods for Rotodynamic Pump Efficiency Testing'' (``HI 40.6-2016'').
The definitions and procedures in HI 40.6-2016 align with the DOE test
procedure for pumps published in the January 2016 Final Rule. HI
published another updated version of HI 40.6 in 2021, ``Methods for
Rotodynamic Pump Efficiency Testing'' (``HI 40.6-2021''). HI 40.6-2021
includes the following modifications as compared to HI 40.6-2014
(relevant sections of HI 40.6-2021 are included in parentheses after a
summary of the modification):
(1) Clarified that the industy testing standard covers efficiency
testing of rotodynamic pumps that are subject to DOE's energy
conservation standards. (Section 40.6.1 ``Scope'')
(2) Updated the calculation of bare pump efficiency to match the
current DOE test procedure requirements for plotting test data to
determine the best efficiency point (``BEP'') rate of flow. (Section
40.6.6.3 ``Performance curve'')
(3) Updated the description and requirements of the pressure tap
configuration for measurement sections at inlet and outlet of the pump.
(Section A.3.1.3 ``Pressure taps'')
(4) Added an informative appendix for determining, applying, and
calculating measurement instrument uncertainty. (Appendix H
``Determination, application, and calculation of instrument
(systematic) uncertainty (informative)'')
(5) References ANSI/HI 14.1-14.2 ``Rotodynamic Pumps for
Nomenclature and Definitions'' (``ANSI/HI 14.1-14.2'') which supersedes
ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014. (Section 40.6.4.1
``Vertically suspended pumps''; Section 40.6.4.3 ``All other pump
types'')
(6) Includes a new appendix (Appendix E) for the testing of
circulator pumps. (Appendix E ``Testing Circulator Pumps'')
DOE noted in the April 2021 RFI that comments in response to the
September 2020 Early Assessment RFI suggested that DOE adopt HI 40.6-
2021 instead of HI 40.6-2016, with commenters stating that the 2021
version includes clarifying edits, is no more burdensome to conduct,
and includes a section for testing circulator pumps. 86 FR 20075,
20080. In the April 2021 RFI, DOE again requested comment on whether it
should adopt HI 40.6-2016 or HI 40.6-2021. Id. Grundfos, the CA IOUs,
HI, and NEEA all supported the adoption of HI 40.6-2021, stating that
the 2021 version does not change the measured test values as compared
to HI 40.6-2014 as referenced by the DOE test procedure, and that
testing according to the 2021 version would not be more burdensome to
conduct. (Grundfos, No. 17 at p. 4; CA IOUs, No. 19 at p. 11; HI, No.
20 at p. 2; NEEA, No. 21 at p. 2)
DOE has tentatively determined that with respect to the provisions
of HI 40.6-2014, the corresponding provisions of HI 40.6-2021 are
substantively the same and adopting such provisions would not change
the current test procedure. As such, in order to reference the most
current industry test procedure, DOE is proposing to incorporate by
reference HI 40.6-2021 in place of HI 40.6-2014.
While DOE proposes to incorporate by reference HI 40.6-2021 as the
basis for its proposed test procedure, DOE has tentatively determined
that certain sections of the industry testing standard are not
applicable to the DOE test procedure. Specifically, Section 40.6.1,
Scope, provides the scope specific to the test methods outlined in HI
40.6; Section 40.6.5.3 provides provisions regarding the generation of
a test report; appendix ``B'' provides informative guidance on test
report formatting; appendix ``E'' provides normative test procedures
for circulator pumps; and appendix ``G'' compares HI 40.6 and DOE's
nomenclature. None of these sections are required for testing and
rating pumps in accordance with DOE's proposed procedure. As such, DOE
is not proposing to adopt Section 40.6.1, Section 40.6.5.3, appendix B,
appendix E, and appendix G.
Additionally, certain provisions of HI 40.6-2021 are consistent
with the additional provisions established by DOE in appendix A. As
such, DOE is proposing to maintain those provisions through reference
to HI 40.6-2021, specifically:
(1) Section I.D.1 of appendix A, which addresses damping devices,
would be amended to reference the corresponding provisions in HI
40.6.3.2.2;
(2) Section I.D.2 of appendix A, which addresses stabilization,
would be amended to reference the corresponding provisions in HI
40.6.5.5.1;
(3) Section I.D.3 of appendix A, which addresses calculations and
rounding, would be amended to reference the corresponding provisions in
HI 40.6.6.1.1;
(4) Sections III.D.1, IV.D.1, V.D.1, VI.D.1, and VII.D.1 of
appendix A, which outline testing the BEP of different pump
configurations, would be amended to reference the corresponding
provisions in HI 40.6.5.5.1.
2. ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014
Subpart Y to part 431 currently incorporates by reference ANSI/HI
1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014. DOE references ANSI/HI 1.1-1.2-
2014 and ANSI/HI 2.1-2.2-2014 in defining certain terms in 10 CFR
431.462. In 2019, ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 were
updated and combined into ANSI/HI 14.1-14.2-2019, ``American National
Standard for Rotodynamic Pumps for Nomenclature and Definitions''
(``ANSI/HI 14.1-14.2-2019''). The notable additions to ANSI/HI 14.1-
14.2 which were absent in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014
are outlined below:
(1) ANSI/HI 14.1-14.2-2019 includes additonal figures and tables to
represent information included in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-
2.2-2014;
(2) ANSI/HI 14.1-14.2-2019 adds new pump definitions and pump
classifications;
(3) ANSI/HI 14.1-14.2-2019 includes configuration definitions for
vertical in-line, vertical end-suction, vertical self-priming, seal-
less, magnetic drive, canned motor, and multi-stage pumps;
(4) ANSI/HI 14.1-14.2-2019 adds new definitions for discharge
casing, volute,concentric casing, modified concentric casing, vaned
diffuser/collector, bowl, and stage casing; and \25\
---------------------------------------------------------------------------
\25\ A volute may also be referred to as a ``housing'' or
``casing.''
---------------------------------------------------------------------------
(5) ANSI/HI 14.1-14.2-2019 includes a new ``preferred operating
region'' section to define a guideline for reccomended operating flow
rates.
In the April 2021 RFI, DOE requested comment on incorporating ANSI/
HI 14.1-14.2-2019 by reference into the DOE test procedure. 86 FR
20075, 20080-20081. Grundfos and HI encouraged DOE to incorporate ANSI/
HI 14.1-14.2-2019 (Grundfos, No. 17 at p. 4; HI, No. 20 at p. 2).
However, stakeholders did not address whether adoption of ANSI/HI 14.1-
14.2-2019 would substantively change currently defined terms and
equipment classes.
As stated previously, in general the current DOE test procedure
incorporates pump designations from ANSI/HI 1.1-1.2-2014 and ANSI/HI
2.1-2.2-2014 as examples for the definitions of end-suction close-
coupled (ESCC); end-
[[Page 21286]]
suction frame mounted/own bearings (ESFM); in-line (IL); radially-
split, multi-stage, vertical, in-line diffuser casing (RSV); and
submersible turbine (ST) pump categories under the DOE test procedure.
10 CFR 431.462. DOE notes that generally, the references to ANSI/HI
1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 are in the context of providing
non-limiting examples. DOE is concerned that continued inclusion of HI
pump designations as examples of specific pump categories may cause
confusion in the market or be misunderstood to limit the scope of the
relevant definitions. To avoid any such misreading, DOE is proposing to
remove the references to ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014
as examples of certain pump category definitions. Additional detail on
the proposed changes to the definitions is discussed in section III.B.2
of this document.
Additionally, DOE's current test procedure definition of ``bowl
diameter'' relies on the ``intermediate bowl'' definition in ANSI/HI
2.1-2.2-2014. DOE is proposing to modify its definition for ``bowl
diameter'' and add a DOE definition for ``intermediate bowl'' to remove
the current reference to ANSI/HI 2.1-2.2-2014. These proposed changes
will create a more self-contained definition. These proposed changes
are discussed in section III.B.3 of this document.
D. Metric
The current energy efficiency standards for pumps are based on the
PEI metric. 10 CFR 431.465. The PEI metric is a ratio of the pump
energy rating (``PER'') of the tested pump to the PER of a minimally-
compliant pump (``PER<INF>STD</INF>''). See section II of appendix A.
The current test procedure defines the metric PEI<INF>CL,</INF> the
pump energy index for a constant load, as applicable to pumps rated as
bare pumps or sold with motors; and the metric PEI<INF>VL</INF>, the
pump energy index for a variable load, as applicable to pumps sold with
motors and continuous controls or noncontinuous controls. Appendix A,
section II.A. A ``continuous control'' is a control that adjusts the
speed of the pump driver continuously over the driver's operating speed
range in response to incremental changes in the required pump flow,
head, or power output. 10 CFR 431.462. A ``non-continuous control'' is
a control that adjusts the speed of a driver to one of a discrete
number of non-continuous preset operating speeds and does not respond
to incremental reductions in the required pump flow, head, or power
output. Id.
The PEI metric is a ratio of the pump energy rating (``PER'') of
the tested pump to the PER of a minimally-compliant pump
(``PER<INF>STD</INF>''). See appendix A. The pump energy rating for
constant load pumps (``PER<INF>CL''</INF>) is calculated as the average
of driver power input at 75 percent, 100 percent, and 110 percent of
flow at the BEP, where the flows are achieved by varying the operating
head to follow the pump performance curve. See appendix A, section
II.A.1 and subsequently referenced sections. The pump energy rating for
variable load pumps (``PER<INF>VL''</INF>) is calculated as the average
of driver power input at 25%, 50%, 75%, 100% of flow at BEP, where the
flows are achieved by speed reduction to follow a specified system
curve. See appendix A, section II.A.2 and subsequently referenced
sections. BEP is defined as the pump hydraulic power operating point
(consisting of both flow and head conditions) that results in the
maximum efficiency. 10 CFR 431.462.
In response to the April 2021 RFI, NEEA stated that DOE's current
pump test procedure generally provides a good representation of pump
energy consumption and that the current pump metrics are good
indicators of relative efficiency. (NEEA, No. 21 at p. 2)
This section discusses the proposed regulatory metric for SVIL
pumps and additional clean water pumps that DOE is proposing to
incorporate into its test procedure scope. In the May 2021 Circulator
Pumps RFI, DOE discussed that the Circulator Pump Working Group
recommended evaluating SVIL pumps using the PEI<INF>CL</INF> or
PEI<INF>VL</INF> metrics, similar to commercial and industrial pumps,
and using the commercial and industrial pump test procedure to measure
performance, with any additional modifications necessary as determined
by DOE. 86 FR 24516, 24527.
In their comments to the May 2021 Circulator Pumps RFI, the CA IOUs
reiterated their support for SVILs to be rated using the
PEI<INF>CL</INF> or PEI<INF>VL</INF> metric, consistent with the
Circulator Pump Working Group term sheet. (CA IOUs, EERE-2016-BT-STD-
0004, at No. 10 p. 6)
DOE reviewed the PEI<INF>CL</INF> and PEI<INF>VL</INF> metrics and
has tentatively determined that, in general, use of PER<INF>CL</INF>
and PER<INF>VL</INF> and indexing the results against PER<INF>STD</INF>
would be a reasonable and consistent way to evaluate SVIL performance.
This tentative determination is based largely on the similarities
between SVILs and in-line pumps, which are evaluated using the
PER<INF>CL</INF> and PER<INF>VL</INF> metrics. As such, DOE is
proposing that the rating metric for SVIL pumps would be
PEI<INF>CL</INF> for constant load pumps and PEI<INF>VL</INF> for
variable load pumps, equivalent to the metric already in use for
currently covered commercial and industrial pumps.
For the additional clean water pump categories that DOE is
proposing to include within the scope of the test procedure (i.e.,
vertical turbine pumps, between-bearing pumps, and radially-split,
multi-stage horizontal pumps), DOE has tentatively determined that its
proposed test procedure would measure energy efficiency during a
representative average use cycle and not be unduly burdensome to
conduct. This determination is based on the similarities between the
pump categories that are addressed in the current test procedure and
those that DOE is proposing to add. Therefore, DOE tentatively
determines that PEI<INF>CL</INF> and PEI<INF>VL</INF> are appropriate
metrics for use these pumps. DOE tentatively determines that using
PEI<INF>CL</INF> and PEI<INF>VL</INF> for the additional pump
categories would ensure a consistent rating approach in the market.
Thus, DOE proposes that the PEI<INF>CL</INF> and PEI<INF>VL</INF>
metric would be used for rating the performance of small vertical in-
line pumps, vertical turbine pumps, between-bearing pumps, and
radially-split multi-stage horizontal pumps.
E. Proposed Amendments to Test Method
As discussed in section III.C.1, DOE is proposing to utilize HI
40.6-2021 in its test procedure for pumps with certain exceptions. HI
40.6-2021 specifies calculating pump power input,\26\ driver power
input (for testing-based methods), \27\ pump power output,\28\ pump
efficiency,\29\ bowl efficiency,\30\ overall efficiency,\31\ and other
relevant values at
[[Page 21287]]
the specified load points necessary to determine PEI<INF>CL</INF> and
PEI<INF>VL</INF>. HI 40.6-2021 also contains specifications regarding
test methodology, standard rating conditions, equipment specifications,
uncertainty calculations, and tolerances.
---------------------------------------------------------------------------
\26\ The term ``pump power input'' in HI 40.6-2021 is defined as
``the power transmitted to the pump by its driver'' and is
synonymous with the term ``pump shaft input power,'' as used in this
document.
\27\ The term ``driver power input'' in HI 40.6-2014 is defined
as ``the power absorbed by the pump driver'' and is synonymous with
the term ``pump input power to the driver,'' as used in this
document.
\28\ The term ``pump power output'' in HI-40.6 is defined as
``the mechanical power transferred to the liquid as it passes
through the pump, also known as pump hydraulic power.'' It is used
synonymously with ``pump hydraulic power'' in this document.
\29\ The term ``pump efficiency'' is defined in HI 40.6-2014 as
a ratio of pump power output to pump power input.
\30\ The term ``bowl efficiency'' is defined in HI 40.6-2014 as
a ratio of pump power output to bowl assembly power input and is
applicable only to VTS and RSV pumps.
\31\ The term ``overall efficiency'' is defined in HI 40.6-2014
as a ratio of pump power output to driver power input and describes
the combined efficiency of a pump and driver.
---------------------------------------------------------------------------
Sections II through VII of the DOE test procedure specify methods
for determining PEI<INF>CL</INF> and PEI<INF>VL</INF> for pumps based
on whether they are distributed into commerce with a motor and or with
controls and are summarized below:
<bullet> Section II: Calculation of PEICL or PEIVL for all pumps
based on the pump energy rating for a minimally-compliant reference
pump (PERCL or PERVL, respectively);
<bullet> Section III: Test procedure for bare pumps;
<bullet> Section IV: Testing-based approach for pumps sold with
motors;
<bullet> Section V: Calculation-based approach for pumps sold with
motors;
<bullet> Section VI: Testing-based approach for pumps sold with
motors and controls; and
<bullet> Section VII: Calculation-based approach for pumps sold
with motors and controls.
See appendix A, sections I.A.2 through I.A.6.
In response to the April 2021 RFI, NEEA recommended against any
modifications to the test procedure that would minimally improve its
representation of efficiency but that would require manufacturers to
retest and rerate. (NEEA, No. 21 at p. 2) Similarly, HI recommended
making only clarifications to the test procedure, except for the
addition of a calculation method for power drive system losses for
inverter-only motors. (HI, No. 20 at p. 1) The following sections
discuss proposed amendments to the test procedure.
1. Nominal Speed
The scope of the current test procedure is limited to pumps
designed to operate with either a 2- or 4-pole induction motor or a
non-induction motor with a speed of rotation operating range between
2,880 and 4,320 rpm and/or 1,440 and 2,160 rpm. 10 CFR
431.464(a)(1)(ii). Section I.C.1 of appendix A specifies the selection
of nominal speed of rotation of either 1,800 or 3,600 rpm depending on
the number of poles of the motor or the operating range of non-
induction motors.
As discussed in section III.A.4.b, DOE is proposing to include in
the scope of the test procedure pumps that operate between 960 and
1,440 rpm or are designed to operate with 6-pole motors. DOE proposes
that these pumps would be tested with a nominal speed of 1,200 rpm. DOE
is also proposing updates to the calculation and rounding sections of
the test procedure to address this additional nominal speed.
Issue 21: DOE requests comment on its proposal that pumps designed
to operate between 960 and 1,440 rpm or with 6-pole motors be assigned
a nominal speed of 1,200 rpm.
In the April 2021 RFI, DOE requested comment on whether the nominal
motor speeds of 1,800 rpm and 3,600 rpm used in the current DOE test
procedure appropriately represent the operation and energy use of pumps
that are capable of higher speeds. 86 FR 20075, 20083. If these motor
speeds are not representative, DOE requested comment on whether a
testing-based or calculation-based approach would provide more
representative energy use values and the expected cost burden of each.
Id. Additionally, DOE requested test data at speeds other than the
nominal speeds specified in the current test procedure in order to
determine if a calculation-based method is appropriate. Id.
HI commented that the test procedure has a gap in regard to pumps
sold with higher speed motors but asserted that the comment period did
not allow enough time to fully develop a recommendation to modify the
test procedure. (HI, No. 20 at p. 7). HI stated that they would
continue to work on a recommendation and requested that DOE involve
stakeholders in the solution.\32\ Id. Grundfos supported the work of HI
in creating a recommendation for how to handle this equipment.
(Grundfos, No. 17 at p. 7) Given that many of the motors in this
category would be included in the inverter-only motor category for
which a new calculation method is being proposed, and that DOE has not
identified any data indicating what nominal speed would be more
representative of higher design speeds, DOE has tentatively decided not
to propose a higher nominal speed for testing.
---------------------------------------------------------------------------
\32\ DOE notes that HI's supplemental comments responding to the
April 2021 RFI did not provide input on this issue. (HI, No. 22)
---------------------------------------------------------------------------
2. Testing of Multi-Stage Pumps
The current DOE test procedure specifies that RSV pumps shall be
tested with three stages and that ST pumps shall be tested with nine
stages. If the unit under test is only available with fewer than the
required number of stages, the pump is tested with the maximum number
of stages with which the unit is distributed in commerce in the United
States. If the unit under test is only available with greater than the
number of required stages, the pump is tested with the lowest number of
stages with which the unit is distributed in commerce in the United
States. If the unit under test is available with both fewer and greater
than the required number of stages, but not the required number of
stages, the pump is tested with the number of stages closest to the
required number of stages. If both the next lower and next higher
number of stages are equivalently close to the required number of
stages, the pump is tested with the next higher number of stages. See
appendix A, section I.C.2.
RSH and VT pumps are sold with a varying number of stages, in which
the same pump may have options for multiple different stages for
multiple applications. To reduce testing burden and mirror the practice
established for RSV pumps, DOE proposes that RSH pumps be tested with
three stages. To reduce testing burden and mirror the practice
established for ST pumps, DOE proposes testing VT pumps with nine
stages. If units of the basic model of pump being tested are not
distributed in commerce with the number of stages prescribed for
testing, the existing instructions for selection of the correct number
of stages to use during testing would be followed.
As defined in section IIIB.5, BB pumps can have either one or two
stages. For BB basic models that are distributed into commerce with
both one and two stages, DOE proposes that the pump would be tested at
two stages. This proposed approach would maintain consistency with
DOE's current test procedure requiring that multi-stage pumps be tested
with more than one stage.
Issue 22: DOE requests comment on the proposed number of stages for
testing RSH, VT, and BB pumps.
3. Best Fit Curve
In the current DOE test procedure, BEP flow rate is determined as
the flow rate at which maximum pump efficiency is achieved on the pump
efficiency curve, as determined in accordance with Section 40.6.6.3 of
HI 40.6-2014. Appendix A, Sections III.D.2, IV.D.2, V.D.2, VI.D.2, and
VII.D.2. Section 40.6.6.3 of HI 40.6-2014 provides instruction for
determining the best fit curve for pump flow rate versus efficiency.
Specifically, the best fit curve may be either (1) up to a 6th order
polynomial, or (2) a spline function with a single slow reversal in the
region of the BEP rate of flow. HI 40.6.6.3.
In response to the April 2021 RFI, Summit recommended better
defining
[[Page 21288]]
``best fit curve'' to the speed corrected data, possibly specifying a
degree of polynomial required. (Summit, No. 16 at p. 2) Summit also
recommended defining a minimum number of data points required per
setpoint, or clarifying that a confidence interval--such as 95%--for
each setpoint. (Summit, No. 16 at p. 2)
DOE tentatively concludes that the provisions in Section 40.6.6.3
of HI 40.6-2021 are sufficient for defining the best fit curve. When
testing a pump, data relating to flow rate and efficiency can be fit
using the allowed methods under HI 40.6-2021 in order to find the
method with the best fit. DOE notes that, in general, ``best fit''
refers to a curve that best expresses the relationship between the
data, and that can be determined through a least squares method.
However, DOE does not fully understand Summit's request regarding the
minimum number of data points required per setpoint. The test procedure
requires taking a minimum of seven flow points and using a least
squares regression to determine a linear relationship between pump
power input or driver power input at measured flow points, which is
then used to determine pump power input or driver power input at the
specified load points. See, e.g., appendix A, section III E.1.1.
Because the specified load points are determined from the measured flow
points, it is not essential for multiple data points to be taken per
measured flow point. DOE notes that appendix A section VI.E.2.1 and
section VI.E.2.2, which are relevant to the testing-based approach for
pumps sold with motors and controls, provide tolerances and correction
equations for the load points that must be measured at reduced speed.
For these reasons, DOE is not proposing any changes in response to
Summit's comment.
4. Load Profile
The current test procedure requires that constant load pump energy
rating be determined using 75, 100 and 110 percent of BEP flow with
each value multiplied by 0.33 and the results summed to determine
PER<INF>CL</INF>. Appendix A, sections III.E, IV.E, V.E. Similarly, for
variable load pumps, energy ratings are determined at 25, 50, 75, and
100 percent of BEP flow with each point weighted by 0.25 and summed to
obtain a value for PER<INF>VL</INF>. Appendix A, sections VI.E, VII.E.
In the April 2021 RFI, DOE sought additional comment on the load
profile distribution for constant and variable load pumps and the
effect of the distribution on PEI value. 86 FR 20075, 20083.
HI stated that the actual load profile of a pump in use is
application specific and will vary widely for the applications covered
by clean water pumps. HI stated that the current load profiles are
sufficient for calculation of the PEI. (HI, No. 20 at p. 7) Grundfos
supported keeping the existing load profiles and stated that given the
large number of applications in which regulated pumps are used, the
current profiles are sufficient to evaluate general pump performance.
(Grundfos, No. 17 at p. 7) NEEA stated that they had no additional
comment beyond their response to the September 2020 Early Assessment
RFI, which DOE summarized in the April 2021 RFI. (NEEA, No. 21 at p.
11)
The existing load profiles provide a consistent method for
comparing the performance of different pumps, which, as noted by
stakeholders, exhibit a range of load profiles across the wide range of
installation environments. At this time, DOE does not have any
indication that the current load profiles are not appropriately
representative. Therefore, DOE is not proposing changes to the current
test procedure's load profiles.
5. Pumps With BEP at Run-Out
To determine a pump's BEP, the DOE test procedure references
testing provisions included in HI 40.6-2014 (excluding sections
40.6.5.3, section A.7 and appendix B) at the following seven flow
points: 40, 60, 75, 90, 100, 110, and 120 percent of the expected BEP
flow rate of the pump at the nominal speed of rotation. Appendix A,
section III.D.1. All pumps have a maximum flow rate which is termed
``run out.'' For pumps where the BEP is expected to be within 20
percent of the maximum flow rate of the pump (BEP at run out), section
I.D.4 of appendix A provides alternative flow points, with the maximum
flow point equal to 100 percent of the expected maximum flow rate so
that the pump may safely operate. As discussed in section III.C.1,
Sections 40.6.5.5.1 and 40.6.6.3 of HI 40.6-2021 now include provisions
related to pumps with BEP at run-out. Section 40.6.5.5.1 provides
alternate test points based on the expected BEP rate of flow for pumps
with a maximum allowable flow rate as specified by the manufacturer
that is less than 120 percent of the BEP flow rate. Section 40.6.6.3
also provides alternate tested load points for the driver input power
as a percentage of BEP flow rate for pumps that cannot be safely tested
to flows greater than 120 percent of BEP. However, these provisions are
based on flow points with respect to expected BEP flow rate rather than
expected maximum flow rate.
In the January 2016 Final Rule, DOE responded to a comment from HI
that in order to determine the location of BEP, testing must occur at
rates of flow greater than 100 percent of expected BEP flow. 81 FR
4086, 4117. DOE stated that its proposal to use flow points only up to
100 percent was with respect to the expected maximum allowable flow
rate rather than with respect to expected BEP. Id. DOE notes that the
existing regulatory text contains an omission in which section I.D.4(1)
of appendix A only refers to ``the expected'' while section I.D.4(2)
refers to ``the expected maximum flow rate of the pump.'' DOE proposes
to include ``expected maximum flow rate of the pump'' in both section
I.D.4(1) and I.D.4(2) of appendix A and would not reference Sections
40.6.5.5.1 or 40.6.6.3 of HI 40.6-2021.
Issue 23: DOE requests comment on whether the alternate flow points
for pumps with BEP at run-out should be determined with respect to
expected maximum flow rate or expected BEP flow rate.
In addition, upon review and in response to previous stakeholder
questions, DOE has tentatively determined that the current regulatory
text would benefit from additional detail as to how the revised loading
points should be applied in the determination of PER<INF>STD.</INF> DOE
proposes to specify that the revised loading points would only be used
in application of the [alpha]<INF>i</INF> coefficient values when
determining pump power input, and not when determining specific speed
(``Ns'') or the minimally-compliant pump efficiency
(``[eta]<INF>pump,STD</INF>''), which should always be based on 100% of
BEP flow for standardization purposes.
DOE has also identified that the current provisions for pumps with
BEP at run-out do not address how to perform motor sizing for bare
pumps, which is based on the horsepower equivalent to, or the next
highest horsepower greater than, the pump power input to the bare pump
at 120 percent of the BEP flow rate of the tested pump. DOE proposes
that for pumps with BEP at run-out, motor sizing would be based on 100
percent of the BEP flow rate of the tested pump, as there are no flow
rates available higher than that level. However, DOE acknowledges that
this proposed change could result in inequitable motor sizing as
compared to pumps not subject to these provisions.
Issue 24: DOE requests comment on how manufacturers are currently
[[Page 21289]]
performing motor sizing for bare pumps with BEP at run-out, and whether
using 100 percent of the BEP flow rate is appropriate.
6. Calibration of Measurement Equipment
HI 40.6-2014 Appendix D, which the current DOE test procedure
adopts, specifies the frequency of measurement equipment calibration.
Table D.1 of HI 40.6-2014 provides that manufacturer's recommendations
on calibration intervals should be followed if they differ from those
in Table D.1. However, DOE notes that its test procedure does not
explicitly reference Table D.1 of HI 40.6-2021.
In the dedicated-purpose pool pump test procedures included in
appendix B and appendix C to 10 part 431 subpart Y (``appendix B'',
``appendix C''), DOE has, for clarity, included the calibration
requirements contained in Appendix D of ANSI/HI 40.6-2014, with
modification allowing for calibration periods up to 3 times longer than
those specified in Table D.1 of ANSI/HI 40.6-2014 if justified by
historical calibration data. See appendix B, section I.B.2 and appendix
C, section I.B.2.
Similar to the approach DOE has followed with appendices B and C,
DOE proposes to specifically reference the calibration requirements in
Appendix D of HI 40.6-2021 in section I.B of appendix A to improve the
overall clarity of its test procedure.
7. Calculations and Rounding
The DOE test procedure includes provisions for calculations and
rounding in section I.D.3 of appendix A. Generally, all measured data
must be normalized such that it represents performance at nominal speed
of rotation in accordance with HI 40.6-2014, and all calculations must
be carried out using raw measured values without rounding. See appendix
A, section I.D.3. PER is rounded to three significant digits and PEI is
rounded to the hundredths place. Id. Explicit rounding directions are
not provided for other parameters. In the April 2021 RFI, DOE requested
comment as to whether the test procedure should specify rounding
requirements on parameters other than PER and PEI, and if so, what
those rounding requirements should be. 86 FR 20075, 20079 and 20083.
HI stated that rounding is not a concern for parameters other than
PER and PEI and that DOE does not need to specify rounding requirements
for these parameters. (HI, No. 20 at p. 7) Grundfos commented that
additional rounding requirements might result in unnecessary data
manipulation and would increase manufacturer burden for data reporting.
(Grundfos, No. 17 at p. 7)
With respect to the current rounding provisions for PER and PEI,
Summit recommended rounding PER to 3 decimal places and rounding PEI to
two decimal places. (Summit, No. 16 at p. 5). Summit also stated that
the number of significant figures is dependent on measurement devices
and measurement uncertainty. Id.
In response to Summit's suggestion for PER, DOE notes that three
decimal places represent three significant figures for values less than
1. DOE has not identified any reason why three decimal places would be
necessary for values greater than one and has tentatively determined
that three significant figures is sufficient. DOE also notes that
Summit's recommendation for two decimal places for PEI is consistent
with the current test procedure's instruction to round to the
hundredths place. For these reasons, DOE is not proposing any changes
to its current rounding requirements, except for updates to reference
the appropriate section of HI 40.6-2021, as discussed in section
III.C.1 of this document.
8. Test Procedure Credits
In response to the April 2021 RFI, NEEA recommended that DOE add a
credit for self-sensing ``smart'' pumps with continuous controls. NEEA
stated that ``smart'' pump technologies use self-sensing technologies
to measure power draw and speed to calculate load and then adjust speed
to maximize performance and reduce energy consumption required to meet
the load, and that the drive is programmed with the specific pump curve
with which it is installed. NEEA stated that these features potentially
reduce energy consumption by optimizing pump performance compared to
traditional control strategies. NEEA commented that the potential
performance improvements of such technology is not reflected in the
test procedure. NEEA recommended that DOE investigate the potential for
energy savings from such controls and develop minimally burdensome ways
to incorporate them in the test procedure, such as the Controls
Verification Procedure for Variable Refrigerant Flow (``VRF'') Systems
or credit for occupancy systems given to certain beverage vending
machines (``BVM''). (NEEA, No. 21 at p. 12)
According to DOE research, at this time the technology referenced
by NEEA is proprietary, and DOE is unable to conduct sufficient testing
on available proprietary technologies in applications to determine
achievable energy savings. Furthermore, NEEA has not presented data
demonstrating the viability of the asserted potential energy savings.
For these reasons, DOE is not proposing a test procedure accommodation
for pumps that incorporate self-sensing technologies at this time.
F. Calculation-Based and Testing-Based Options According to Pump
Configuration (Table 1)
The DOE test procedure for pumps includes calculation-based and
testing-based options that apply based on pump configuration (including
style of motor and control) as distributed in commerce. See appendix A,
Table 1. The calculation-based options rely on a bare pump test,
whereas the testing-based options rely on a ``wire-to-water'' test. The
calculation-based options may reduce test burden by allowing a
manufacturer to test a sample of bare pumps and use that data to rate
multiple pump configurations using calculation-based methods. On the
other hand, wire-to-water testing may more accurately represent pump,
motor, and control performance.
In order to further assess opportunity for reducing burden, DOE
requested additional information on how manufacturers are implementing
Table 1 of appendix A. Specifically, DOE sought comment on the extent
to which pumps sold with multiple motor and control configurations are
evaluated multiple times using physical testing-based methods (rather
than a calculation-based approach); the extent to which pumps sold with
single-phase motors are being rated as bare pumps (using a calculation-
based approach); and the extent to which pumps sold with motors (other
than inverter-only motors) are having their efficiency being evaluated
using a calculation-based approach as opposed to a testing-based
approach. 86 FR 20075, 20082. DOE also requested comment on whether any
revisions to Table 1 of appendix A could be considered to maintain or
improve the information derived from the test procedure while reducing
burden with no impact on the PEI rating for currently regulated pumps.
Id.
HI stated that testing burdens typically cause manufacturers to
calculate losses based on the standard motor efficiency and that
approximately 1 percent of pumps are wire-to-water tested according to
section IV of the test procedure. HI stated that no products were
reported with wire-to-water testing on induction motors with controls
per section VI of the test procedure. (HI, No. 20 at p. 5) HI stated
that a majority of pumps with single-phase motors use the
[[Page 21290]]
bare pump PEI<INF>CL</INF> value; however, there are a small number of
these products that were wire-to-water tested. Id. Grundfos stated that
it utilized calculated methods wherever it was allowed, given what
Grundfos characterized as the overly burdensome testing required to
qualify the most efficient products running inverter-only motors.
Grundfos stated that it conducted no testing using Section IV or
Section VI for any product using an induction motor and reported all
single-phase equipment using Section III. (Grundfos, No. 17 at p. 5)
Summit stated that it filed its certification reports using only
Section III, as they saw only minimal PEI improvement with section V,
and using section IV for ESCC pumps would be burdensome. (Summit, No.
16 at p. 5)
NEEA encouraged DOE to ensure the information derived from the test
procedure is maintained when considering possible changes to Table 1 to
reduce burden. Specifically, NEEA recommended against DOE removing
options for wire-to-water testing as a way to reduce burden and
asserted that wire-to-water testing may result in more accurate
ratings. NEEA also recommended that DOE not require wire-to-water
testing but keep the option to use calculation-based or wire-to-water
testing approaches. (NEEA, No. 21 at p. 10-11)
HI recommended amending Table I to allow use of section IV for
pumps + single-phase induction motor and to require section VI for
pumps + single-phase induction motor + continuous or non-continuous
controls. (HI, No. 20 at pp. 5-6). HI also recommended amending Table 1
to require section IV for pump + motor + controls other than continuous
or non-continuous controls (e.g., ON/OFF switches). (HI, No. 20 at pp.
5-6) Grundfos supported the edits to Table 1 as recommended by HI.
(Grundfos, No. 17 at p. 5-6) Grundfos additionally stated that because
single-phase motors are not completely regulated (currently only open
drip-proof motors are regulated), using section III for pump + motors
should remain, and section IV should be optional but not mandatory.
Grundfos commented that section VI testing for single-phase product
using a variable frequency drive (``VFD'') should be mandatory.
(Grundfos, No. 17 at p. 9)
DOE has reviewed the ways in which manufacturers are utilizing the
various options in Table 1 as well as the recommended edits to Table 1.
In response to NEEA, DOE is not proposing to remove wire-to-water
testing options from Table 1. In response to HI and Grundfos, DOE
agrees that Table 1 would benefit from providing more explicit
instruction, particularly by moving information out of footnotes and
into the table itself. However, DOE does not agree with the specific
changes requested. Specifically, commenters provided no reason that a
``pump + motor + controls,'' other than continuous or non-continuous
controls, must use a test method rather than a calculation method, or
why single-phase products using a VFD must use a test method rather
than the bare pump calculation method. Neither of these constraints are
currently included in appendix A Table 1. DOE maintains that the
existing allowances to use a calculation method for these products are
appropriate and consistent with stakeholders' general desire to use
calculation methods where possible. In particular, controls other than
continuous or non-continuous controls--such as ON/OFF switches--would
not be expected to impact the results of the test method. As such, the
calculation method should adequately represent performance. Similarly,
the current procedure permits single-phase equipment to be tested using
the bare pump method, which eliminates the possibility of penalizing
this equipment for using these less efficient motors compared to pumps
sold with polyphase motors. While manufacturers could choose to use a
testing-based approach when evaluating pumps sold with single-phase
induction motors that use continuous or non-continuous controls in
order to get a better rating than a bare pump rating, this is not
necessary. For these reasons, DOE is not proposing to remove the
calculation-based option, but is proposing to clarify Table 1 by moving
information out of footnotes and into the table itself.
NEEA encouraged DOE to consider developing a calculation-based
testing approach that would apply to any new or future pump
configurations not covered by the current Table 1. NEEA recommended
that DOE consider a hybrid approach to testing and calculation, similar
to the test method included in Appendix H of ANSI/AMCA Standard 214-21,
``Test Procedure for Calculating Fan Energy Index (FEI) for Commercial
and Industrial Fans and Blowers'' (``AMCA 214''), which stipulates a
one-time test of the motor at multiple load points, which can be used
to determine the input power at the appropriate pump test procedure
load points and then used to calculate a rating. With this method, each
motor need only be tested once, and the results used for multiple pump
configurations. (NEEA, No. 21 at p. 10)
The hybrid method as suggested by NEEA would require use of a test
procedure that may be dependent on the type of motor. As such, DOE
would be unable to implement such a method for unknown future pump
configurations without specifying all possible test methods that might
be appropriate for various motor types. Accordingly, DOE is declining
to adopt this suggested approach. DOE addresses a similar request
related to a specific motor type in section III.F.3 of this document.
Issue 25: DOE requests comment on whether manufacturers would use a
hybrid mapping approach, and if so, whether manufacturers would conduct
the motor tests or request the tests from their suppliers. In addition,
DOE requests comment on what additional provisions would need to be
added to Appendix H of AMCA 214 to make it applicable to pumps, such as
speed and load corresponding to pump rating points.
In relation to Table 1, Grundfos asked DOE to clarify how
manufacturers are expected to report pumps using single-phase motors.
Grundfos commented that these are sold as a pump + motor but reported
using section III data, and that it was unclear whether they should be
reported as a bare pump. (Grundfos, No. 17 at p. 5)
Under the current scope, actual pump configuration should be
certified for pumps sold with single-phase motors. These pumps should
not be certified as a bare pump.
1. Calculation Method for Pumps Sold With Induction Motors and Controls
In the April 2021 RFI, DOE noted that while its test procedure for
pumps incorporates by reference HI 40.6-2014, it also includes
additional provisions related to measuring the hydraulic power, shaft
power, and electric input power of pumps, inclusive of electric motors
and any continuous or non-continuous controls. 86 FR 20075, 20081. DOE
also noted the publication of the International Electrotechnical
Commission (``IEC'') standard IEC 61800-9-2:2017 ``Adjustable speed
electrical power drive systems--Part 9-2: Ecodesign for power drive
systems, motor starters, power electronics and their driven
applications--Energy efficiency indicators for power drive systems and
motor starters,'' (``IEC 61800-9-2:2017''), which addresses test
methods and reference losses for power drive systems, comparable to the
approach in section VII of appendix A. Id. DOE noted that the majority
of commenters responding to the
[[Page 21291]]
September 2020 Early Assessment RFI urged DOE to maintain the current
test approach in section VII of appendix A and that substituting IEC
61800-9-2 would add burden without achieving additional energy savings.
Id.
DOE also noted the publication of the American Movement and Control
Association (``AMCA'') standard, AMCA 207-17 ``Fan System Efficiency
and Fan System Input Power Calculation'' (``AMCA 207-17'') in the April
2021 RFI and requested comment on the applicability of the VFD/motor
efficiencies in AMCA 207-17 to pumps, and whether DOE should consider
replacing the calculations in section VII of appendix A with those in
AMCA 207-17. 86 FR 20075, 20081. DOE additionally requested comment on
whether adoption of the AMCA 207-17 approach would be representative
for pumps, and whether such a change would impact PEI ratings,
manufacturer testing burden, or manufacturer pump designs. Id. Finally,
DOE requested comment on whether it should consider incorporating any
aspect of ISO/ASME 14414 ``Pumps System Energy Assessment'' (``ISO ASME
14414'') into its test procedure for pumps, and if so, which aspects
and why. Id.
As stated previously, the DOE test procedure for pumps includes
calculation-based and testing-based options that apply based on pump
configuration (including style of motor and control) as distributed in
commerce. See appendix A, Table 1. The calculation-based options rely
on a bare pump test, whereas the testing-based options rely on a wire-
to-water test. Section VII of appendix A provides the calculation-based
testing method for pumps sold with motors and continuous controls--
specifically polyphase motors covered by DOE's electric motor energy
conservation standards or submersible motors. Section VII includes four
separate algorithms for determining part-load losses of the motor and
continuous controls together. These algorithms account for part-load
losses of the motor as well as additional losses that result from
continuous control inefficiencies and from increased inefficiencies in
the speed-controlled motor due to harmonic distortion as a function of
motor horsepower.
HI stated that the current calculation methodology should remain
consistent, but that HI would provide recommendations for updates to
coefficients that would not increase testing burden on pump
manufacturers. (HI, No. 20 at p. 4) HI additionally commented that ISO/
ASME 14414 is a pump system assessment standard and is not applicable
to individual bare pumps or pumps sold with motors and/or controls.
(HI, No. 20 at p. 5) Grundfos stated that there is no need to modify or
replace the Section VII calculation method. Grundfos supported the HI
recommendation to use updated coefficients in section VII for induction
equipment. (Grundfos, No. 17 at p. 4)
NEEA recommended that DOE continue using the current motor loss
calculation approach, including the motor and drive loss equation and
required test points for pump manufacturers. NEEA stated that the AMCA
207-17 approach would result in an average 3 to 6 percent reduction in
calculated motor and drive losses, and also PEI<INF>VL</INF>, in
comparison to the current DOE pumps test procedure. NEEA also commented
that, while the AMCA 207-17 approach could be considered more
representative of typical losses in comparison to test data, AMCA 207-
17 was developed specifically for fans. NEEA added that IEC 61800-9-2
results in a similar change in motor and drive losses and appears to be
achieving wider adoption in the industry. NEEA suggested that if DOE
were to consider updating the motor and drive losses in the test
procedure, NEEA would support aligning with IEC 61800-9-2 (and the
embedded standard IEC 60034-2, ``Rotating electrical machines--part 2-
3: Specific test methods for determining losses and efficiency of
converter-fed AC motors''). NEEA stated that updating the loss
calculations to reference AMCA 207-2017 or IEC 61800-9-2 would require
manufacturers to re-rate pumps for a difference in PEI<INF>VL</INF> of
only about 0.01. Instead, NEEA recommended that if DOE elects to pursue
updates to the losses, DOE should do so by updating the coefficients or
the calculations and make no changes to pump, motor, or drive testing.
NEEA stated that it is important that the calculation-based approach
result in conservative ratings so that manufacturers are not
disincentivized from testing equipment, which provides a more accurate
result, and are not able to overstate product performance based on the
calculation-based approach. (NEEA, No. 21 at pp. 7-8)
The CA IOUs stated that cost of wire-to-water testing can result in
the use of the calculation method for some efficient products, even
though the calculated PEI would be reduced via this method, creating a
market distortion in which efficient products are scored with PEIs
worse than would be representative. The CA IOUs commented that this
highlights the need for a calculation method to be as representative as
possible, while requiring some conservativeness in the calculation
methodology to prevent scores higher than wire-to-water testing of
conventional products. The CA IOUs stated that the actual motor drive
system performance is approximately 3 to 14 percent better in practice
than estimated with the current methodology and encouraged DOE to make
adjustments to the calculation method to improve the representativeness
and align across industries. (CA IOUs, No. 19 at p. 2)
The CA IOUs expressed support for the use of AMCA 207-17, stating
that it was designed for predictions based solely on variable-torque
curves, which apply to pumps, that it provides accurate and somewhat
conservative default losses, and that it has been directly or
indirectly adopted by various industry consensus standards. The CA IOUs
stated that the adoption of the AMCA 207-17 method would result in
manufacturers reporting lower PEIs without actually improving the
efficiency of the pump, but that they believe it is more important that
DOE adopt a loss calculation method that is representative and can be
used across all product lines that employ VFD power drive systems. The
CA IOUs included a figure comparing the percent PER improvement with
AMCA 207 losses compared to DOE losses, with PER improvements ranging
between 6 and 14 percent. (CA IOUs, No. 19 at pp. 2-4)
The CA IOUs also commented that industry stakeholders highlighted
IEC 61800-9-2 as a potential framework that could apply motor VFD
losses in an industry and product independent manner, and stated that
they provided a spreadsheet comparing this method, the AMCA 207 method,
and the existing DOE methods.\33\ The CA IOUs also stated that IEC
61800-9-2 provides high reference VFD losses that they expect to be
dealt with in the International Energy Agency Round Robin of Converter
Losses, Phase 2.\34\ (CA IOUs, No. 19 at pp. 4-7).
---------------------------------------------------------------------------
\33\ The docketed spreadsheet only includes a comparison of the
DOE method and the AMCA 207 method. (CA IOUs, No. 19, attachment).
\34\ For information on the International Energy Agency Round
Robin of Converter Losses, see: <a href="http://www.iea-4e.org/emsa/news/global-round-robin-test-program-for-converter-losses/">www.iea-4e.org/emsa/news/global-round-robin-test-program-for-converter-losses/</a>.
---------------------------------------------------------------------------
In a subsequent submission, HI stated that the current coefficients
for induction motors provide incremental losses well below the values
in IEC 60034-31, and that the percent of incremental losses were up to
4 times more than what IEC provides (primarily above 50 hp). HI stated
that it developed recommended coefficients using the delta between the
IEC and current motor incremental losses, and that the
[[Page 21292]]
modified coefficients provide more accurate, but still conservative,
PEI values for induction products. HI also recommended a separate set
of coefficients for the 50 to 100 hp range in order to provide more
accurate losses. (HI, No. 22 at p. 3)
HI also provided a table showing the delta PEI as a function of
horsepower with the proposed induction motor loss coefficients as well
as a limited data set of Section VI wire-to-water testing results
compared to the proposed Section VII induction motor loss calculations.
For three tested pumps, the calculation method was equivalent to or
more conservative than the wire-to-water test results. (HI, No. 22 at
p. 4)
Since ISO/ASME 14414 is a pump system assessment standard and is
not applicable to individual bare pumps or pumps sold with motors and/
or controls, DOE has tentatively determined that this industry standard
is not relevant to the DOE test procedure for pumps. DOE has reviewed
the industry standards mentioned by NEEA, the CA IOUs, and HI,
including AMCA 207-17, IEC 61800-9-2:2017, IEC 60034-2-3:2020 and IEC
60034-31:2021 (``Rotating Electrical Machines--Part 31: Selection of
Energy-Efficient Motors Including Variable Speed Applications--
Application Guidelines''). IEC 60034-2-3 is a method of test and does
not provide information related to motor and control part-load losses,
and as such DOE did not evaluate this method further. AMCA 207-17 is
specific to fans and includes a more complicated model with more than
three coefficients, resulting in efficiency rather than losses. IEC
60034-31:2021 is a technical specification document that gives
technical and economical guidelines for the use of energy-efficient
motors in constant speed and variable-speed operations in different
applications. Annex A (informative) to this standard further provides
typical efficiency values and losses of motors and controls. IEC 61800-
9-2:2017 is an international standard and provides test methods and
efficiency classification provisions for controls and for motors and
controls. Annex A (normative) to this standard further provides losses
for reference motors and controls used to develop the efficiency
classifications.
DOE has also reviewed the coefficients provided by HI, which HI
stated were designed to provide incremental motor losses similar to the
values in IEC 60034-31 when comparing an induction motor operated
without controls and with controls. (HI, No. 22 at p. 3) Based on a
subsequent submission, DOE understands that the intent of HI's
recommended coefficients is to better match the full-load losses that
would result from starting with motor-only full-load losses and adding
incremental harmonic losses of 15 percent for motors up to 90 kW and
adding incremental harmonic losses of 25 percent for motors over 90 kW,
as specified in section A.3 of IEC 60034-31, as well as adding an
assumed VFD efficiency penalty \35\ of 2 percent. (HI, No. 23 at p. 1)
---------------------------------------------------------------------------
\35\ Decrease in efficiency, in percentage points due to the
addition of a VFD.
---------------------------------------------------------------------------
Figures III-1 through III-3 \36\ show example plots for a 1 hp, 10
hp, and 25 hp power drive system (i.e., motor and controls), with the
efficiency plotted as a function of motor load for the existing DOE
loss model, HI's suggested loss model, AMCA 207, IEC 61800-9-2 (Annex
A), and IEC 60034-31 (Annex A).\37\ In addition, DOE has included AHRI
Standard 1210, ``Standard for Performance Rating of Variable Frequency
Drives,'' (``AHRI 1210'') certified data from 2016, 2020, and 2021 for
specific power drive systems to provide a point of comparison, noting
that this is a different test method and may not be directly comparable
to the other standards. DOE has developed these plots for other
horsepower drive systems, although the AHRI 1210 data do not go above
75 hp.\38\
---------------------------------------------------------------------------
\36\ Color versions of Figures 1-3 are available at Docket No.
EERE-2020-BT-TP-0032-0025.
\37\ In the IEC standards, the losses are a function of torque
and speed, not load. Load equals torque times speed; as such there
are multiple results at the same load depending on the torque/speed
point, and the average of those results is plotted.
\38\ Color versions of Figures III.1-III.3 are available at
Docket No. EERE-2020-BT-TP-0032-0025.
---------------------------------------------------------------------------
DOE notes that on February 28, 2022, the National Electric
Manufacturers Association (``NEMA'') released NEMA MG 1011-2022,
``Power Index Calculation Procedure--Standard Rating Methodology for
Power Drive Systems and Complete Drive Modules.'' While this NEMA
methodology does not addresses the default losses that are core to
DOE's pumps test procedure method, and, accordingly, would not be
considered within the context of the current rulemaking at hand, data
based on MG 1011-2022's methodology could prove useful in supplementing
already-collected data regarding part-load losses. To the extent that
information and data using MG 1011-2022 are available, DOE invites
interested parties to provide feedback and comment regarding their
respective experience with this NEMA testing standard.\39\
---------------------------------------------------------------------------
\39\ NEMA MG 1011-2022 defines a rating system for power drive
systems that is similar to PEI, although it is exclusive of the
driven load (i.e., pump, fan, compressor). The direct measurement
approach in the NEMA testing method relies on testing in accordance
with Section 7.7.1 or 7.7.2 of IEC 61800-9-2; the testing standard
also offers a calculation-based approach which includes default
losses for a premium efficiency motor, but not default losses for a
combined power drive system, as are needed for DOE's test procedure
for pumps. However, DOE recognizes the possibility that industry use
of this testing standard could encourage the collection of part-load
performance data, including part-load losses, for power drive
systems applied in pumping applications. These data could be used in
the future to supplement the AHRI 1210-certified data displayed in
Figures III.1-III.3 and help DOE better tailor potential energy
conservation standards for the pumps addressed by the current test
procedure rulemaking.
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[[Page 21293]]
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[[Page 21295]]
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BILLING CODE 6450-01-C
DOE's current test procedure provides a calculation method for
pumps sold with motors and controls in order to reduce testing burden
compared to wire-to-water testing. However, DOE did not intend for the
calculation method to be used for overrating pumps. None of the
commenters provided justification for their statements that actual
motor drive system performance is better than that assumed by the DOE
coefficients. At 1 hp, the DOE model seems to appropriately capture
motor drive system performance of the systems represented by the AHRI
1210 data (i.e., none of the systems represented would likely be
overrated using this model). However, while DOE based its model using
results relying on AHRI 1210-2011 testing to establish the maximum
values of the ratio of VFD and motor losses to the motor full-load
losses,\40\ current AHRI 1210 data for 10 hp to 50 hp motors show that
the current DOE model may be overstating motor drive system performance
across all loads. The curves for AMCA 207, IEC 60034-31, and HI's
proposed coefficients result in better motor drive system performance
compared to the DOE model at higher motor loads (with the exception of
IEC 60034-31 at 1 hp). However, some curves result in worse motor drive
system performance at lower motor loads compared to the DOE model since
the DOE model tends to be flatter than the other curves, particularly
in the 10-25 hp range. The relative efficiency difference between the
DOE model and the suggested model with the highest efficiency (i.e.,
the AMCA 207 curve) across the majority of the curve is 4 percent,
averaged across all horsepower sizes and loads.
---------------------------------------------------------------------------
\40\ 80 FR 17586, 17621 (April 1, 2015)
---------------------------------------------------------------------------
DOE notes that the motor load points do not necessarily correspond
to the pump test points in appendix A; if motors were sized such that
100 percent BEP flow represented 100 percent motor load, the points
would be relatively close. However, the current test procedure for bare
pumps assumes that motor sizing is based on 120 percent BEP flow, which
DOE understands to be more representative of typical use. Furthermore,
a recent DOE motor study shows that only three percent of commercial
sector motor system electricity consumption and six percent of
industrial motor system electricity consumption operate below 40
percent load factor.\41\ For these reasons, DOE expects that typical
motor load points for pumps would tend to be higher than those tested
according to AHRI 1210, and the higher load points represent a larger
contribution to the average measured power under the test procedure. As
such, DOE has tentatively determined that it is more important for the
selected model to accurately capture performance at higher loads.
Nevertheless, the best model that would be representative across all
loads without overrating efficiency depends
[[Page 21296]]
on the performance of the motor drive systems associated with the pumps
being evaluated. DOE does not have these specific data.
---------------------------------------------------------------------------
\41\ Prakash Rao et al., ``U.S. Industrial and Commercial Motor
System Market Assessment Report Volume 1: Characteristics of the
Installed Base,'' Prepared for the U.S. Department of Energy,
January 12, 2021, <a href="https://doi.org/10.2172/1760267">https://doi.org/10.2172/1760267</a>. (p. 173)
---------------------------------------------------------------------------
DOE notes that AMCA 207 is specific to fans. IEC 60034-31 is based
on ``typical'' values, which would be expected to overstate the
performance of at least some motor drive systems. Section 7.7 of that
testing standard states that Annex A may not be a good approximation of
loads less than 50 percent, which DOE notes may be a significant
portion of loads based on the pumps test procedure. Finally, HI's
proposed induction coefficients are based on typical harmonic losses
and typical VFD efficiency penalties. DOE believes that, at a minimum,
the VFD efficiency penalty may be understated and it is also not clear
if the typical harmonic losses associated with IE3 \42\ motors are
applicable to the U.S. market. Furthermore, HI's proposed inverter-only
coefficients, discussed in section III.F.2, result in a lower PEI than
a tested PEI in at least one instance (i.e. slightly overstate motor
drive system performance), and given that those coefficients were based
on HI's proposed induction coefficients and an assumed incremental
efficiency improvement between induction and inverter-only motors, DOE
expects that HI's proposed induction coefficients may also overstate
motor drive system performance. As seen in Figure III-1, IEC 61800-9-2
represents coefficients least likely to overstate motor drive system
performance; however, DOE understands that these coefficients are
undergoing IEC review.
---------------------------------------------------------------------------
\42\ ``IE3'' is the IEC designation for premium efficiency
motors. IE3, NEMA premium and Energy Independence and Security Act
(``EISA'') 2007 standards for electric motors are often considered
equivalent efficiency requirements, although the actual values
differ depending on pole/hp/enclosure.
---------------------------------------------------------------------------
Based on its review of available coefficients and part-load loss
data, DOE has tentatively determined that without further data
indicating that its current coefficients overstate motor drive system
losses for pumps, it will retain its current loss model for motors less
than 50 hp. DOE's current coefficients correspond to about 30 percent
added harmonic losses and a 3 percent VFD efficiency penalty. DOE would
consider revising its coefficients below 50 hp in accordance with the
method suggested by HI, or to harmonize with fans (AMCA 207) or with
international standards (IEC 60034-31 or IEC 61800-9-2), given
appropriate data specific to pumps. To ensure that the calculation
method does not overrate pumps while balancing stakeholders' requests
for representativeness, DOE is proposing to allow use of an AEDM, as
discussed in section III.I.2 of this document.
Issue 26: DOE requests: (1) Data indicating whether AHRI 1210-
certified data is applicable to pumps as well as any other applicable
part-load loss data; (2) data indicating whether 15 percent and 25
percent incremental losses, which are specified as part of IE3 ratings
that are not commonly used in the U.S., are applicable to the U.S. and
do not overstate performance, and if not, what incremental losses would
be appropriate to apply, and (3) data indicating an appropriate VFD
efficiency penalty by hp.
Given HI's statement that losses are especially overstated in the
50 hp to 100 hp range, DOE has reviewed its existing coefficients and
found that they result in a dip in full-load efficiency at 75 hp, which
would not be expected. In addition, the AHRI 1210-certified data is
limited to a maximum of 75 hp and does not exist at higher hp.
Furthermore, DOE's current coefficients in the 50 hp to 100 hp range
correspond to about 60 percent added harmonic losses and a 3 percent
VFD penalty, and, based on previous discussion of typical losses, DOE
has tentatively determined that these losses are too high.
In light of this situation, DOE proposes to update its coefficients
for motors rated at 50 hp and above. DOE has determined that HI's
approach is relatively reasonable, although the 2 percent VFD penalty
may be too low. To adjust its coefficients for motors 50 hp and above,
DOE started with the current DOE default losses for the motor-only at
full-load and added 15 to 25 percent losses, as applicable, as well as
a VFD efficiency penalty of 3 percent. DOE then adjusted the current
DOE default losses for the motor and control at 100 percent to match
the result of adding the incremental harmonic losses and VFD penalty
and applied the same adjustment factor to all load points. Table III.1
includes DOE's proposal for the induction motor and control part-load
loss coefficients.
[GRAPHIC] [TIFF OMITTED] TP11AP22.006
Issue 27: DOE requests comment on its proposed part-load loss
factors for induction motors and controls greater than 50 hp.
2. Calculation Method for Pumps Sold With Inverter-Only Motors (With or
Without Controls)
For pumps sold with motors or with motors and continuous or
noncontinuous controls that are rated using the calculation-based
approach, the nominal full-load motor efficiency used in determining
the PER<INF>CL</INF> or PER<INF>VL</INF> will be the value that is
certified to DOE as the nominal full-load motor efficiency in
accordance with the standards and test procedures for electric motors
at 10 CFR part 431, subpart B. Use of the certified motor efficiency is
available only for motors that are subject to DOE's test procedure for
electric motors and only pumps sold with motors subject to DOE's
electric motor test procedure and energy conservation standards are
able to utilize the calculation-based approach.
Inverter-only motors are currently not subject to DOE's electric
motor energy conservation standards, and as such, based on Table 1 in
appendix A, pumps with inverter-only motors currently require wire-to-
water testing. DOE
[[Page 21297]]
requested information and feedback on the categories of motors for
which DOE should consider allowing the application of the calculation-
based method in the April 2021 RFI. 86 FR 20075, 20082. Specifically,
DOE requested information on the categories of inverter-only motors
(e.g., electronically commutated motors (``ECMs''), permanent magnet
alternative current motors (``PMACs''), or other alternative current
(``AC'') induction motors) for which DOE should consider allowing the
application of the calculation-based method. Id. DOE also sought
feedback on the general approach for including default values and
equations to represent inverter-only motor performance. Id. DOE also
requested data and information to support the development of default
values for inverter-only motors (similar to the values developed for
submersible motors in Table 2 of appendix A) as well as equations that
would represent the part-load efficiency or losses of these motors
(similar to the equations developed for certain motor and drive
combinations in Table 4 of appendix A). Id. To the extent DOE should
consider a different approach, DOE requested information on the
methodology it should consider in addition to supporting data. Id.
Finally, DOE requested information on the percentage of pumps sold with
inverter-only motors without controls (which would be impacted by a
change in rating from PEI<INF>CL</INF> to PEI<INF>VL</INF>). Id.
HI stated that all inverter-only (synchronous) motors should have a
calculation method with similar methodology to ST pumps, but with
updated full-load motor efficiencies and loss coefficients. (HI, No. 20
at p. 6) Grundfos supported the creation of a calculation method for
inverter-only \43\ equipment that covers IE4 and IE5 \44\ motors and
controls. (Grundfos, No. 17 at p. 4) Additionally, Grundfos supported
HI's efforts to create a calculation-based method for inverter-only
motors with part-load loss coefficients specifically designed for
inverter-only products. Grundfos stated that the final proposal should
include both IE4 and IE5 calculation-based methods to reduce testing
burden. (Grundfos, No. 17 at p. 6)
---------------------------------------------------------------------------
\43\ Grundfos referenced induction-only motors, which DOE
understands to have been intended to be a reference to inverter-only
motors.
\44\ The International Electrotechnical Commission (``IEC'')
standards IEC 60034-30 for variable-speed electric motors
establishes an efficiency classification system for these motors.
Efficiency classes are designated as IE1, IE2, IE3, IE4, and IE5.
IE4 is an approximation of super premium efficiency motors and IE5
is the IEC designation for ultra-premium efficiency motors.
---------------------------------------------------------------------------
NEEA commented that inverter-only motors are increasing in
popularity because many inverter-only motors are represented as having
higher efficiencies than induction motors, especially at reduced
speeds, and that the variable-speed capabilities make them a compelling
choice in variable load pumping applications. (NEEA, No. 21 at p. 8)
NEEA also stated that while ECM motors are particularly common, there
is no technical limitation to other inverter-only motor types such as
permanent magnet and synchronous reluctance motors being used in clean
water applications. (NEEA, No. 21 at p. 8)
NEEA stated that while they supported wire-to-water testing as the
most accurate way to rate a pump and motor (and drive), the calculation
method of test is a conservative but economical option, and the
inability to rely on the calculation method may discourage
manufacturers from selling or developing these more efficient pump
systems. Therefore, NEEA recommended that DOE include a calculation
test method for inverter-only motors. NEEA stated that motor
efficiencies consistent with an IE4 efficiency level would be
appropriate for pumps. (NEEA, No. 21 at p. 8-9)
The CA IOUs supported calculation approaches for inverter-only
motor drive systems, provided that the calculation methodology can
reliably generate representative, but slightly conservative motor drive
system losses, in order to minimize potential market distortion. (CA
IOUs, No. 19 at p. 7) Additionally, the CA IOUs commented that, unlike
submersible motors, inverter-only motors are found in numerous
industries, sectors, and applications, so the motor losses table must
be aligned with other DOE and industry treatments of these motors. (CA
IOUs, No. 19 at p. 8) The CA IOUs stated that ECM performance between
products and manufacturers is likely similar enough to performance
variance typical of conventional induction motors that a loss table
could be developed with manufacturer-submitted data. The CA IOUs
commented that typical ECM motors will be using surface permanent
magnet architectures, while permanent magnet power drive systems will
use internal permanent magnet architectures, and that while these
differences may eventually result in diverging performance, at the
moment a single losses table may be sufficient. The CA IOUs recommended
that DOE verify this single losses table assumption. (CA IOUs, No. 19
at p. 8)
The CA IOUs recommended developing a conventional-efficiency branch
and a high-efficiency branch of a calculation method, for example by
referring to IEC 60034-30-2 and assigning conventional product losses
to products with an IE4 motor-drive system rating and efficient product
losses to products with an IE5 motor drive system rating. (CA IOUs, No.
19 at p. 8) For permanent magnet inverter-only motors with a non-
integrated controller sold with a choice of controller, the CA IOUs
cautioned against the use of a losses table due to variance in
performance between drive units (as opposed to induction motors, which
are relatively uninfluenced by choice of drive unit) and instead
recommended this subset use a hybrid power drive system mapping
procedure. The CA IOUs stated that this does not apply to ECM products
that typically have the drive embedded. (CA IOUs, No. 19 at pp. 8-9)
Ultimately, the CA IOUs recommended that DOE consider a hybrid testing
approach similar to that detailed in appendix F of AMCA 214, in which a
motor drive system is mapped at several test points, with interpolation
allowed between test points, which could be applied to any pumps that
would be connected to that power drive system. The CA IOUs estimated
that this approach would reduce test time compared to a wire-to-water
pump test. The CA IOUs suggested that manufacturers could choose to use
the calculation method or the hybrid mapping test method. (CA IOUs, No.
19 at pp. 9-10)
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\45\ HI provided the incremental loss delta values in a
subsequent submission. (HI, No. 23 at p. 1)
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In a subsequent submittal responding to the April 2021 RFI, HI
stated that it developed coefficients and calculation modifications for
inverter-only motors by establishing the incremental loss delta between
power drive systems operating with induction motors and power drive
systems operating with inverter-only motors.\45\ HI commented that it
used actual motor data from multiple manufacturers to calculate these
coefficients. The coefficients developed by HI would require using
either IE4 or IE5 minimum efficiencies (IEC 60034-30-2) in the Section
VII calculation for the equipped motor efficiency in appendix A. As
suggested by HI, IE3 efficiency would be used to calculate
PER<INF>STD</INF>. (HI, No. 22 at pp. 1-2) HI also provided limited
comparisons of the recommended inverter-only calculation method to test
data for IE5 products. In five out of six cases, the calculation method
resulted in a PEI
[[Page 21298]]
equivalent to or higher than the test method.\46\ (HI, No. 22 at p. 2)
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\46\ While the final column of Table 2 shows that in all six
cases, the calculation method resulted in a PEI equivalent to or
higher than the tested PEI, in one case the actual delta calculated
from columns three and five results in one case where the
calculation method results in a lower PEI than the test method.
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After reviewing the comments, DOE understands stakeholder
references to ``inverter-only motors'' to mean inverter-only electric
motors that are synchronous electric motors. DOE's current definition
of ``inverter-only motor'' at 10 CFR 431.12 also includes AC induction
motors.\47\
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\47\ DOE defines ``inverter-only electric motor'' in 10 CFR
431.12 as an electric motor that is capable of rated operation
solely with an inverter, and is not intended for operation when
directly connected to polyphase, sinusoidal line power.
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In the December 17, 2021, Electric Motors TP NOPR (``Motors TP
NOPR''), DOE describes a ``synchronous electric motor'' as an electric
motor in which the average speed of the normal operation is exactly
proportional to the frequency of power supply to which it is connected,
regardless of load. 86 FR 71710, 71726. DOE proposed to include within
the scope of its electric motors test procedure synchronous electric
motors with specific characteristics, inclusive of synchronous electric
motors that are inverter-only electric motors. 86 FR 71710, 71727.
As stated, only pumps sold with motors subject to DOE's electric
motor test procedure and energy conservation standards can be used to
conduct the calculation-based approach. The current electric motors
test procedures and standards apply only to induction electric motors,
and the ``induction motor'' criteria exclude synchronous electric
motors from scope. 10 CFR 431.25(g)(1). In this NOPR, DOE proposes
that, to the extent that DOE adopts a definition, test procedure, and
energy conservation standard for synchronous electric motors that are
inverter-only electric motors, DOE would reference such regulations in
the pumps test procedure, allowing for the use of the calculation
method by pumps sold with synchronous electric motors that are
inverter-only electric motors.
In the Motors TP NOPR, DOE proposed to test inverter-only
synchronous electric motors (inclusive of the inverter) that include an
inverter in accordance with Section 7.7.2 of IEC 61800-9-2:2017, using
the test provisions specified in section 7.7.3.5 and testing conditions
specified in section 7.10. 86 FR 71710, 71742. DOE proposed to test
inverter-only synchronous electric motors that do not include an
inverter in the same manner and to specify that testing must be
performed using an inverter as recommended in the manufacturer's
catalogs or offered for sale with the electric motor. Id. In response
to comments from HI, Grundfos, NEEA, and CA IOUs, rather than
referencing IE4 and IE5 motor efficiencies in the proposed calculation
method for pumps sold with inverter-only synchronous electric motors,
DOE proposes to require use of the nameplate efficiency of the
inverter-only synchronous electric motors tested in accordance with any
relevant test procedure in subpart B to part 431 if available, or if
none available, in accordance with the DOE test procedure, should it be
finalized. DOE notes that this nameplate efficiency, as proposed, would
be representative of the motor + inverter efficiency rather than just
the motor efficiency.
As proposed in the Motors TP NOPR, manufacturers of synchronous
electric motors would not be required to test according to the DOE test
procedure, if finalized, until the compliance date of energy
conservation standards. 86 FR 71710, 71716. Accordingly, should DOE
finalize a test procedure for these motors, there may be a period of
time in which motor manufacturers would not be required to publish
efficiency information for these motors. However, since the proposed
electric motors test procedure is an IEC test procedure, if DOE's
proposal is finalized, the tested efficiency of the synchronous
inverter-only electric motors + inverters would likely already be
available.
Issue 28: DOE requests comment on whether inverter-only motors used
by pump manufacturers are typically tested in accordance with IEC
61800-9-2:2017.
With respect to HI's proposal to use IE3 efficiency to calculate
PER<INF>STD</INF>, DOE maintains that the appropriate denominator for
pumps sold with inverter-only synchronous electric motors is the same
as for other pumps sold with motors (with or without controls)--i.e.,
the efficiency standards for NEMA Design B motors in 10 CFR 431.25 is
comparable to the PEI metric when comparing pumps across a common
baseline. Consequently, DOE is not proposing a revision to the
calculation of PER<INF>STD</INF> for these pumps.
With respect to part-load losses, while DOE does not have data to
evaluate the model quantitatively, DOE has plotted HI's suggested model
and preliminarily finds the resulting trends in losses to be reasonable
in relation to the expected loss differences between induction and
synchronous electric motors. Specifically, the suggested model shows
inverter-only motors to be more efficient at part-load when compared to
DOE's loss model for induction motors. Further, HI's suggested model
shows higher efficiency at full-load compared to DOE's loss model for
induction motors--an expected outcome given that induction motor
efficiency is set at a NEMA Premium level, whereas inverter-only
efficiency is Super Premium.
DOE notes that the HI-provided comparison of wire-to-water test
data with results from the c
[…truncated; see source link]This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.