Energy Conservation Program: Test Procedure for Pumps
Federal RegisterApr 1, 2015
Ask Donna
What actually matters in this document.
Text
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 431
[Docket No. EERE-2013-BT-TP-0055]
RIN 1905-AD50
Energy Conservation Program: Test Procedure for Pumps
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and public meeting.
SUMMARY:
The U.S. Department of Energy (DOE) proposes to establish a new test procedure for pumps. Specifically, DOE is proposing a test method for measuring the hydraulic power, shaft power, and electric input power of pumps, inclusive of electric motors and any continuous or non-continuous controls. The proposal, if adopted, would incorporate by reference the test procedure from the Hydraulic Institute (HI)—Standard 40.6-2014, “Methods for Rotodynamic Pump Efficiency Testing.” The proposed test procedure would be used to determine the constant load pump energy index (PEI
CL
) for pumps sold without continuous or non-continuous controls or the variable load pump energy index (PEI
VL
) for pumps sold with continuous or non-continuous controls. The PEI
CL
and PEI
VL
describe the power consumption of the rated pump, inclusive of an electric motor and, if applicable, any integrated continuous or non-continuous controls, normalized with respect to the performance of a minimally compliant pump for each pump basic model. The proposal reflects certain recommendations made by a stakeholder Working Group for pumps established under the Appliance Standards Rulemaking Federal Advisory Committee (ASRAC). DOE is also announcing a public meeting to discuss and receive comments on issues presented in this notice of proposed rulemaking (NOPR).
DATES:
DOE will hold a public meeting on Wednesday, April 29, 2015, from 9:00 a.m. to 1:00 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section IV.M, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this NOPR before and after the public meeting, but no later than June 15, 2015. See section IV.M, “Public Participation,” for details.
ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW., Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586-2945.
Persons can attend the public meeting via webinar. For more information, refer to the Public Participation section near the end of this proposed rule.
Comments may be submitted using any of the following methods:
1.
Federal eRulemaking Portal: www.regulations.gov.
Follow the instructions for submitting comments.
2.
Email: Pumps2013TP0055@ee.doe.gov.
Include the docket number and/or RIN in the subject line of the message.
3.
Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. If possible, please submit all items on a CD. It is not necessary to include printed copies.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all items on a CD. It is not necessary to include printed copies.
For detailed instructions on submitting comments and additional information on the rulemaking process, see section IV.M of this document (“Public Participation”).
Docket:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the regulations.gov index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/14.
This Web page will contain a link to the docket for this notice on the regulations.gov site. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket. See section IV.M for information on how to submit comments through regulations.gov.
For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Ms. Ashley Armstrong, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-6590. Email:
ashley.armstrong@ee.doe.gov.
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:
Michael.kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Incorporation by Reference Under 1 CFR part 51
DOE proposes to incorporate by reference the following industry standards into 10 CFR part 431:
(1) ANSI/HI Standard 1.1-1.2, (“ANSI/HI 1.1-1.2-2014”), “Rotodynamic (Centrifugal) Pumps For Nomenclature And Definitions;” approved 2014, sections 1.1, “Types and nomenclature,” and 1.2.9, “Rotodynamic pump icons.”
(2) ANSI/HI Standard 2.1-2.2, (“ANSI/HI 2.1-2.2-2008 ”), “Rotodynamic (Vertical) Pumps For Nomenclature And Definitions,” approved 2008, section 2.1, “Types and nomenclature.”
(3) HI 40.6-2014, (“HI 40.6-2014”), “Methods for Rotodynamic Pump Efficiency Testing,” except for section 40.6.5.3, “Test report;” section A.7, “Testing at temperatures exceeding 30 °C (86 °F);” and appendix B, “Reporting of test results,” approved 2014.
Copies of ANSI/HI 1.1-1.2-2014, ANSI/HI 2.1-2.2-2008 and HI 40.6-2014 can be obtained from: The Hydraulic Institute at 6 Campus Drive, First Floor North, Parsippany, NJ 07054-4406, or by going to
www.pumps.org.
(4) FM Class Number 1319, “Approval Standard for Centrifugal Fire Pumps (Horizontal, End Suction Type),” approved October 2008.
Copies of FM Class Number 1319 can be obtained from: Factory Mutual. 270 Central Avenue Johnston, RI 02919, 401-275-3000.
www.fmglobal.com/
.
(5) NFPA Standard 20-2013, “Standard for the Installation of Stationary Pumps for Fire Protection,” approved 2013.
Copies of NFPA Standard 20-2013 can be obtained from: The National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169, 617-770-3000.
www.nfpa.org.
(6) UL Standard 448-2007, “Centrifugal Stationary Pumps for Fire-Protection Service,” approved 2007.
Copies of UL Standard 448-2007 can be obtained from: The Underwriters Laboratory, 333 Pfingsten Road, Northbrook, IL 60062.
http://ul.com/.
Also, this material is available for inspection at U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, Sixth Floor, 950 L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, or go to
http://www1.eere.energy.gov/buildings/appliance_standards/.
These standards are discussed in more detail in section IV.M. of this document.
Table of Contents
I. Authority and Background
A. Authority
General Test Procedure Rulemaking Process
B. Background
II. Synopsis of the Notice of Proposed Rulemaking
III. Discussion
A. Scope
1. Definitions Related to the Scope of Covered Pumps
2. Equipment Classes
3. Scope Exclusions Based on Application
4. Parameters for Establishing the Scope of Pumps in This Rulemaking
5. Non-Electric Drivers
6. Pumps Sold With Single-Phase Induction Motors
B. Rating Metric
1. Working Group and Other Stakeholder Comments
2. Selected Metric: Constant Load and Variable Load Pump Energy Index
C. Determination of Pump Performance
1. Referenced Industry Standards
2. Minor Modifications and Additions to HI 40.6-2014
D. Determination of Motor Efficiency
1. Default Motor Efficiency
2. Determining Part Load Motor Losses
E. Test Methods for Different Pump Configurations
1. Calculation-Based Test Methods
2. Testing-Based Methods
3. Applicability of Calculation and Testing-Based Test Methods to Different Pump Configurations
F. Representations of Energy Use and Energy Efficiency
G. Sampling Plans for Pumps
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
1. Small Business Determination
2. Assessing the Number of Basic Models per Manufacturer
3. Burden of Conducting the Proposed DOE Pump Test Procedure
4. Capital Expense Associated With Constructing a Pump Testing Facility
5. Recurring Burden Associated With Ongoing Testing Activities
6. Cumulative Burden
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. Attendance at Public Meeting
B. Procedure for Submitting Prepared General Statements For Distribution
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
Pumps are included in the list of “covered equipment” for which DOE is authorized to establish and amend energy conservation standards and test procedures. DOE does not currently regulate the energy efficiency of this equipment or have test procedures to measure the efficiency of such equipment. 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 of 1975 (EPCA), Public Law 94-163, as amended by Public Law 95-619, Title IV, Sec. 441(a), established the Energy Conservation Program for Certain Industrial Equipment under Title III, Part C. (42 U.S.C. 6311-6317, as codified).
1
Included among the various types of industrial equipment addressed by EPCA are pumps, the subject of today's notice. (42 U.S.C. 6311(1)(A)) All references to EPCA refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18, 2012).
1
For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.
Under EPCA, the energy conservation program consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. The 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 under EPCA, (42 U.S.C. 6295(s) and 6316(a)(1)), and (2) making representations about the energy consumption of that equipment. (42 U.S.C. 6314(d))
General Test Procedure Rulemaking Process
EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered equipment. EPCA provides, in relevant part, that any test procedures prescribed or amended under this section shall be reasonably designed to produce test results that measure energy efficiency, energy use, or estimated annual operating cost of covered equipment during a representative average use cycle or period of use and shall not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2))
In addition, before prescribing any final test procedures, DOE must publish proposed test procedures and offer the public an opportunity to present oral and written comments on them. (42 U.S.C. 6314(b)(1)-(2))
DOE is authorized to prescribe energy conservation standards and corresponding test procedures for statutorily-covered equipment such as pumps. While DOE is currently evaluating whether to establish energy conservation standards for pumps, (Docket No. EERE-2011-BT-STD-0031), DOE must first establish a test procedure that measures the energy use, energy efficiency, or estimated operating costs of a given type of covered equipment before establishing any new energy conservation standards for that equipment.
See generally
42 U.S.C. 6295(r) and 6316(a).
To fulfill these requirements, DOE is proposing to establish a test procedure for pumps concurrent with its ongoing energy conservation standards rulemaking for this equipment.
See
Docket No. EERE-2011-BT-STD-0031. The test procedure, if adopted, would include the methods necessary to: (1) Measure the performance of the covered equipment; and (2) use the measured results to calculate a pump energy index (PEI
CL
for pumps sold without continuous or non-continuous controls or PEI
VL
for pumps sold with continuous or non-continuous controls) to represent the power consumption of the pump, inclusive of a motor
2
and
any continuous or non-continuous controls, normalized with respect to the performance of a minimally compliant pump. DOE is also proposing to set the scope of those pumps to which the proposed test method would apply. DOE's proposals reflect certain recommendations made by a stakeholder Working Group for pumps established under the Appliance Standards Rulemaking Federal Advisory Committee (ASRAC), which is discussed further in section I.B. This group consisted of a wide variety of interested parties with a diverse set of interests with respect to pump efficiency.
2
DOE is proposing to include pumps sold with all electric motors except single-phase induction motors in the scope of this rulemaking. The terms
“motor” and “electric motor” are used synonymously and interchangeably in this document to refer to those motors to which the proposed test procedure would apply (
i.e.,
all electric motors except single-phase induction motors). See section III.A.6.
If adopted, manufacturers would be required to use the proposed test procedure and metric when making representations regarding the energy use of covered equipment 180 days after the publication date of any applicable energy conservation standards final rule for those pumps that are addressed by the test procedure.
See
Docket No. EERE-2011-BT-STD-0031).
See also
42 U.S.C. 6314(d).
B. Background
DOE does not currently regulate pumps. In 2011, DOE issued a Request for Information (RFI) to gather data and information related to pumps in anticipation of initiating rulemakings to formally consider test procedures and energy conservation standards for this equipment. 76 FR 34192 (June 13, 2011). In February 2013, DOE published a Notice of Public Meeting and Availability of the Framework Document to initiate the energy conservation standard rulemaking for pumps. 78 FR 7304 (Feb. 1, 2013). DOE posted the February 2013 Framework Document (“Framework Document”) to its Web site.
3
In the Framework Document, DOE requested feedback from interested parties on how to test pump efficiency. DOE held a public meeting to discuss the Framework Document on February 20, 2013 (the “Pumps Framework Public Meeting”). While the comment period had been scheduled to close on March 18, 2013, DOE extended the comment period to May 2, 2013, to allow commenters sufficient time to formulate responses to the large number and broad scope of questions and issues raised by DOE in the Framework Document.
See
78 FR 11996 (Feb. 21, 2013). DOE received 12 comments in response to the Framework Document.
3
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/14.
Concurrent with these efforts, DOE also began a process through the ASRAC to discuss conducting a negotiated rulemaking to develop standards and test procedures for pumps as an alternative to the route DOE had already begun. (Docket No. EERE-2013-BT-NOC-0039)
4
On July 23, 2013, DOE published a notice of intent to establish a negotiated rulemaking working group for commercial and industrial pumps (“CIP Working Group” or, in context, “Working Group”) to negotiate, if possible, Federal standards for the energy efficiency of commercial and industrial pumps. 78 FR 44036. On November 12, 2013, DOE published a notice to announce the first meeting of the CIP Working Group and listed the 14 nominees that were selected to serve as members of the Working Group, in addition to one member from ASRAC and one DOE representative. 78 FR 67319. The members of the Working Group were selected to ensure a broad and balanced array of stakeholder interests and expertise, including representatives from efficiency advocacy organizations, manufacturers, and a utility (representing a user of pumps). Table I.1 lists the members and their affiliations.
4
Information on the ASRAC, about the commercial and industrial pumps working group, and about meeting dates is available at
http://energy.gov/eere/buildings/appliance-standards-and-rulemaking-federal-advisory-committee.
Table I.1—ASRAC Pump Working Group Members and Affiliations
Member
Affiliation
Lucas Adin
U.S. Department of Energy.
Tom Eckman
Northwest Power and Conservation Council (ASRAC Member)
Robert Barbour
TACO, Inc.
Charles Cappelino
ITT Industrial Process.
Greg Case
Pump Design, Development and Diagnostics.
Gary Fernstrom
Pacific Gas & Electric Company, San Diego Gas & Electric Company, Southern California Edison, and Southern California Gas Company.
Mark Handzel
Xylem Corporation.
Albert Huber
Patterson Pump Company.
Joanna Mauer
Appliance Standards Awareness Project.
Doug Potts
American Water.
Charles Powers
Flowserve Corporation, Industrial Pumps.
Howard Richardson
Regal Beloit.
Steve Rosenstock
Edison Electric Institute.
Louis Starr
Northwest Energy Efficiency Alliance.
Greg Towsley
Grundfos USA.
Meg Waltner
Natural Resources Defense Council.
The Working Group commenced negotiations at an open meeting on December 18 and 19, 2013, and held six additional meetings and two webinars to discuss scope, metrics, test procedures, and standard levels for pumps.
5
The CIP Working Group concluded its negotiations on June 19, 2014, with a consensus vote to approve a term sheet containing recommendations to DOE on appropriate standard levels for pumps as well as recommendations addressing issues related to the metric and test procedure for pumps (“Working Group Recommendations”).
6
The term sheet containing the Working Group Recommendations is available in the CIP Working Group's docket. (Docket No. EERE-2013-BT-NOC-0039, No. 92) ASRAC subsequently voted unanimously to approve the Working Group Recommendations during a July 7, 2014 webinar.
5
Details of the negotiation sessions can be found in the public meeting transcripts that are posted to the docket for the Working Group (
http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-NOC-0039
).
6
The ground rules of the CIP Working Group define consensus as no more than two (2) negative votes. (Docket No. EERE-2013-BT-NOC-0039, No. 18 at p. 2) Concurrence was assumed if absent, and overt dissent evidenced by a negative vote. Abstention was not construed as a negative vote. In this NOPR, only negative votes are discussed.
Those recommendations regarding issues pertinent to the test procedure and standard metric are addressed in this NOPR and reflected in DOE's proposed pump test procedure. In this NOPR, DOE also refers to discussions from the CIP Working Group meetings regarding potential actions that may not have been formally approved as an addition to the Working Group Recommendations. All references to approved recommendations will be specified with a citation to the Working Group Recommendations and noting the recommendation number (for example: Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #X at p. Y); references to discussion or suggestions of the CIP Working Group not found in the Working Group Recommendations will have a citation to meeting transcripts (for example: Docket No. EERE-2013-BT-NOC-0039, No. X at p. Y).
DOE notes that many of those who submitted comments on the Framework Document later became members of the CIP Working Group. As such, the concerns of these commenters were fully discussed as part of the meetings, and their positions may have changed as a result of the compromises inherent in a negotiation. The proposals in this NOPR incorporate and respond to several issues and recommendations that were raised in response to the Framework Document. However, where a framework commenter became a member of the CIP Working Group, DOE does not reference or respond to comments made by that stakeholder regarding issues that were later discussed or negotiated in the CIP Working Group. Table I.2 lists the framework commenters as well as whether they participated in the CIP Working Group.
Table I.2—List of Framework Commenters
Commenter
Member of the CIP Working Group
Engineered Software, Inc.
No.
Richard Shaw
No.
Grundfos Pumps Corporation
Yes.
Hydraulic Institute (HI)
Yes.
Pacific Gas and Electric Company, San Diego Gas and Electric, Southern California Gas Company, and Southern California Edison (collectively, “the CA IOUs”)
Yes.
National Fire Protection Association (NFPA)
No.
Air-Conditioning, Heating, and Refrigeration Institute (AHRI)
No.
Colombia Engineering
No.
Earthjustice
No.
Edison Electric Institute (EEI)
Yes.
The Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), American Council for an Energy Efficient Economy (ACEEE), Earthjustice, and Natural Resources Defense Council (NRDC) (collectively, “the Advocates”)
ASAP and NRDC.
Northwest Energy Efficiency Alliance and the Northwest Power and Conservation Council (collectively, “NEEA/NPCC”)
Yes.
II. Synopsis of the Notice of Proposed Rulemaking
DOE is proposing to establish a new subpart Y to part 431 of Title 10 of the
Code of Federal Regulations
that would contain definitions and a test procedure applicable to pumps. Today's NOPR also contains related proposals for sampling plans for the purposes of demonstrating compliance with any energy conservation standards for pumps that DOE adopts. As part of the test procedure, DOE proposes to prescribe test methods for measuring the energy consumption of pumps, inclusive of motors and controls (continuous or non-continuous), if they are included with the pump when distributed in commerce. To do this, DOE's proposed test procedure includes measurements and calculations of the produced hydraulic power, pump shaft input power, electric input power to the motor, and electrical input power to the continuous or non-continuous controls, as applicable.
Consistent with the Working Group Recommendations, DOE proposes that these test methods be in accordance with HI Standard 40.6-2014, “Methods for Rotodynamic Pumps Efficiency Testing,” (“HI 40.6-2014”), with slight modifications as noted in section III.C.2. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #10 at p. 4) Members of the pumps industry developed HI 40.6-2014, which contains methods for determining the energy performance of rotodynamic pumps without accounting for the impact of continuous or non-continuous controls. HI 40.6-2014 was developed following DOE's announcement in the Framework Document that DOE planned to develop a test procedure for pumps. In this NOPR, DOE also proposes to include testing and calculation methods to account for the energy performance of pumps sold with motors and continuous or non-continuous controls. DOE has reviewed HI 40.6-2014 and finds, for the reasons stated below and in detail in section III,
that the procedure would be likely to produce test results that would reflect the energy efficiency, energy use, and estimated operating costs of a pump during a representative average use cycle. (42 U.S.C. 6314(a)(2)) DOE also has reviewed the burdens associated with conducting the proposed test procedure, including HI 40.6-2014 and, based on the results of such analysis, finds the proposed test procedure would not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)) DOE's analysis of the burden associated with the proposed test procedure is presented in detail in section IV.B.
DOE's approach, which is consistent with the Working Group's recommendations, proposes to use a new metric, the pump energy index (PEI), to rate the energy performance of pumps covered by this proposed test procedure. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #11 at p. 5) The proposed test procedure contains methods for determining the constant load PEI (PEI
CL
) for pumps sold without continuous or non-continuous controls and the variable load PEI (PEI
VL
) for pumps sold with either continuous or non-continuous controls. The PEI
CL
or PEI
VL
, as applicable, describes the weighted average performance of the rated pump, inclusive of any motor and, if included, continuous or non-continuous controls, at specific load points, normalized with respect to the performance of a minimally compliant pump without controls. These indices, if adopted, would provide a representative measurement of the energy consumption of the rated pump under expected conditions of use since they are inclusive of a motor and any continuous or non-continuous controls at full and partial loading. The indices would also describe the performance of the rated pump in comparison to a minimally compliant pump of the same equipment class with no controls (see section III.A.2 for a discussion of pump equipment classes) and provide a description of a covered pump's energy performance that can be readily interpreted and used by customers and the market.
The proposed test procedure contains methods to determine the appropriate index for all equipment for which this test procedure would apply using either calculation-based methods and/or testing-based methods. While both methods include some amount of testing and some amount of calculation, the terms “calculation-based” and “testing-based” are used to distinguish between methods in which the input power to the pump is determined either by (a) measuring the pump shaft input power
7
and combining it with the efficiency, or losses, of the motor and any continuous control
8
at specific load points using an algorithm (
i.e.,
calculation-based method) or (b) measuring the input power to the driver,
9
or motor, and any continuous or non-continuous controls
10
for a given pump directly at each of the load points (
i.e.,
testing-based method). In both cases, the results for the given pump are divided by the calculated input power to the motor for a hypothetical pump (sold without a motor or controls) that serves an identical hydraulic load and minimally complies with any energy conservation standards that DOE may set as a result of the ongoing standards rulemaking. (Docket No. EERE-2011-BT-STD-0031) This normalized metric would effectively result in a value that is indexed to the standard (
i.e.,
a value of 1.0 for a pump that is minimally compliant, and a value less than 1.0 for a pump that is less consumptive than the maximum the standard allows).
7
The term “pump shaft input power” is referred to as “pump power input” in HI 40.6-2014. The term “pump shaft input power” is used synonymously with that term in this document.
8
DOE notes that for non-continuous controls, as defined in section III.E.1.c, PEI
VL
can only be determined using a “testing-based” method. If a calculation-based method is desired, the pump would instead be rated as a pump sold with a motor and without speed controls using the PEI
CL
metric. See section III.E.1.c for further discussion.
9
The input power to the driver is referred to as “driver power input” in HI 40.6-2014. The term “input power to the driver” is used synonymously with that term in this document.
10
In the case that a pump is sold with a motor equipped with either continuous or non-continuous controls and is rated using the testing-based method, the input power to the pump would be determined as the input power to the continuous or non-continuous control. See section III.E.2.c.
DOE notes that the calculation-based method discussed in section III.E.1 would only apply to certain pumps: (1) Pumps sold without either a motor or controls (
i.e.,
“bare pump,” discussed later in section III.A.1.a), (2) pumps sold with motors that are subject to DOE's energy conservation standards for electric motors (with or without continuous controls), and (3) pumps sold with submersible motors (with or without continuous controls). This is because for other pumps, the necessary efficiency information is not available in a standardized, referenceable format and the assumptions inherent in the calculation-based approach do not apply. Specifically, for pumps sold with motors that are not subject to DOE's energy conservation standards for electric motors, except submersible motors, DOE has not established standards or default values for the nominal full load efficiency that can be used in the calculations. For pumps sold with any motors (
i.e.,
covered, uncovered, or submersible motors) and non-continuous controls, the reference system curve is not applicable (see section III.E.1.c for more information). Under DOE's proposal, such pumps would be required to be tested using the testing-based methods discussed in section III.E.2. Conversely, only the proposed calculation-based method could be used to test a pump sold without a motor or controls because a PEI rating (which includes the efficiency of the motor) could not be determined based on a test of the pump without a motor. The specific test methods applicable to each class and configuration of pump model are described in more detail in section III.E.3.
DOE also proposes to establish requirements regarding the sampling plan and representations for covered pumps at subpart B of part 429 of Title 10 of the Code of Federal Regulations. The proposed sampling plan requirements are similar to those for several other types of commercial equipment and are appropriate for pumps based on the expected range of measurement uncertainty and manufacturing tolerances for this equipment. Regarding representations, for those pumps addressed by this proposal, DOE is also specifying the energy consumption or energy efficiency representations that may be made, in addition to the regulated metric (PEI
CL
or PEI
VL
).
DOE notes that equipment meeting the proposed pump definition is already covered equipment. However, DOE's proposal is more narrowly applied to a specific scope of pumps. Specifically, this proposal would apply to the limited scope of rotodynamic pumps
11
for which standards are being considered in DOE's energy conservation standards rulemaking and as proposed in section III.A of this NOPR. (Docket No. EERE-2011-BT-STD-0031) Manufacturers of those pumps that would be regulated as a result of DOE's parallel test procedure and standards rulemakings would be required to use the test procedure DOE adopts when certifying compliance with any applicable standard and when
making representations about the efficiency or energy use of their equipment. (42 U.S.C. 6314(d))
11
A rotodynamic (or centrifugal) pump is a kinetic machine that continuously imparts energy to the pumped fluid by means of a rotating impeller, propeller, or rotor. This is in contrast to positive-displacement pumps, which have an expanding cavity on the suction side and a decreasing cavity of the discharge side that move a constant volume of fluid for each cycle of operation. DOE is proposing limiting the scope of the test procedure to only specific kinds of rotodynamic pumps.
Starting on the compliance date for any energy conservation standards that DOE may set, and assuming that the provisions of this NOPR are adopted, all pumps within the scope of those energy conservation standards would be required to be tested in accordance with the proposed subpart Y of part 431 and must have their testing performed in a manner consistent with the applicable sampling requirements. Similarly, all representations regarding the energy efficiency or energy use of pumps within the scope of pumps proposed for coverage by this test procedure would be required to be made based on the adopted pump test procedure 180 days after the publication date of any final rule establishing energy conservation for those pumps that are addressed by the test procedure.
See
42 U.S.C. 6314(d).
III. Discussion
DOE's proposal would place a new pump test procedure and related definitions in a new subpart Y of part 431, and add new sampling plans and reporting requirements for this equipment in a new section 429.59 of 10 CFR part 429. This proposed subpart Y would contain definitions, materials incorporated by reference, and the test procedure for certain classes and configurations of pumps established as a result of this rulemaking, as well as any energy conservation standards for pumps resulting from the ongoing energy conservation standard rulemaking, as shown in Table III.1. (Docket No. EERE-2011-BT-STD-0031)
Table III.1—Summary of Proposals in This NOPR, Their Location Within the Code of Federal Regulations, and the Applicable Preamble Discussion
Location
Proposal
Summary of additions
Applicable preamble discussion
10 CFR 429.59
*
Sampling Plan
Number of pumps to be tested to rate a pump basic model and calculation of rating
Section III.G.
10 CFR 431.461
Purpose and Scope
Scope of pump regulations, as well as the proposed test procedure and associated energy conservation standard
Section III.A.
10 CFR 431.462
Definitions
Definitions pertinent to establishing equipment classes and testing applicable classes of pumps
Section III.A.
10 CFR 431.463
Incorporation by Reference
Description of industry standards incorporated by reference in the DOE test procedure or related definitions
Section III.A and III.C.
10 CFR 431.464 and Appendix A to Subpart Y of Part 431
Test Procedure
Instructions for determining the PEI
CL
or PEI
VL
for applicable classes of pumps
Section III.B, III.C, III.D, and III.E.
10 CFR 431.466
Energy Conservation Standards
Energy conservation standard for applicable classes of pumps, in terms of PEI and associated C-Value
Section Error! Reference source not found. and Docket EERE-2011-BT-STD-0031.
* Note: DOE also proposes minor modifications to 10 CFR 429.2; 429.11(a) and (b); 429.70; 429.72; and 429.102 to apply the general sampling requirements established in these sections to the equipment-specific sampling requirements proposed for pumps at 10 CFR 429.59.
The following sections discuss DOE's proposals regarding establishing new testing and sampling requirements for pumps, including: Scope; rating metric; determination of pump performance; determination of motor efficiency; test methods for different combinations of pumps and drivers and controls; representations; and sampling plans.
A. Scope
Although a “pump” is listed as a type of covered equipment under EPCA, that term is undefined.
See
42 U.S.C. 6311(1)(A). As part of its collective efforts to help DOE craft an appropriate regulatory approach for pumps, the CIP Working Group made a series of recommendations regarding a variety of potential definitions that would have an impact on the overall scope and structure of the proposed test procedure and related energy conservation standards. In particular, the Working Group offered a definition for “pump” along with other related terms “bare pump,” “mechanical equipment,” “driver,” and “controls.” Each of these terms relate to particular pump components that are germane to DOE's efforts to set standards and establish a test procedure for this equipment. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendations #1 and 2 at pp. 1-2) Accordingly, DOE proposes to adopt these recommended definitions for these terms.
DOE notes that while the proposed definition of “pump” is broad, the scope of prospective energy conservation standards, as recommended by the Working Group, would be limited to a more narrow range of equipment. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendations #4 and 6-8 at pp. 2-4) DOE also notes that the scope of this proposed test procedure is intended to be consistent with the scope of the parallel standards rulemaking effort currently under evaluation. In other words, DOE proposes that only pumps subject to an energy conservation standard would have to be tested in accordance with the adopted test procedure. Finally, DOE notes that the broad definition of “pump” being considered in this proposal would provide DOE with flexibility to make any necessary adjustments to its regulations to address potential scoping changes in the future that DOE may consider.
After considering the Working Group Recommendations, DOE is proposing to define which pumps would need to be tested with the proposed test procedure by applying three criteria: (1) The equipment class; (2) the application; and (3) applicable performance specifications—
i.e.,
horsepower (hp), flow rate, head, design temperature, and speed restrictions. For these three areas, DOE's proposed criteria for establishing which pumps would be subject to the proposed test procedure are discussed in sections III.A.2, III.A.3, and III.A.4, respectively.
DOE requests comment on its proposal to match the scopes of the pump test procedure and energy conservation standard rulemakings, as recommended by the Working Group.
1. Definitions Related to the Scope of Covered Pumps
To help set the scope for this proposal and the manner in which both the procedure and related standards would
be applied to different pump configurations and classes of pumps, the aforementioned definitions for pump, certain pump components, and others, are discussed in the following subsections.
a. Pumps and Related Components
DOE proposes to include definitions in a new 10 CFR 431.462 that would describe the components comprising a pump for scoping purposes. Consistent with the intent of the Working Group Recommendations, DOE proposes to define the following terms:
(1) Pump means equipment that is designed to move liquids (which may include entrained gases, free solids, and totally dissolved solids) by physical or mechanical action and includes at least a bare pump and, if included by the manufacturer at the time of sale, mechanical equipment, driver and controls.
(2) Bare pump means a pump excluding mechanical equipment, driver, and controls.
Mechanical equipment means any component of a pump that transfers energy from a driver to the bare pump.
Driver means the machine providing mechanical input to drive a bare pump directly or through the use of mechanical equipment. Examples include, but are not limited to, an electric motor, internal combustion engine, or gas/steam turbine.
Control means any device that can be used to operate the driver. Examples include, but are not limited to, continuous or non-continuous speed controls, schedule-based controls, on/off switches, and float switches.
(Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendations #1-2 at pp. 1-2)
DOE notes that, while there was consensus among the members of the Working Group in favor of these definitions as part of the entirety of the Working Group Recommendations, there was one Working Group member who specifically objected to the “pump” definition that the Working Group developed,
12
see Recommendation #1.
12
The voting procedures and consensus requirements agreed upon by the CIP Working Group did not require identification of the individual opposing or their reason for opposition and so is not noted in the transcript for that public meeting. (See ground rules: Docket No. EERE-2013-BT-NOC-0039, No. 18; and the public meeting transcript: Docket No. EERE-2013-BT-NOC-0039, No. 46 at p. 165)
DOE requests comment on the proposed definitions for “pump,” “bare pump,” “mechanical equipment,” “driver,” and “control.”
b. Definition of Categories of Controls
The definition of “control” proposed by DOE and recommended by the CIP Working Group is broad. DOE acknowledges the proposed definition may be include many different kinds of electronic or mechanical devices that can “control the driver” of a pump (
e.g.,
continuous or non-continuous speed controls, timers, and on/off switches). These various controls may use a variety of mechanisms to control the pump for operational reasons, which may or may not result in reduced energy consumption.
For this proposed test procedure, DOE is focusing on those controls that reduce energy consumption—
i.e.,
controls that reduce pump power input at a given flow rate. As discussed by the CIP Working Group, DOE understands that speed controls achieve this goal and are the most common kind of control currently applied to pumps. After carefully examining the pump market, DOE has not found any mechanisms for controlling pump drivers that would reduce pump power input at a given flow other than those mechanisms used to control the driver's rotating speed. Consistent with this finding, DOE's proposal to establish test methods for those configurations in which a bare pump is configured with motors that have been paired with controls would address only such configurations using speed controls. Similarly, DOE also proposes that the PEI
VL
metric would only apply to pumps sold with motors and speed controls. Conversely, pumps sold with motors and controls other than speed controls would be subject to the appropriate bare pump and motor test procedures and rated using PEI
CL
.
To explicitly establish the kinds of controls that can apply the PEI
VL
metric, DOE would define the terms “continuous” and “non-continuous” control (see section III.B.2 and III.E.3 for further discussion of the PEI
VL
rating metric and its applicability to pumps with controls, respectively):
(1)
Continuous control
means 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.
13
As an example, variable speed drives, including variable frequency drives and electronically commutated motors (ECMs) would meet the definition for continuous controls.
13
HI-40.6, as incorporated by reference, defines pump power output as “the mechanical power transferred to the liquid as it passes through the pump, also known as pump hydraulic power.”
(2)
Non-continuous control
means 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. As an example, multi-speed motors such as 2-speed motors would meet the definition for non-continuous controls.
While the proposed PEI
VL
test procedure would only apply to pumps sold with continuous and non-continuous controls, DOE recognizes that including a broader definition of “control” provides the flexibility to address additional kinds of controls in future test procedure revisions, as was discussed in the CIP Working Group. (EERE-2013-BT-NOC-0039, No. 46 at pp. 179-85) To retain this flexibility, DOE proposes to maintain the broad definition of control presented above, which would include any device that operates a pump driver, regardless of its impact on energy consumption or rotational speed of the driver. However, pumps with a motor and controls that do not meet the proposed definitions of continuous or non-continuous controls would be required to be tested as a pump sold with a motor under the proposed test procedure.
DOE also notes that the definitions of continuous and non-continuous controls do not require the control to include the necessary sensors and feedback logic to automatically respond to changes in the required flow, head, or pump power output. DOE recognizes that such continuous or non-continuous controls (
e.g.,
variable speed drives (VSDs) or multi-speed motors, respectively) will not reduce energy consumption unless some feedback is provided regarding the process requirements at any given time. However, DOE understands that many applications use such controls as part of a larger process or facility-wide energy management system. Similarly, such feedback sensors and control logic may also be custom-designed based on an application's specific design requirements. Consequently, while sensors and logic to enable automatic feedback and response of any speed control are available from pump manufacturers, they are not always required by, or included in, a given pump at the time of sale.
In summary, by not requiring continuous or non-continuous controls to be automatically actuating when distributed in commerce, DOE seeks to limit the costs and burdens of adding continuous or non-continuous controls to a given pump. Furthermore, DOE believes that the incremental cost of any continuous or non-continuous control is sufficiently high, making it extremely unlikely that a customer would buy a pump with such controls and not employ appropriate and application-specific sensors and feedback logic to achieve energy savings. As such, DOE is
proposing to define continuous and non-continuous controls as devices that “adjust the speed” of the driver without requiring that adjustment to happen automatically.
DOE requests comment on the proposed definitions for “continuous control” and “non-continuous control.”
DOE also requests comment on the likelihood of a pump with continuous or non-continuous controls being distributed in commerce, but never being paired with any sensor or feedback mechanisms that would enable energy savings.
c. Definition of Basic Model
In the course of regulating consumer products and commercial and industrial equipment, DOE has developed the concept of a “basic model” to determine the specific product or equipment configuration(s) to which the regulations would apply. For the purposes of applying the proposed pumps regulations, DOE is also proposing to define what constitutes a “basic model” of pump. Applying this basic model concept would allow manufacturers to group similar models within a basic model to minimize testing burden. In other words, manufacturers would need to test only a representative number of units of a basic model in lieu of testing every model they manufacture. By grouping models together, a manufacturer would be able to test a smaller number of units. However, manufacturers would need to make this decision with the understanding that there is increased risk associated with these groupings due to the potential for a wider impact from a noncompliance finding. Basic model groupings increase this risk because, if DOE determines a basic model is noncompliant, all models within the basic model are determined to be noncompliant.
In keeping with this practice, DOE also proposes to define a “basic model” for pumps so manufacturers can determine the pump models on which they must conduct testing to demonstrate compliance with a prospective energy conservation standard for pumps. The proposal would define a “basic model” in a manner similar to that for other commercial and industrial equipment, with the exception of two pump-specific issues. For most commercial and industrial equipment, DOE defines basic model to include all units of a given product or equipment type (or class thereof) manufactured by one manufacturer, having the same primary energy source, and having essentially identical electrical, physical, and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency, water consumption, or water efficiency.
For the purposes of establishing a basic model definition for pumps, DOE proposes modifying the general definition by addressing two particular characteristics that impact the energy consumption of pumps. First, radially split, multi-stage vertical in-line casing diffuser (RSV) and vertical turbine submersible (VTS) pumps for which the bare pump varies only in the number of stages would be required to be treated as the same basic model. Second, pumps for which the bare pump varies only in impeller diameter, or impeller trim, may be considered to be the same basic model or may optionally be rated as unique basic models. These exceptions are discussed in the following sections.
Variation in Number of Stages for Multi-Stage Pumps
The first modification to the basic model definition applies to variation in the number of stages for multi-stage pumps. DOE proposes that variation in the number of stages, while it may affect efficiency and will affect power, should not constitute a characteristic that would differentiate pump basic models. Specifically, any improvements in the hydraulic design of a single stage (or bowl) would be reflected in the measured performance of the pump with any number of stages. In addition, requiring testing for each stage version of a multi-stage pump would add significant testing burden. For these reasons, the CIP Working Group recommended each multi-stage pump be tested with a specified number of stages, as discussed in section III.C.2.c. DOE notes that any representations made with respect to PEI and pump energy rating (PER) for individual models with alternate number of stages within a single basic model: (1) Must be on the same as the basic model with the specified number of stages required for testing under the test procedure and (2) must be rated using method A.1, “bare pump with default motor efficiency and default motor part load loss curve” (explained further in section III.E).
Basic Model Grouping for Pumps With Different Impeller Trims
The second modification DOE proposes to the typical basic model definition is that a trimmed impeller, though it may impact efficiency, would not be a basis for requiring units to be rated as unique basic models. This proposal is consistent with the Working Group recommendation that the rating of a given pump basic model should be based on testing at full impeller diameter only and that DOE not require testing at reduced impeller diameters. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #7 at p. 3) DOE understands that a given pump may be distributed to customers with a variety of impeller trims to meet a certain hydraulic load for a certain application, and impeller trim has a direct impact on a pump's performance characteristics. However, DOE, in general, agrees with the Working Group's proposal. Rather than requiring a manufacturer to certify to DOE a pump with any given impeller trim that may be requested by a customer, DOE is proposing to limit the number of specific pump models to certify, which would reduce the overall manufacturer burden from testing while helping ensure that a reasonably accurate measurement of a given pump's efficiency is obtained. Rating at full impeller would typically reflect the most consumptive rating for that pump, due to the higher hydraulic power provided by the full impeller, as compared to a trimmed impeller in the same bare pump bowl. Therefore, any pump model with a bare pump that is otherwise identical (
i.e.,
same casing, same bearings and seals, etc.) but with a trimmed impeller will, except in very limited cases, almost always consume less energy than the same pump with full impeller. Consistent with the CIP Working Group Recommendations, DOE proposes to base the certified rating for a given pump basic model on that model's full impeller diameter—all PEI and PER representations for the members of this basic model would be based upon the full impeller model.
Relevant to this requirement, DOE proposes to define the term “full impeller” as it pertains to the rating of pump models in accordance with the proposed test procedure. The European Union (EU) defines “full impeller” as “the impeller with the maximum diameter for which performance characteristics are given for a pump size in the catalogues of a water pump manufacturer.”
14
DOE proposes to largely harmonize with this definition, but is proposing additional language to establish requirements for pumps for which performance data are not published in manufacturer catalogs, such as custom pumps. Specifically,
DOE proposes to define full impeller as the maximum diameter impeller with which the pump is distributed in commerce in the United States or the maximum impeller diameter represented in the manufacturer's literature, whichever is larger. DOE understands that in most cases, these would be the same. However, for pumps that may only be sold with a trimmed impeller due to a custom application, DOE is proposing to define the full impeller as the maximum diameter impeller with which the pump is distributed in commerce. DOE notes that the certified rating should represent the configuration based on the maximum diameter impeller offered by the manufacturer, regardless of the actual impeller size used with a given pump.
14
Council of the European Union. 2012. Commission Regulation (EU) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps.
Official Journal of the European Union.
L 165, 26 June 2012, pp. 28-36.
Under DOE's proposed definition for “full impeller,” manufacturers would also be able to represent a model with a trimmed impeller as less consumptive than at full impeller. To do so, they must treat that trimmed impeller model as a different basic model and test a representative number of models at the maximum diameter distributed in commerce of that trimmed basic model listing. In such a case, the impeller trim with which the pump is rated becomes the “full impeller diameter,” which is the “maximum diameter impeller used with a given pump basic model distributed in commerce or the maximum diameter impeller referenced in the manufacturer's literature for that pump basic model, whichever is larger.” In these cases, manufacturers may elect to: (1) Group individual pump units with bare pumps that vary only impeller diameter into a single basic model or (2) establish separate basic models (with unique ratings) for any number of unique impeller trims, provided that the PEI rating associated with any individual model is based on the maximum diameter impeller for that basic model and that basic model is compliant with any energy conservation standards established as part of the parallel pumps ECS rulemaking. (Docket No. EERE-2011-BT-STD-0031)
DOE notes that, while manufacturers may group pump models with various impeller trims under one basic model with the same certified PEI rating based on the full impeller diameter, all representations of PEI and PER for any individual model must be: (1) Based on testing of the model with the full diameter impeller in the basic model and (2) rated using method A.1, “bare pump with default motor efficiency and default motor part load loss curve” (explained further in section III.E).
d. Basic Models for Pumps Sold With Motors or Motors and Speed Controls
DOE notes that, for pumps sold with motors and pumps sold with motors and continuous or non-continuous controls, pump manufacturers may pair a given pump with several different motors with different performance characteristics. Under the proposed definition, each unique pump and motor pairing would represent a unique basic model. However, consistent with DOE's practice with other products and equipment, pump manufacturers may elect to group similar individual pump models within the same equipment class into the same basic model to reduce testing burden, provided all representations regarding the energy use of pumps within that basic model are identical and based on the most consumptive unit.
See
76 FR 12422, 12423 (March 7, 2011)).
15
15
These provisions allow manufacturers to group individual models with essentially identical, but not exactly the same, energy performance characteristics into a basic model to reduce testing burden. Under DOE's certification requirements, all the individual models within a basic model identified in a certification report as being the same basic model must have the same certified efficiency rating and use the same test data underlying the certified rating. The CCE final rule also establishes that the efficiency rating of a basic model must be based on the least efficient or most energy consuming individual model
(i.e.,
put another way, all individual models within a basic model must be at least as energy efficient as the certified rating). 76 FR at 12428-29 (March 7, 2011).
For example, pumps that share the same bare pump but have different motors could be grouped into the same basic model based on the least efficient pump and motor combination as long as the manufacturer did not want to make representations of the more-efficient pump and motor combination. However, for pumps sold with trimmed impellers, DOE recognizes that a given pump with a trimmed impeller may be sold with a different motor than the same pump with a full impeller. As variation in impeller trim of the bare pump does not constitute a characteristic that would differentiate basic models, variation in motor sizing as a result of different impeller trims would also not serve as a basis for differentiating basic models.
Since the proposed pump basic model definition and certified rating are both based on the pump as tested with a full impeller and a specific number of stages, to the extent that the paired motor varies between a given pump unit and the same bare pump at full impeller diameter with the specified number of stages for testing, this difference would not constitute a characteristic that would define separate basic models.
DOE requests comment on the proposed definition for “basic model” as applied to pumps. Specifically, DOE is interested in comments on DOE's proposal to allow manufacturers the option of rating pumps with trimmed impellers as a single basic model or separate basic models, provided the rating for each pump model is based on the maximum impeller diameter available within that basic model.
DOE requests comment on the proposed definition for “full impeller.”
DOE requests comment on the proposal to require that all pump models be rated in a full impeller configuration only.
DOE requests comment on any other characteristics of pumps that are unique from other commercial and industrial equipment and may require modifications to the definition of “basic model,” as proposed.
2. Equipment Classes
Table III.2 presents a list of the specific pump categories that DOE considered in the context of its Framework Document. The treatment of these rotodynamic pumps was extensively discussed and debated among members of the CIP Working Group. Those pump categories that the Working Group recommended for inclusion as part of DOE's standards-setting efforts are marked accordingly. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #4 at p. 2)
Table III.2—Rotodynamic Clean Water Pump Equipment Overview and Recommended Scope of Pumps Test Procedure and Energy Conservation Standards
Pump category
Sub-category
Stages
DOE terminology
ANSI/HI Term
In CIP working
group scope
End Suction
Close-coupled
Single
End Suction Close-coupled (ESCC)
OH7
Yes.
Own Bearings/Frame Mounted
Single
End Suction Frame Mounted (ESFM)
OH0, OH1
Yes.
Vertical In-Line
Single
In-Line (IL)
OH3, OH4, OH5
Yes.
Axial Split
Single
Double Suction (DS)
BB1, OH4 (double suction)
No
Multi
Axially Split Multi-Stage (AS)
BB1 (2-stage), BB3
No.
Radial Split
Multi
Radially Split Multi-Stage Vertical In-Line Casing Diffuser (RSV)
VS8
Yes.*
Multi
Radially Split Multi-Stage Horizontal (RSH)
BB2 (2-stage), BB4
No.
Vertical Turbine
Non-Submersible
Any
Vertical Turbine (VT)
VS1, VS2
No.
Submersible
Any
Vertical Turbine Submersible (VTS)
VS0
Yes.
Axial/Propeller and Mixed Flow
Any
Axial/Propeller and Mixed (AM)
OH00, VS3
No.
* Multistage radial split vertical immersible pumps are excluded from the proposed scope.
Discussions regarding the inclusion and exclusion of certain categories of pumps can be found in the transcripts from the first several meetings of the CIP Working Group. (Docket No. EERE-2013-BT-NOC-0039, Nos. 8, 9, 14, 15, 46, 47, and 62) As recommended by the Working Group, DOE is applying a scope (for both the test procedure and in evaluating potential standards) that would include the following pump equipment classes: end suction close-coupled (ESCC), end suction frame mounted (ESFM), in-line (IL), radially split multi-stage vertical IL casing diffuser (RSV), and vertical turbine submersible (VTS) pumps. DOE notes that, while intended to be consistent with this test procedure proposal, the scope of any energy conservation standards proposed for pumps will be discussed as part of a separate rulemaking.
DOE requests comment on the proposed applicability of the test procedure to the five pump equipment classes noted above, namely ESCC, ESFM, IL, RSV, and VTS pumps.
a. Definitions of Pump Equipment Classes
To help manufacturers determine whether a given pump falls into one of the equipment classes that would be addressed by the scope of this proposal and the parallel energy conservation standards under consideration, DOE is proposing to define each pump equipment class that DOE would regulate. In developing these definitions, DOE considered the comments received in response to the Framework Document along with subsequent input provided during the CIP Working Group meetings. For example, HI preferred that DOE use the American National Standards Institute (ANSI) HI definitions for equivalent pump categories and nomenclature instead of the definitions tentatively proposed by DOE. (HI, No. 25 at p. 28)
16
Grundfos preferred that DOE use EU and HI definitions and resolve any conflicts through the existing Joint International Pump Industry Standardization Committee. Grundfos regarded the DOE definitions as ambiguous. (Grundfos, No. 24 at p. 10)
16
A notation in this form provides a reference for information that is in the docket of DOE's rulemaking to develop energy conservation standards for commercial and industrial pumps (Docket No. EERE-2011-BT-STD-0031, which is maintained at
www.regulations.gov
). This particular notation refers to a comment: (1) Submitted by HI; (2) appearing in document number 25 of the docket; and (3) appearing on page 28 of that document.
A joint comment submitted by the Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), American Council for an Energy-Efficient Economy (ACEEE), Earthjustice, and the National Resources Defense Council (NRDC) (collectively referred to as “the Advocates”)
17
criticized the HI definitions as narrow, increasing the risk that a manufacturer could make small changes to avoid DOE's regulations. To avoid this problem, the Advocates preferred DOE's broad definitions and offered some recommended modifications to those definitions. (Advocates, No. 32 at p. 4) Earthjustice also suggested adopting the Advocates' suggestions for modifying the definitions and added that DOE could provide illustrative references to the relevant HI nomenclature for further clarification. (Earthjustice, No. 30 at p. 1) Northwest Energy Efficiency Alliance (NEEA) and Northwest Power and Conservation Council (NPCC) made a similar suggestion, suggesting that the definitions be coupled with an appendix that would map to the appropriate ANSI/HI nomenclature and definitions. (NEAA/NPCC, No. 31 at p. 3)
17
As noted in Table I.2, ASAP and NRDC were members of the CIP Working Group, while ASE, ACEE, and Earthjustice were not.
While the CIP Working Group recommended establishing a test procedure and standards for specific classes of pumps, in the interest of time, the specific definitions of these pump equipment classes were not negotiated by the CIP Working Group. After considering the stakeholder comments on the Framework Document, DOE is proposing specific definitions for particular categories of pumps and specific pump equipment classes. DOE is proposing general definitions for some specific characteristics of pumps for which DOE is proposing that the test procedure be applicable; namely rotodynamic pump, single-axis flow pump, and end suction pump.
DOE proposes that rotodynamic pump refer to a pump in which energy is continuously imparted to the pumped fluid by means of a rotating impeller, propeller, or rotor. DOE proposes such a definition to help define the specific pump equipment classes to which the proposed test procedure is applicable and differentiate those from positive displacement pumps (
i.e.,
non-
rotodynamic pumps) with otherwise similar attributes.
DOE also proposes to define 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 to clarify when specific pump equipment classes, discussed below, are proposed to exclude similar pumps in which the pumped liquid enters and exits the pump on different axes.
DOE proposes to define end suction pump as a specific variety of rotodynamic pump that is single-stage and in which the liquid enters the bare pump in a direction parallel to the impeller shaft and on the end opposite the bare pump's driver-end. Such a pump is not single axis flow because the liquid is discharged through a volute in a plane perpendicular to the shaft.
Based on these three definitions describing general pump characteristics, DOE proposes to define the following five pump equipment classes to which the proposed test procedure would be applicable:
(1)
End suction frame mounted (ESFM) pump
means an end suction pump wherein:
(a) The bare pump has its own impeller shaft and bearings and so does not rely on the motor shaft to serve as the impeller shaft;
(b) the pump requires attachment to a rigid foundation to function as designed and cannot function as designed when supported only by the supply and discharge piping to which it is connected; and
(c) the pump does not include a basket strainer.
Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature OH0 and OH1, as described in the 2008 version of ANSI/HI Standard 1.1-1.2, “Rotodynamic (Centrifugal) Pumps For Nomenclature And Definitions” (ANSI/HI 1.1-1.2-2014).
(2)
End suction close-coupled (ESCC) pump
means an end suction pump in which:
(a) The motor shaft also serves as the impeller shaft for the bare pump;
(b) the pump requires attachment to a rigid foundation to function as designed and cannot function as designed when supported only by the supply and discharge piping to which it is connected; and
(c) the pump does not include a basket strainer.
Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature OH7, as described in ANSI/HI 1.1-1.2-2014.
(3)
In-line (IL) pump
means a single-stage, single axis flow, rotodynamic pump in which:
(a) Liquid is discharged through a volute in a plane perpendicular to the impeller shaft; and
(b) the pump requires attachment to a rigid foundation to function as designed and cannot function as designed when supported only by the supply and discharge piping to which it is connected.
Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature OH3, OH4, or OH5, as described in ANSI/HI 1.1-1.2-2014.
(4)
Radially split, multi-stage, vertical, in-line, diffuser casing (RSV) pump
means a vertically suspended, multi-stage, single axis flow, rotodynamic pump in which:
(a) liquid is discharged in a plane perpendicular to the impeller shaft;
(b) each stage (or bowl) consists of an impeller and diffuser; and.
(c) no external part of such a pump is designed to be submerged in the pumped liquid.
Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature VS8, as described in the 2008 version of ANSI/HI Standard 2.1-2.2, “Rotodynamic (Vertical) Pumps For Nomenclature And Definitions” (ANSI/HI 2.1-2.2-2008).
(5)
Vertical turbine submersible (VTS) pump
means a single-stage or multi-stage rotodynamic pump that is designed to be operated with the motor and stage(s) (or bowl(s)) fully submerged in the pumped liquid, and in which:
(a) each stage of this pump consists of an impeller and diffuser and
(b) liquid enters and exits each stage of the bare pump in a direction parallel to the impeller shaft.
Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature VS0, as described in ANSI/HI 2.1-2.2-2008.
DOE notes that any references to HI nomenclature in ANSI/HI 1.1-1.2-2014 or ANSI/HI 2.1-2.2-2008 are incorporated into the definitions of the aforementioned pump equipment classes as examples only. As several interested parties expressed their desire to reference the HI nomenclature to help provide clarity to the industry, DOE is proposing to list the relevant HI pump nomenclature in the definition of each pump equipment class. However, in some cases, the HI nomenclature can be vague or inconsistent.
18
In cases where there is a conflict between the description provided in ANSI/HI 1.1-1.2-2014 or ANSI/HI 2.1-2.2-2008, as applicable, and the proposed regulatory text, the language in the regulatory text would prevail. Accordingly, a manufacturer would need to carefully review the applicable regulatory text in determining how its equipment would be affected because DOE would be using these provisions when applying the test procedure and setting the scope for any standards that DOE may develop.
18
For example, ANSI/HI 1.1-1.2-2014 does not identify specific definitions for the considered pumps. Rather, it provides classification trees (as in Figure 1.1.3a of that document) as well as construction drawings (
e.g.
Figures 1.1.5a-bb). The words describing a given pump classification are not always exactly consistent between the tree and the drawing captions. For example, OH0 is variously described as “overhung—flexibly coupled—horizontal—frame mounted” and “overhung impeller—flexibly coupled—single stage—frame mounted.”
DOE requests comment on the proposed definitions for end suction pump, end suction frame mounted pump, end suction close-coupled pump, in-line pump, radially split multi-stage vertical in-line casing diffuser pump, rotodynamic pump, single axis flow pump, and vertical turbine submersible pump.
DOE requests comment on whether the references to ANSI/HI nomenclature are necessary as part of the equipment definitions in the regulatory text, are likely to cause confusion due to inconsistencies, and whether discussing the ANSI/HI nomenclature in this preamble would provide sufficient reference material for manufacturers when determining the appropriate equipment class for their pump models.
With regard to the proposed definition for RSV pumps, DOE understands that, in such a pump, flow typically proceeds from the bare pump inlet through the stages in series, with each stage increasing the total head, and exits at the pump discharge. DOE requests comment on whether it needs to clarify the flow direction to distinguish RSV pumps from other similar pumps when determining test procedure and standards applicability.
One issue related to the above that DOE is currently considering is whether its proposed RSV pump definition requires further clarification to ensure that immersible pumps do not fall within the definition. As proposed, this definition would exclude immersible pumps that would otherwise meet the remaining characteristics detailed in the definition (
i.e.,
“No external part of such a pump is designed to be submerged in the pumped liquid).” While DOE believes that this language should be sufficient to exclude any immersible pumps from being treated as an RSV pump for purposes of DOE's regulations,
DOE requests comment on whether any additional language is necessary to make this exclusion clearer.
b. Circulators and Pool Pumps
Circulators, which are a specific kind of rotodynamic pump, are small, low-head pumps similar to the in-line or end suction close-coupled configuration pumps that are generally used to circulate water in hydronic space conditioning or potable water systems in buildings.
The CIP Working Group recommended that circulator pumps be addressed as part of a separate rulemaking process that would involve informal negotiation between stakeholders followed by an ASRAC-approved negotiation. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #5A at p. 2) DOE has not yet received any proposals or requests for negotiation from the stakeholders.
To explicitly exclude circulators from this rulemaking and the parallel energy conservation standards rulemaking, DOE proposes to define the term “circulator” as referring to either:
• An end suction pump with a pump housing that requires only the support of the supply and discharge piping to which it is connected to function as designed, or
• A single-stage, single axis flow, rotodynamic pump, with a pump housing that requires only the support of the supply and discharge piping to which it is connected to function as designed.
Under this definition, such a pump would not be able to function as designed without attachment to a rigid foundation. Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature CP1, CP2, or CP3, as described in ANSI/HI 1.1-1.2-2014.
Adopting this definition would help ensure that circulators can be clearly and unambiguously differentiated from other pumps that DOE may consider regulating and to which this proposed test procedure would apply. The proposed definition would rely on the unique and distinguishable design characteristics of circulators—namely, that circulators require only pipe-mounted support and do not need to be attached to a rigid foundation to function as designed. Conversely, ESCC, ESFM, and IL pumps, by definition, require attachment to a rigid foundation to function as designed. DOE believes that such a definition for a circulator would encompass all pumps commonly referred to as circulators by the industry, which the CIP Working Group recommended that DOE not regulate in this rulemaking. DOE proposes to also reference the ANSI/HI 1.1-1.2—2014 nomenclature for circulators, as included in the CIP Working Group Recommendations. (Docket No. EERE-2013-BT-NOC-0039, No. 92 at p. 2)
By defining circulators, ESCC, ESFM, and IL pumps as mutually exclusive from each other on the basis of design characteristics, it is unnecessary to include a size-based threshold in the proposed circulator definition, as had been suggested by stakeholders. (HI, No. 25 at p. 20; Docket No. EERE-2013-BT-NOC-0039, No. 14 at p. 338) DOE notes that it is uncommon for pumps larger than 3 hp to be supported only by their supply and discharge pipes. This is due to limitations on the structural weight loads that a piping system can support. The constraint imposed by the piping system, in effect, acts as an inherent upper size threshold for circulators.
The CIP Working Group also formally recommended that DOE initiate a separate rulemaking for dedicated-purpose pool pumps by December 2014. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #5A at p. 2) The CIP Working Group further sought to identify the unique characteristics of pool pumps that differentiate them from the other pump classes within the scope of this rulemaking to make clear that dedicated-purpose pool pumps are not required to be tested in accordance with the proposed procedure. During the March 26, 2014 CIP Working Group meeting, Xylem Inc. (Xylem) indicated that all dedicated-purpose pool pumps include an integrated basket strainer, unlike other end suction close-coupled pumps. (Docket No. EERE-2013-BT-NOC-0039, No. 62 at p. 195) To distinguish a “dedicated-purpose pool pump” from other pumps that DOE is currently considering regulating in this NOPR, DOE proposes to define this device as an end suction pump designed specifically to circulate water in a pool and that includes an integrated basket strainer.
DOE notes that this definition will be discussed in more detail in a separate rulemaking to consider potential energy conservation standards and test procedures for pool pumps.
DOE requests comment on its proposal to exclude circulators and pool pumps from the scope of this test procedure rulemaking. DOE also requests comment on the proposed definitions for circulators and dedicated-purpose pool pumps. Finally, DOE requests comment on the extent to which ESCC, ESFM, IL, and RSV pumps require attachment to a rigid foundation to function as designed. Specifically, DOE is interested to know if any pumps commonly referred to as ESCC, ESFM, IL, or RSV do not require attachment to a rigid foundation.
c. Axial/Mixed Flow and Positive Displacement Pumps
“Axial/mixed flow pump” is a term used by the pump industry to describe a rotodynamic pump that is used to move large volumes of liquid at high flow rates and low heads. These pumps are typically custom-designed and used in applications such as dewatering, flood control, and storm water management.
Positive displacement (PD) pumps are a style of pump that operates by first opening an increasing volume to suction; this volume is then filled, closed, moved to discharge, and displaced. PD pumps operate at near-constant flow over their range of operational pressures and can often produce higher pressure than a centrifugal pump, at a given flow rate. PD pumps also excel at maintaining flow and efficiency for liquids more viscous than water. When used in clean water applications, PD pumps are typically chosen for high pressure, constant flow applications such as high pressure power washing, oil field water injection, and low-flow metering processes.
The CIP Working Group recommended excluding both of these types of pumps from being subject to the prospective energy conservation standards DOE is considering. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #6 at p. 2) The primary reason for excluding these pumps at this time is their low market share in the considered horsepower range and low potential for energy savings. (Docket No. EERE-2013-BT-NOC-0039, No. 14 at pp. 114 and 372-373) In addition, the CIP Working Group acknowledged that PD pumps are more commonly used in non-clean water applications and provide a different utility than the categories of pumps addressed in this rulemaking. (Docket No. EERE-2013-BT-NOC-0039, No. 14 at p. 114) Therefore, DOE is considering excluding these pumps from the scope of this rulemaking and the parallel energy conservation standards rulemaking.
DOE believes that the pump equipment classes and scope parameters defined in sections III.A.2 and III.A.4, respectively, implicitly exclude positive displacement and axial flow pumps.
As mentioned previously, axial/mixed flow pumps are designed to accommodate high flow-to-head-ratio applications and are therefore implicitly
excluded from the scope of pumps being considered in this NOPR based on the head, flow, and pump brake horsepower parameters proposed in section III.A.4. Additionally, the proposed definitions of ESCC, ESFM, and IL pumps would exclude axial/mixed flow pumps through the reference of a discharge volute, which is typically not present on equipment referred to as axial/mixed flow pumps. The proposed definition of RSV pumps would also exclude equipment referred to as axial/mixed flow pumps through implication by specifying that the liquid inlet is in a plane perpendicular to the impeller shaft, as compared to axial/mixed flow pumps where liquid intake is parallel to the impeller shaft. Finally, the proposed definition of VTS pumps would exclude equipment referred to as axial/mixed flow pumps because axial/mixed flow pumps are not designed to be completely submerged in the pumped liquid. Consequently, given the required characteristics of each of the proposed equipment class definitions, DOE believes additional clarification is unnecessary to effectively exclude axial/mixed flow pumps. If, however, additional facts suggest that further clarification is needed, DOE may consider the merits of adding clarifying language to the appropriate regulatory text.
As discussed previously, PD pumps are typically used to handle high viscosity liquids or handle extremely high head applications. PD pumps are not rotodynamic pumps and so do not meet the definition of any of the pump equipment classes discussed in section III.A.2.a that DOE is considering addressing in this rulemaking.
DOE requests comment on its initial determination that axial/mixed flow and PD pumps are implicitly excluded from this rulemaking based on the proposed definitions and scope parameters. In cases where commenters suggest a more explicit exclusion be used, DOE requests comment on the appropriate changes to the proposed definitions or criteria that would be needed to appropriately differentiate axial/mixed flow and/or PD pumps from the specific rotodynamic pump equipment classes proposed for coverage in this NOPR.
3. Scope Exclusions Based on Application
DOE initially considered limiting its rulemaking scope to address only rotodynamic pumps intended for use in pumping clean water, with the potential of further limiting the scope to exclude specific categories of pumps based on their design or application. (Docket No. EERE-2011-BT-STD-0031, No. 13 at pp. 2-6) DOE also discussed the possibility of defining “clean water pump” using physical characteristics rather than just defining “clean water” as in the EU Commission Regulation No 547/2012 EU 547.
19
After extensive discussions on this subject, the CIP Working Group recommended limiting the scope of the rulemaking to pumps designed for use in pumping clean water and excluding certain pumps, some of which are designed for use in pumping clean water and some of which are not, from being regulated for the purposes of this proposal and the standards currently under consideration. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #8 at pp. 3-4) However, in the interest of time, the CIP Working Group did not recommend specific definitions to help implement any of these recommendations.
19
Council of the European Union. 2012. Commission Regulation (EU) No 547/2012 of 25 June 2012.
In an effort to meet the intent and recommendations of the CIP Working Group, DOE is proposing to define “clean water pump.” DOE is also proposing to define several kinds of clean water pumps that are designed for specific applications and that the Working Group had indicated should be excluded from the scope of this proposal and DOE's standards rulemaking efforts that are under development. These definitions would be laid out in a new 10 CFR 431.462.
a. Definition of Clean Water Pump
First, DOE proposes to define “clean water pump” as a pump that is designed for use in pumping water with a maximum non-absorbent free solid content of 0.25 kilograms per cubic meter, and with a maximum dissolved solid content of 50 kilograms per cubic meter, 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 −10 °C.
DOE notes that, when determining whether a given pump would satisfy the definition of clean water pump, DOE would consider marketing materials, labels and certifications, equipment design, and actual application of such equipment.
To clarify the scope of “clean water pumps,” DOE notes that several common pumps would not meet the definition of clean water pumps, as they are not designed for pumping clean water. The CIP Working Group specifically identified the following non-clean water pumps:
(1) Wastewater, sump, slurry, or solids handling pump (
i.e.,
a pump designed to move liquid with maximum dissolved solid content that exceeds the limits in the definition of clean water).
(2) Pump designed for pumping hydrocarbon product fluids that meets the requirements of API's Standard 610-2010, “Centrifugal Pumps for Petroleum, Petrochemical and Natural Gas Industries” or ISO 13709:2009.
20
20
ISO 13709:2009 is an identical standard to API 610 and is included under the same cover.
(3) Chemical process pump that meets the requirements of ANSI/ASME Standard B73.1-2012, “Specification for Horizontal End Suction Centrifugal Pumps for Chemical Process;” ANSI/ASME B73.2-2002, “Specifications for Vertical In-Line Centrifugal Pumps for Chemical Process;” or International Organization for Standardization (ISO) 2858:1975, “End-suction centrifugal pumps (rating 16 bar)—Designation, nominal duty point and dimensions,” and ISO 5199:2002, “Technical specifications for centrifugal pumps—Class II.”
(4) Sanitary pump that meets the requirements of 3-A Sanitary Standards, Inc. Standard 3A 02-11, “Centrifugal and Positive Rotary Pumps for Milk and Milk Products.”
DOE also proposes to establish a specific definition for “clear water” for testing purposes that would describe the fluid to be used when testing pumps in accordance with the DOE test procedure. Specifically, DOE proposes to incorporate by reference the definition for “clear water” established in HI 40.6-2014. This definition would apply solely for the purposes of the test procedure and is distinct from the definition of “clean water,” as defined in this section. The definition of “clear water” as it applies to the test fluid to be used in the testing of pumps under the proposed DOE test procedure is narrower than the proposed definition of “clean water,” which would be used to establish the scope of the DOE test procedure and related energy conservation standards.
DOE also requests comment on the proposed definition for “clean water pump.”
DOE requests comment on its proposal to incorporate by reference the definition for “clear water” in HI 40.6-2014 to describe the testing fluid to be used when testing pumps in accordance with the DOE test procedure.
b. Exclusion of Specific Kinds of Clean Water Pumps
Also in accordance with the Working Group recommendations, DOE proposes
to define several kinds of pumps that are clean water pumps, as defined, but would not be subject to the proposed test procedure. Specifically, DOE proposes that the test procedure would not apply to:
(1) Fire pumps;
(2) self-priming pumps;
(3) prime-assist pumps;
(4) sealless pumps;
(5) pumps designed to be used in a nuclear facility subject to 10 CFR part 50—Domestic Licensing of Production and Utilization Facilities; and
(6) a pump meeting the design and construction requirements set forth in Military Specification MIL-P-17639F, “Pumps, Centrifugal, Miscellaneous Service, Naval Shipboard Use” (as amended).
Accordingly, DOE proposes the following definitions for fire pump, self-priming pump, prime-assist pump, and sealless pump:
(1)
Fire pump
means a pump that is compliant with National Fire Protection Association (NFPA) Standard 20-2013, “Standard for the Installation of Stationary Pumps for Fire Protection,” and either (1) Underwriters Laboratory (UL) listed under UL Standard 448-2007, “Centrifugal Stationary Pumps for Fire-Protection Service,” or (2) Factory Mutual (FM) approved under the October 2008 edition of FM Class Number 1319, “Approval Standard for Centrifugal Fire Pumps (Horizontal, End Suction Type).”
(2)
Self-priming pump
means a pump designed to lift liquid that originates below the center line of the pump impeller. Such a pump requires initial manual priming from a dry start condition, but requires no subsequent manual re-priming.
(3)
Prime-assist pump
means a pump designed to lift liquid that originates below the center line of the pump impeller. Such a pump requires no manual intervention to prime or re-prime from a dry-start condition. Such a pump includes a vacuum pump or air compressor to remove air from the suction line to automatically perform the prime or re-prime function.
(4)
Sealless pump
means either:
(a) A pump that transmits torque from the motor to the bare pump using a magnetic coupling, or
(b) A pump in which the motor shaft also serves as the impeller shaft for the bare pump, and the motor rotor is immersed in the pumped fluid.
DOE notes that the proposal to exclude fire pumps is consistent with comments submitted in response to the Framework Document, including from from stakeholders that were not members of the CIP Working Group.
21
(NFPA, No. 27 at pp. 1-2; Colombia Engineering, No. 29 at p. 1) However, while Earthjustice suggested that DOE could require that fire pumps be marked “For use as a fire pump only,” (Earthjustice, No.30 at p.2) DOE declines to propose a mandatory label for fire pumps because it seems superfluous in that there is an increased cost of such pumps that is likely to inherently limit their sale to that specific application.
21
DOE did not receive comments on the Framework Document regarding other types of pumps for exclusion from stakeholders not represented on the CIP Working Group.
DOE reviewed the requirements for fire pumps, pumps designed to be used in a nuclear facility under 10 CFR 50, and pumps designed per military specification MIL-P-17639F (Pumps, Centrifugal, Miscellaneous Service, Naval Shipboard Use). DOE believes that in all cases, the increased burden in design and test requirements provides a legitimate reason to exclude these from the scope of the proposed test procedure and standards.
According to Patterson Pumps, fire pumps are manufactured according to NFPA Standard 20, and certified according to either UL or FM standards. (Docket No. EERE-2013-BT-NOC-0039, No. 15 at pp. 191-192) The CIP Working Group agreed to exclude pumps compliant with NFPA 20 as long as they are certified as “fire pumps” to the relevant UL or FM standard, noting that UL and FM are the only two certification bodies for fire pumps. (Docket No. EERE-2013-BT-NOC-0039, No. 15 at p. 193-194). The CIP Working Group also represented that it was unlikely manufacturers would attempt to sell pumps intended for other applications as fire pumps in an effort to circumvent a proposed DOE standard for pumps because of the high expense in testing to complete the certification process for UL or FM. Likewise, consumers would find the expense of buying a fire pump for a non-fire pump application would be higher than that of buying a pump that complies with an eventual DOE standard. (Docket No. EERE-2013-BT-NOC-0039, No. 14 at p. 125)
Nuclear facility pumps must have certified design specifications and must conform to many specific design and testing criteria. These include, but are not limited to, classification as ASME Code Class 1 of the ASME Boiler and Pressure Vessel Code, Section III, “Rule for Construction of Nuclear Facility Components,” for reactor coolant pumps. DOE understands that the design and construction of pumps in accordance with ASME Code Class 1 represent significant additional expense and significantly increases the cost of such pumps compared to the clean water pumps considered in this test procedure. Similar to fire pumps, DOE believes there is sufficient justification to exclude such nuclear facility pumps from the scope of this rulemaking without a risk of clean water pumps being marketed or sold as nuclear facility pumps for actual use in other applications.
Pumps designed to military specifications (commonly referred to as “MIL-SPEC”), such as MIL-P-17639F, must meet very specific physical and or operational characteristics and have complex and rigid reporting requirements.
22
Specifically, MIL-P-17639F requires significant amounts of design and test data be submitted to various military design review agencies to ensure that the pump can be operated and maintained in harsh naval environments. When considering if a pump is designed and constructed to the requirements set forth in MIL-P-17639F, DOE may request that a manufacturer provide DOE with copies of the original design and test data that were submitted to appropriate design review agencies, as required by MIL-P-17639F. Similar to fire and nuclear facility pumps, DOE believes there is sufficient justification to exclude MIL-SPEC pumps from the scope of this rulemaking without a risk of clean water pumps being marketed or sold as MIL-SPEC for actual use in other applications.
22
United States General Accounting Office, Report to Congressional Committees, Acquisition Reform: DOD Begins Program To Reform Specifications and Standards, GAO/NSIAD-95-14. October 11, 1994. Washington, DC. pp. 2-3.
http://www.gao.gov/archive/1995/ns95014.pdf
DOE requests comment on the proposed definition for “fire pump,” “self-priming pump,” “prime-assisted pump,” and “sealless pump.”
Regarding the proposed definition of a self-priming pump, DOE notes that such pumps typically include a liquid reservoir above or in front of the impeller to allow recirculating water within the pump during the priming cycle. DOE requests comment on any other specific design features that enable the pump to operate without manual re-priming, and whether such specificity is needed in the definition for clarity.
DOE requests comment on the proposed specifications and criteria to determine if a pump is designed to meet a specific Military Specification and if
any Military Specifications other than MIL-P-17639F should be referenced.
DOE requests comment on excluding the following pumps from the test procedure: Fire pumps, self-priming pumps, prime-assist pumps, sealless 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 Specification MIL-P-17639F, “Pumps, Centrifugal, Miscellaneous Service, Naval Shipboard Use” (as amended).
4. Parameters for Establishing the Scope of Pumps in This Rulemaking
In addition to limiting the types of pumps that DOE would regulate at this time through pump definitions and their applications, DOE proposes to further limit its scope consistent with the Working Group's recommendation by applying the following performance and design characteristics:
(1) 1-200 hp (shaft power at the best efficiency point, BEP, at full impeller diameter for the number of stages required for testing to the standard);
23
23
The CIP Working Group also recommended that testing be required with 3 stages for RSV pumps and 9 stages for VTS pumps, unless a model is not available with that specific number of stages, in which case the pump would be tested with the next closest number of stages. This recommendation is discussed in more detail in section III.C.2.a.
(2) 25 gpm and greater (at BEP at full impeller diameter);
(3) 459 feet of head maximum (at BEP at full impeller diameter);
(4) design temperature range from −10 to 120 °C;
(5) pumps designed for nominal 3,600 or 1,800 revolutions per minute (rpm) driver speeds; and
(6) 6-inch or smaller bowl diameter for VTS pumps (HI VS0).
(Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #7 at p. 3)
Similarly, DOE proposes to apply the pump test procedure scope to the scope of pumps discussed in sections III.A.1 and III.A.3 possessing the characteristics presented by the CIP Working Group.
DOE notes that with respect to the limiting criterion proposed for VTS pumps (
i.e.,
bowl diameter) DOE is also proposing to define this term to remove ambiguity and to ensure that all entities are calculating bowl diameter the same way. HI 40.6-2014 defines bowl diameter as follows: “Bowl diameter means the measure of a straight line passing through the center of a circular shape that intersects the circular shape at both of its ends.” While DOE largely agrees with the HI definition, additional specificity is required with respect to that definition's use of the phrase “circular shape.” As such, DOE proposes to define “bowl diameter” as it applies to VTS pumps as follows:
Bowl diameter
means the maximum dimension of an imaginary straight line passing through and in the plane of the circular shape of the intermediate bowl or chamber of the bare pump that is perpendicular to the pump shaft and that intersects the circular shape of the intermediate bowl or chamber of the bare pump at both of its ends, where the intermediate bowl or chamber is as defined in ANSI/HI 2.1-2.2-2008.
If adopted, only those VTS pumps with bowl diameters of 6 inches or less would be required to be tested under the proposed procedure.
DOE requests comment on the listed design characteristics (
i.e.,
power, flow, head, design temperature, design speed, and bowl diameter) as limitations on the scope of pumps to which the proposed test procedure would apply.
DOE requests comment on the proposed definition for “bowl diameter” as it would apply to VTS pumps.
5. Non-Electric Drivers
DOE recognizes that some pumps, particularly in the agricultural sector, may be sold and operated with non-electric drivers, such as engines, steam turbines, or generators. During the CIP Working Group's negotiations, testing and coverage of non-electric drivers were discussed. To ensure simplicity and comparability when testing and certifying pumps with non-electric drivers, the CIP Working Group recommended that pumps sold with non-electric drivers be rated as a bare pump, excluding the energy performance of the non-electric driver. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #3 at p. 2) By requiring testing and certification in this manner, any hydraulic improvements made to the bare pump to comply with any applicable energy conservation standards that may apply to the bare pump would also result in energy savings if the pump is used with a non-electric driver. DOE notes that the proposed test procedure is applicable only to drivers that are electric motors. Therefore, when rating a pump with any driver other than an electric motor, or other bare pump, DOE would provide default rating calculations in the test procedure to represent the performance of the given bare pump with a default motor that is minimally compliant with DOE's energy conservation standards for electric motors. See 10 CFR 431.25. This procedure is described in more detail in section III.E.1.a. (In context, as noted earlier, the terms “electric motor” and “motor” are used interchangeably.)
The Working Group's approach, as described above, is likely to reduce the test burden and complexity of the regulation. DOE notes that, in order to accurately capture the energy performance of non-electric drivers in the DOE pump test procedure, separate test procedures would be necessary for each type of driver (
e.g.,
turbines, generators), which are not currently available in HI 40.6-2014 or other relevant pump test standards and, thus, would add significant complexity and burden to the pump test procedure. DOE believes that there is insufficient technical merit or potential for additional energy savings to justify the additional burden associated with rating and certifying pumps sold with non-electric drivers inclusive of those drivers.
DOE requests comment on its proposal to test pumps sold with non-electric drivers as bare pumps.
6. Pumps Sold With Single-Phase Induction Motors
DOE recognizes that some pumps within the proposed scope of this rulemaking may be distributed in commerce with single-phase motors. However, DOE understands that the majority of pumps in the proposed scope of this test procedure rulemaking are sold with polyphase induction motors. One reason for the prevalence of polyphase motors is that the pumps for which the proposed test procedure would apply are typically sold into commercial and industrial applications where polyphase (three-phase) power is known to be commonplace. Additionally, single-phase induction motors are not widely available in motors with horsepower (hp) ratings greater than approximately 5 hp, while the proposed test procedure would apply to pumps from 1-200 hp, as discussed in section III.A.4. This circumstance further restricts the prevalence of single-phase motors in pumps for which the proposed test procedure would apply. According to the CIP Working Group, almost all pumps except for smaller pumps use three-phase motors, with the transition from single-phase to three-phase motors occurring at around
1/2
to
3/4
hp. (Docket No. EERE-2013-BT-NOC-0039, No. 105 at p. 224-225)
In addition, DOE understands that most pumps within the scope of this proposed rulemaking that are distributed in commerce with single-phase induction motors are also distributed in commerce with polyphase induction motors of similar size to
accommodate variation in power requirements among customers.
DOE understands that single-phase induction motors are, in general, less efficient than polyphase induction motors and, thus, would result in different energy consumption characteristics when paired with the same bare pump. Therefore, to establish the desired calculation-based methods for pumps paired with single-phase and polyphase motors, DOE would need to develop specific default motor efficiency assumptions and motor loss curves for both single-phase and polyphase motors. However, DOE believes that developing a separate rating methodology (including separate default motor efficiency assumptions) for pumps sold with single-phase induction motors is not justified at this time due to the small percentage of pumps sold with only single-phase induction motors. The CIP Working Group agreed that, based on the scope established for pumps being from 1-200 hp, it is more meaningful to focus the rating methodology on three-phase motors. (Docket No. EERE-2013-BT-NOC-0039, No. 105 at p. 226)
For these reasons, DOE has developed the proposed test methods to be based on polyphase induction motors in that the default nominal full load motor efficiency discussed in section III.D.1 would specify a minimum efficiency value for a National Electrical Manufacturers Association (NEMA) Design A, NEMA Design B, or IEC Design N electric motor, which are a specific kind of polyphase induction motor. However, DOE believes that such default nominal full load motor efficiency values are not applicable to single-phase induction motors. Therefore, in order not to penalize pumps sold with single-phase induction motors, DOE proposes that such pumps be tested and rated in the bare pump configuration, using the calculation-based method.
DOE notes that, if a pump distributed in commerce with a single-phase induction motor is also distributed in commerce in a bare pump configuration, this proposal would not increase the testing or rating burden on manufacturers. DOE also wishes to clarify that, to the extent that such a pump is also sold with an electric motor other than a single-phase induction motor, the pump must also be rated based on the PEI
CL
or PEI
VL
as determined for the pump when paired with that other motor.
DOE requests comment on its proposal that any pump distributed in commerce with a single-phase induction motor be tested and rated in the bare pump configuration, using the calculation method.
DOE requests comment from interested parties on any other categories of electric motors, except submersible motors, that: (1) Are used with pumps considered in this rulemaking and (2) typically have efficiencies lower than the default nominal full load efficiency for NEMA Design A, NEMA Design B, or IEC Design N motors.
B. Rating Metric
One of the first and most important issues DOE must consider in designing a test procedure is selection of the regulatory metric. The most common metric used in the pump industry today to describe the performance of bare pumps (
i.e.,
pumps sold alone, not inclusive of motors and controls) is pump efficiency, which is the ratio of hydraulic power (the product of flow, density, gravity, and head) to pump shaft input power, as shown in equation (1):
EP01AP15.000
Where:
η
pump
= bare pump efficiency,
P
Hydro
= pump hydraulic output power, and
P
i
= shaft input power to the bare pump at rating point (i).
When a pump is tested for performance inclusive of a motor and/or controls, pump efficiency is not as useful a metric, as it does not capture the performance of the other components that are integral to the performance and utility of the pump when installed in the field. In the Framework Document, DOE discussed bare pump efficiency as well as overall pump efficiency (
i.e.,
the efficiency of a pump coupled with a driver, as defined in HI 40.6-2014) and “wire-to-water,”
24
power-based metrics. DOE also discussed the possible application of different metrics to pumps depending on how they are sold: (1) Alone as bare pumps, (2) with motors, or (3) with motors and continuous or non-continuous controls.
24
The term “wire-to-water” refers to the physically-tested, combined performance of the bare pump, motor, and any continuous or non-continuous controls. This is consistent with the testing-based methods discussed in section III.E.2.
1. Working Group and Other Stakeholder Comments
The different rating approaches suggested in the Framework Document were also discussed in the negotiations of the CIP Working Group. The Working Group recommended that DOE use a wire-to-water, power-based metric for all pumps, regardless of how they are sold. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #11 at p. 5) The CIP Working Group recommended a similar metric for all pump configurations (
i.e.,
bare pumps, pumps sold with a motor, and pumps sold with a motor and continuous or non-continuous controls) to allow for better comparability and more consistent application of the rating metric for all pumps within the recommended scope. This way, the benefit of speed control, as compared to a similar pump without speed control, can be reflected in the measurement of energy use or energy efficiency.
In developing the metric proposed in this NOPR, DOE reviewed the CIP Working Group recommendations as well as the relevant comments made in response to the Framework Document. The Air-Conditioning, Heating, and Refrigeration Institute (AHRI), which was not a member of the Working Group, suggested that if DOE defines pumps to be inclusive of motors and/or controls, that DOE develop a combined pump/motor/control efficiency metric using a weighted average of measurements at specified rating points (as preferable to minimum levels at multiple points because it allows more design flexibility). (AHRI, No. 28 at p. 2) AHRI noted that a regulatory regime that includes controls must include appropriate part load levels and operating points, reflective of part load conditions typically in use. It cited AHRI 1210-2011, “2011 Standard for Performance Rating of Variable Frequency Drives,” as an example of a relevant test procedure that requires that a variable frequency drive
25
(VFD) and
motor be tested at four different speeds: 40, 50, 75, and 100 percent of full speed. AHRI estimated that VFDs in pump/motor/VFD packages range from 50 to 100 percent of maximum speed, and average operation is approximately 75 percent of full speed. AHRI also noted that the methodology used to develop the Integrated Part Load Value (IPLV) metric in appendix D of AHRI standard 550/590 may be a useful reference. (AHRI, No. 28 at p. 2)
25
Variable Frequency Drive (or VFD) is defined in AHRI 1210-2011 as “A power electronic device that regulates the speed of an alternating current (AC) motor by adjusting the frequency and the
voltage of the electrical power supplied to the motor.” This definition applies to asynchronous induction motors. The term “dynamic continuous control,” as defined in section III.E.1.c, is synonymous with the term “variable speed drive (VSD)” and refers to a power electronic device that controls the output of a motor via continuous modulation rotating speed. This includes variable frequency drives, which control speed through changes in input frequency to the motor and are applicable only to AC motors, as well as direct-current machines such as electronically commutated motors. (HI, Europump, and DOE; “Variable Speed Pumping Systems: A Guide to Successful Applications,” pg. 9) For the purposes of this rulemaking, “VSD” will be used when discussing speed control of pumps in general, as applicable to either AC- or DC-driven motors. VFD will only be used when specifically discussing continuous control of AC induction motors.
DOE notes that in general, AHRI's comments are in line with the CIP Working Group recommendation. Specifically, the metric recommended by the CIP Working Group is a weighted average of measurements at specified load points. The CIP Working Group recommended metric incorporates load points of 75, 100, and 110 percent of BEP flow for pumps without continuous or non-continuous controls, and 25, 50, 75, and 100 percent of BEP flow for a pump sold with continuous or non-continuous controls. The latter load points are similar to those specified in AHRI 1210. The reasoning behind these differing loading profiles is further discussed in section III.B.2.a.
2. Selected Metric: Constant Load and Variable Load Pump Energy Index
After carefully considering the Framework stage comments and the recommendations of the CIP Working Group, DOE is proposing to adopt the metric recommended by the CIP Working Group. That metric consists of a ratio of the representative performance of the pump being rated over the representative performance of a pump that would minimally comply with any prospective DOE energy conservation standard for that pump type. The representative performance is referred to as the “pump energy rating” (PER) and is calculated as the equally-weighted average of the electric input power to the pump at three or four load points. As recommended by the CIP Working Group, DOE is also proposing similar metrics for all pumps, regardless of whether they are sold with continuous or non-continuous controls.
For pumps sold without continuous or non-continuous controls, DOE proposes to use three load points near the BEP of the pump to determine the constant load pump energy rating (PER
CL
). For pumps sold with continuous or non-continuous controls, DOE proposes to use four load points to determine the variable load pump energy rating (PER
VL
).
To scale the rated pump performance (PER
CL
or PER
VL
) with respect to the weighted average electrical input power of a bare pump that would minimally comply with any prospective DOE energy conservation standard for that pump type, DOE proposes to define a “standard pump energy rating” (PER
STD
) that represents the performance of a bare pump of the same equipment class that is minimally compliant with DOE's energy conservation standards serving the same hydraulic load. In other words, when determining the PER
STD
for a bare pump, a pump with a motor, or a pump with a motor using either continuous or non-continuous controls, the PER
CL
of a minimally compliant bare pump within the same class would be used. A more detailed discussion of the PER
STD
value is provided in section III.B.2.b.
Specifically, for pumps sold without continuous or non-continuous controls, DOE proposes using the PEI
CL
metric, which would be evaluated as shown in equation (2):
EP01AP15.001
Where:
PER
CL
= the weighted average input power to the motor at load points of 75, 100, and 110 percent of BEP flow (hp) and
PER
STD
= the PER
CL
for a pump of the same equipment class that is minimally compliant with DOE's energy conservation standards serving the same hydraulic load (hp).
Evaluating this metric for a given pump would entail the following steps:
(1) Determining the PER
CL
for that pump in accordance with the specific methods discussed in section III.D,
(2) determining the PER
STD
for a pump of the same equipment class (
i.e.,
pumps of the same configuration and performance characteristics to which a single standard would apply) that would be minimally compliant with the applicable energy conservation standards DOE may set, and
(3) taking a ratio of the two values.
As shown in equation (3), the PER
CL
would be evaluated as the weighted average input power to the motor at load points of 75, 100, and 110 percent of BEP flow:
EP01AP15A.002
Where:
ω
i
= weighting at each rating point (equal weighting),
P
i
in
= measured or calculated input power to the motor at rating point i (hp), and
i = 75, 100, and 110 percent of BEP flow as determined in accordance with the DOE test procedure.
Similarly, for pumps sold with a motor and continuous or non-continuous controls, DOE is proposing using PEI
VL
, which would be evaluated as shown in equation (4):
EP01AP15.003
Where:
PER
VL
= the weighted average input power to the motor and continuous or non-continuous controls at load points of 25, 50, 75, and 100 percent of BEP flow (hp) and
PER
STD
= the PER
CL
for a pump of the same equipment class that is minimally compliant with DOE's energy conservation standards serving the same hydraulic load (hp). The procedure for determining PER
STD
is described in detail in section III.B.2.b.
PEI
VL
would be similarly evaluated for a given pump equipped with motors and continuous or non-continuous controls, by:
(1) Determining the PER
VL
for that pump in accordance with the methods specified in section III.E.1.c,
(2) determining the same PER
STD
as for the same class of pump without continuous or non-continuous controls, and
(3) taking a ratio of the two values.
PER
VL
would then be calculated as a weighted average of input power to the motor and continuous or non-continuous controls at load points of 25, 50, 75, and 100 percent of BEP flow, as shown in equation (5):
EP01AP15.004
Where:
ω
i
= weighting at each rating point (equal weighting),
P
i
in
= measured or calculated input power to the motor at rating point i (hp), and
i = 25, 50, 75, and 100 percent of BEP flow as determined in accordance with the DOE test procedure.
Under DOE's proposed approach, the performance of bare pumps or pumps paired with motors (but without continuous or non-continuous controls) would be determined for the appropriate load points along the single-speed pump curve by increasing head (
i.e.,
throttling) as flow is decreased from the maximum flow rate of the pump. As the flow is decreased, the power will typically decrease slightly. Pumps sold with continuous or non-continuous controls, by contrast, can follow a system curve and achieve the desired flow points by reducing the pump's speed of rotation rather than controlling flow by throttling. By reducing speed, power would be reduced in proportion to the cube of speed, resulting in lower power requirements for any part load flow points. As such, the PEI
VL
for a pump sold with continuous or non-continuous controls will be lower than the PEI
CL
for the same pump sold without continuous or non-continuous controls. In essence, adopting both PEI
CL
and PEI
VL
would illustrate the inherent performance differences that can occur when coupling a given pump with continuous or non-continuous controls.
a. Load Profile
In order to determine the part load performance of pumps, DOE must define a load profile and establish specific part load rating points at which to test a given pump. DOE researched the variety of applications and usage profiles for the pumps considered for the scope of this rulemaking and determined that the data regarding typical duty profiles of covered pumps are extremely variable and not widely available. Thus, it is extremely difficult to generalize duty profiles for a given pump based on type, size, or other factors.
The CIP Working Group indicated that pumps sold as bare pumps and pumps sold with motors are more often installed in constant load applications that are intended to operate in applications with the design load closer to the BEP of the pump. Conversely, the Working Group added that pumps sold with continuous or non-continuous controls are typically applied in more variable applications with design conditions between 25 percent and 100 percent of the BEP flow and head conditions. (Docket No. EERE-2013-BT-NOC-0039, No. 73 at pp. 80-82) Based on the assessment and recommendation provided by the Working Group, DOE is therefore proposing to adopt two distinct load profiles to represent constant speed and variable speed pump operation. See Table III.3.
Table III.3—Load Profiles Based on Pump Configuration
Pump configuration
Load profile
Load points
Pumps Sold without Continuous or Non-Continuous Controls (
i.e.,
bare pumps and pumps sold with motors)
Constant Load Profile
75%, 100%, and 110% of BEP flow.
Pumps Sold with Continuous or Non-Continuous Controls
Variable Load Profile
25%, 50%, 75%, and 100% of BEP flow.
Lack of field data on load profiles and the wide variation in system operation also make it difficult to select appropriate weights for the load profiles. For these reasons, the CIP Working Group members concluded that equal weighting would at least create a level playing field across manufacturers. (See,
e.g.,
Docket No. EERE-2013-BT-NOC-0039, No. 63 at p. 125) DOE also proposes to equally weight the measured input power to the driver or driver and continuous or non-continuous controls at each of the specified flow points in both the constant load and the variable load case, as recommended by the CIP Working Group. Due to the wide range of operating conditions a given pump may experience in the field, DOE believes the proposed load points and weights adequately represent the operating range of pumps sold with and without continuous or non-continuous controls.
DOE requests comment on the proposed load points and weighting for PEI
CL
for bare pumps and pumps sold with motors and PEI
VL
for pumps inclusive of motors and continuous or non-continuous controls.
b. PER
STD
: Minimally Compliant Pump
Within the PEI
CL
and PEI
VL
equations, the average input power to the motor or motor with continuous or non-continuous control in the numerator of these equations would be scaled based on a normalizing factor to provide a rating for each pump model that is indexed to a standardized value. DOE recognizes the benefit of scaling the PEI
CL
and PEI
VL
metrics based on a normalizing factor because it could help compare values across and among various pump types and sizes.
In recognition of these potential advantages, DOE proposes normalizing the weighted average input power to the pump being rated against the weighted average input power to a pump that would minimally comply with the applicable standard for the same class of pump. This approach is consistent with the CIP Working Group's recommendations. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #11 at pg. 5) This approach is also similar to the approach suggested by Europump, a trade association of European pump manufacturers. Europump's approach would normalize the tested input power to the tested pump with a motor and continuous or non-continuous controls, as measured at the input to the continuous or non-continuous control, relative to the reference shaft power for a minimally compliant pump with a minimally compliant motor at the given BEP.
26
Europump's approach relies on the EU's existing regulations for certain categories of rotodynamic pumps designed for pumping clean water which were first published in 2012.
27
26
Europump.
Extended Product Approach for Pumps: A Europump Guide.
April 8, 2013.
27
Council of the European Union. 2012. Commission Regulation (EU) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps. Official Journal of the European Union. L 165, 26 June 2012.
DOE is proposing implementing an approach that would approximate a baseline pump, inclusive of a minimally compliant default motor, to use as a reference pump for each combination of flow and specific speed. The minimally compliant pump would be defined as a function of variables descriptive of the bare pump's physical properties, such as flow and specific speed, as in the EU approach to regulating clean water pumps.
28
DOE proposes to use the same equation used by the EU to develop its standard, translated to 60 Hz electrical input power and English units
29
as shown in equation (6), to determine the efficiency of a minimally compliant pump:
28
Council of the European Union. 2012. Commission Regulation (EU) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps.
Official Journal of the European Union.
L 165, 26 June 2012, pp. 28-36.
29
The equation to define the minimally compliant pump in the EU is of the same form, but employs different coefficients to reflect the fact that the flow will be reported in m
3
/hr at 50 Hz and the specific speed will also be reported in metric units. Specific speed is a dimensionless quantity, but has a different magnitude when calculated using metric versus English units. DOE notes that an exact translation from metric to English units is not possible due to the logarithmic relationship of the terms.
EP01AP15.005
Where:
Q
100
%
= BEP flow rate (gpm),
Ns = specific speed at 60 Hz, and
C = an intercept that is set for the two-dimensional surface described by equation (6), which is set based on the speed of rotation and equipment type of the pump model. The values of this intercept, or “C-values,” used for determining pump efficiency for the minimally compliant pump would be established in the pump energy conservation standard rulemaking.
In the above equation (6), the specific speed (N
s
) is a quasi-non-dimensional number used to classify pumps based on their relative geometry and hydraulic characteristics. It is calculated as a function of the rotational speed, flow rate, and head of the pump as shown in equation (7) below:
EP01AP15.006
Where:
N
s
= specific speed,
N = speed of rotation (rpm),
Q
100
%
= BEP flow rate (gpm), and
H
100
%
= total head at BEP flow (ft).
Under this proposal, the calculated efficiency of the minimally compliant pump reflects the pump efficiency at BEP. As pump efficiency typically varies as a function of flow rate, DOE must also determine a method to specify the default efficiency of a minimally compliant pump at the load points corresponding to 75 and 100 percent of BEP flow. To do so, DOE also proposes to follow the approach used in the EU regulations; that is, DOE proposes to scale the efficiency determined at 100 percent of BEP flow in equation (6) using nominal and standardized values that represent how pump efficiency typically changes at part load (75 percent of BEP flow) and over load (110 percent of BEP flow) load conditions. Namely, the efficiency at 75 percent of BEP flow is assumed to be 94.7 percent of that at 100 percent of BEP flow, and the pump efficiency at 110 percent of BEP flow is assumed to be 98.5 percent of that at 100 percent of BEP flow, as shown in equation (8):
EP01AP15.007
Where:
ω
i
= weighting at each rating point (equal weighting or
1/3
in this case),
P
Hydro,i
= the measured hydraulic output power at rating point i of the tested pump (hp),
η
pump,STD
= the minimally compliant pump efficiency, as determined in accordance with equation (6),
L
i
= the motor losses at each load point i, as determined in accordance with the procedure specified for bare pumps in sections III.E.1.a. and III.D.2, and
i = 75, 100, and 110 percent of BEP flow, as determined in accordance with the DOE test procedure.
Equation (8) also demonstrates how the ratio between the minimally compliant pump efficiency and the hydraulic output power for the rated pump is used to determine the input power to a minimally compliant pump at each load point. Note that the pump hydraulic output power for the minimally compliant pump would be the same as that for the particular pump being evaluated. Under DOE's proposed approach, calculating the hydraulic power in equation (8) at 75, 100, and 110 percent of BEP flow, would require the following equation (9):
EP01AP15.008
Where:
P
Hydro,i
= the measured hydraulic output power at rating point i of the tested pump (hp),
Q
i
= the measured flow rate at each rating point i of the tested pump (gpm),
H
i
= pump total head at each rating point i of the tested pump (ft), and
SG = the specific gravity of water at specified test conditions.
The calculated shaft input power for the minimally compliant pump at each load point is then combined with a minimally compliant motor for that default motor type and appropriate size, described in section III.D.1, and the default part load loss curve, described in section III.D.2, to determine the input power to the motor at each load point. The applicable minimum nominal full load motor efficiency is determined as a function of type (
i.e.,
open or enclosed), pole configuration, and horsepower rating, as specified by DOE's electric motor standards. PER
STD
would then be determined as the weighted average input power to the motor at each load point, as shown in equation (8).
The use of a reference denominator based on PER
CL
for a minimally compliant bare pump (including assigned default motor losses), as described in the preceding paragraphs, was recommended by the CIP Working Group. The benefit of this approach is that it would consistently show the difference between a given pump's performance and the baseline performance of a pump with the same flow and specific speed. A value higher than 1.0 would indicate that the pump would exceed the applicable pump energy consumption standard and would not comply, while a lower value would indicate that the pump is less consumptive than the maximum allowed by the standard and would therefore comply.
To implement the Working Group's recommended approach, DOE's proposal would describe how to calculate PEI
CL
and PEI
VL
as a ratio of the weighted average input power of the tested pump model over the weighted average input power of a minimally compliant bare pump paired with a minimally compliant motor with no controls, as shown in equations (10) and (11):
EP01AP15.054
Where:
PEI
CL
= the pump energy index for a constant load (applicable to bare pumps and pumps sold with a motor) (hp),
ω
i
= weighting at each rating point (equal weighting or
1/3
in this case),
P
i
in
= measured or calculated input power to the motor at rating point i for the tested pump (hp),
P
Hydro,i
= the measured hydraulic output power at rating point i of the tested pump (hp),
η
pump,STD
= the minimally compliant pump efficiency, as determined in accordance with equation (6),
L
i
= the motor losses at each load point i, as determined in accordance with the procedure specified for bare pumps in sections III.E.1.a. and III.D.2 (hp), and
i = 75, 100, and 110 of BEP flow, as determined in accordance with the DOE test procedure.
Equation (10) would apply to both bare pumps and pumps sold with a motor (but without any accompanying continuous or non-continuous controls). For pumps sold with motors inclusive of continuous or non-continuous controls, the PEI
VL
would be calculated as defined in equation (11) below:
EP01AP15.010
Where:
PEI
VL
= pump energy index for a variable load (applicable to pumps sold with a motor and continuous or non-continuous controls),
ω
i
= weighting at each rating point (equal weighting
1/3
or
1/4
as applicable),
P
i
in
= measured or calculated input power to the continuous or non-continuous controls at rating point i for the tested pump,
P
Hydro,i
= the measured hydraulic output power at rating point i of the tested pump (hp),
η
pump,STD
= the minimally compliant pump efficiency, as determined in accordance with equation (6),
L
i
= the motor losses at each load point i, as determined in accordance with the procedure specified for bare pumps in sections III.E.1.a. and III.D.2, and
i = 25, 50, 75, 100, and 110 percent of BEP flow, as determined in accordance with the DOE test procedure, where the load points are as noted in equation (11).
DOE requests comments on the proposed PEI
CL
and PEI
VL
metric architecture.
Default Motor Efficiency for the Minimally Compliant Pump
DOE notes that the default motor efficiency discussed above varies as a function of motor horsepower. As such, DOE must prescribe a consistent method to determine the rated horsepower, and thus default efficiency, of the hypothetical minimally compliant motor used to determine PER
STD
. DOE proposes that for bare pumps, which must be assigned a hypothetical default motor in order to calculate the proposed PEI
CL
metric, the motor horsepower for the minimally compliant pump (PER
STD
) would be determined using the bare pump (PER
CL
), described in section III.D.1.a. This procedure would select the default motor's horsepower as equivalent to, or the next highest horsepower-rated level greater than, the calculated pump shaft input power of the pump when evaluated at 120 percent of BEP flow. This approach would yield the same motor horsepower being selected for bare pumps and for their associated minimally compliant pump.
For pumps sold with motors and pumps sold with motors and continuous or non-continuous controls, manufacturers could choose to sell their pump with a motor whose horsepower varies from that assumed based on the default motor selection criteria. See section III.D.1.a., infra. In such a case, the horsepower of the default motor selected to calculate PER
STD
may vary from that of the one sold with the evaluated pump. DOE believes that applying the same motor horsepower to both the pump being evaluated and the minimally compliant pump (PER
STD
) would provide the most equitable and straight-forward comparison of pump performance. As a result, DOE is proposing to require that if a pump is sold with: (1) A motor or (2) a motor and continuous or non-continuous controls, the motor horsepower for the minimally compliant pump used in the calculation would be based on the horsepower rating of the motor with which that pump is sold. To determine the minimally compliant pump's associated motor part load losses at each load point, the nominal full load efficiency associated with that motor's horsepower would be determined based on a motor that minimally complies with the applicable DOE electric motor energy conservation standards (or in the case of submersible motors, as described in section III.D.1.b) and using the procedure for calculating part load losses described in section III.D.2.
DOE requests comment on its proposal to base the default motor horsepower for the minimally compliant pump on that of the pump being evaluated. That is, the motor horsepower for the minimally compliant pump would be based on the calculated pump shaft input power of the pump when evaluated at 120 percent of BEP flow for bare pumps and the horsepower of the motor with which that pump is sold for pumps sold with motors (with or without continuous or non-continuous controls).
C. Determination of Pump Performance
To determine PEI
CL
or PEI
VL
for applicable pumps, the proposed test procedure would require physically measuring the performance of either: (1) The bare pump, under the calculation-
based methods (see section III.E.1), or (2) the entire pump, inclusive of any motor, continuous control, or non-continuous control, under the testing-based methods (III.E.2). Specifically, the input power to the pump at 75, 100, and 110 percent of BEP flow for PEI
CL,
or at 25, 50, 75, and 100 percent of BEP flow for PEI
VL,
is required for input into the PEI
CL
or PEI
VL
equations, respectively. Depending on whether the calculation-based method or testing-based method is applied, a slightly different test method would apply for measuring pump performance. In the case of the calculation-based method, only the bare pump performance is physically measured—the performance of the motor and any continuous or non-continuous controls would be addressed through a series of calculations. In the case of the testing-based method, the full wire-to-water performance of the pump is physically measured and the measured input power to the pump at the motor or at the continuous or non-continuous control, if any, is used to calculate PEI
CL
or PEI
VL
. In either case, DOE's test procedure, as proposed, would require instructions for how to physically measure the performance of bare pumps, pumps with motors, and pumps with motors and continuous or non-continuous controls in a standardized and consistent manner.
1. Referenced Industry Standards
In developing this proposal, DOE reviewed domestic and international industry test procedures. Table III.4 shows a number of industry test methods that relate to the pumps for which DOE is considering adopting a test method and standards.
Table III.4—Overview of Currently Available Pump Test Procedures
Test procedure
Origin
Notes
ANSI/HI 14.6-2011, “Rotodynamic Pumps for Hydraulic Performance Acceptance Tests”
United States
Harmonized with ANSI/HI 11.6 and ISO 9906-2012.
HI 40.6-2014, “Methods for Rotodynamic Pump Efficiency Testing”
United States
Developed, in coordination with DOE and the CIP Working Group, to support DOE's pump test procedure.
ANSI/HI 11.6-2012, “Submersible Pump Tests”
United States
Harmonized with ANSI/HI 14.6.
ASME PTC 8.2-1990, “Centrifugal Pump”
United States
References dated measurement techniques.
ISO 9906-2012 Rotodynamic pumps—Hydraulic performance acceptance tests—Grades 1, 2 and 3
International
Harmonized with ANSI/HI 14.6 and referenced in EU regulations.
*
ISO 5198-1999 Centrifugal, mixed flow, and axial pumps. Code for hydraulic performance tests. Precision class
International
Provides guidance for measurement of very high accuracy. Includes specification of an optional thermodynamic method for direct measurement of pump efficiencies.
AS 2417-2001 Rotodynamic pumps—Hydraulic performance acceptance tests—Grades 1 and 2
Australia
Based on ISO 9906-2012.
GB/T 3216-2005
China
Based on ISO 9906-2012.
NOM-010-ENER-2004 Submersible deep well clean water motor pumps
Mexico
Based on ISO 9906-2012.
NOM-001-ENER-2000 Vertical turbine pumps with external vertical electric motor for pumping clean water for irrigation, municipal supply, or industrial supply
Mexico
Based on ISO 3555 (predecessor to 9906-2012).
* Council of the European Union. Commission Regulation (EU) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps.
Official Journal of the European Union.
L 165, 26 June 2012, pp. 28-36.
As presented in the Framework Document, DOE determined that ANSI/HI 14.6-2011: (1) Is the most widely used test standard in the pump industry for evaluating pump performance; (2) defines uniform methods for conducting laboratory tests to determine flow rate, head, power, and efficiency at a given speed of rotation; and (3) applies to all pumps that DOE is considering regulating. See section III.A., supra. In the Framework Document, DOE requested comments from interested parties on the use of several test procedures, including ANSI/HI 14.6-2011, as a basis for developing DOE's test procedure. HI, Grundfos, and AHRI all recommended the use of ANSI/HI 14.6-2011 for stand-alone pump testing (
i.e.,
testing of a bare pump without a motor and without continuous or non-continuous controls). (HI, No. 25 at p. 34, Grundfos, No. 24 at p. 17, and AHRI, No. 28 at p. 2)
After publication of the Framework Document, HI convened a group of subject matter experts to, in coordination with DOE and the CIP Working Group, revise ANSI/HI 14.6-2011 to make the test protocol more relevant for incorporation by DOE as part of the DOE test procedure. The new, revised standard was issued by HI in July 2014 as HI 40.6-2014 and incorporates several improvements over the previous testing standard, including greater precision and accuracy in describing evaluation techniques and mandatory language. The CIP Working Group recommended that whatever procedure the DOE adopts, it should be consistent with HI 40.6-2014 for determining bare pump performance. (Docket No. EERE-2013-BT-NOC-0039, No. 92, Recommendation #10 at pg. 4)
DOE has reviewed HI 40.6-2014 and determined that it contains the relevant test methods needed to accurately characterize the performance of the pumps that would be addressed by this rulemaking. These test methods include a means to determine pump shaft input power (for the calculation-based methods) and input power to the motor or motor and continuous or non-continuous controls (for the testing-based methods) at the specified load points. Specifically, HI 40.6-2014 defines and explains how to calculate pump power input,
30
driver power input,
31
pump power output,
32
pump efficiency,
33
bowl efficiency,
34
overall
efficiency,
35
and other relevant quantities. HI 40.6-2014 also contains appropriate specifications regarding the scope of pumps covered by the test methods, test methodology, standard rating conditions, equipment specifications, uncertainty calculations, and tolerances. Additionally, HI 40.6-2014, when coupled with the minor modifications specified in section III.C.2.a, would provide clarity regarding certain mandatory requirements when performing the test procedure, such as the test conditions and instrumentation requirements necessary to ensure testing accuracy and repeatability.
30
The term “pump power input” in HI 40.6-2014 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.
31
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.
32
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.
33
The term “pump efficiency is defined in HI 40.6-2014 as a ratio of pump power output to pump power input.
34
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.
35
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.
To limit the overall burden presented by this proposal, DOE has chosen an approach that is as closely aligned as possible with existing and widely used industry test procedures. Although HI 40.6-2014 is a new test standard, its methods are substantially the same as those specified in ANSI/HI 14.6-2011 and currently used to evaluate pumps in the industry. Accordingly, in DOE's view, HI 40.6-2014, as a procedure based on an already widely used and recognized industry-developed procedure, is an appropriate method for evaluating bare pump/pump and motor performance. For this reason, DOE is proposing to incorporate this testing standard as part of DOE's test procedure for measuring the energy consumption of pumps, with the minor modifications and exceptions listed in the following sections III.C.2.a through III.C.2.f.
DOE requests comment on using HI 40.6-2014 as the basis of the DOE test procedure for pumps.
2. Minor Modifications and Additions to HI 40.6-2014
In general, DOE finds the test methods contained within HI 40.6-2014 are sufficiently specific and reasonably designed to produce test results which measure energy efficiency and energy use. However, in DOE's view, a few minor modifications are necessary to ensure repeatable and reproducible test results and to provide measurement methods and equipment specifications for the entire scope of pumps that DOE is addressing as part of this proposal.
a. Sections Excluded From DOE's Incorporation by Reference
While DOE proposes to reference HI 40.640.6-2014 as the basis for its proposed test procedure, DOE notes that some sections of the standard are not applicable to DOE's regulatory framework. Specifically, section 40.6.5.3 provides requirements regarding the generation of a test report and appendix “B” provides guidance on test report formatting, both of which are not required for testing and rating pumps in accordance with DOE's proposed procedure. As such, DOE proposes to not incorporate by reference section 40.6.5.3 and appendix B of HI 40.6-2014.
HI 40.6-2014 also contains relevant requirements for the characteristics of the testing fluid to be used when testing pumps in section 40.6.5.5, “Test conditions.” Specifically, section 40.6.5.5 requires that “tests shall be made with clear water at a maximum temperature of 10-30 °C (50-86 °F)” and clarifies that “clear water means water to be used for pump testing, with a maximum kinematic viscosity of 1.5 × 10
−
6
m
2
/s (1.6 × 10
−
5
ft
2
/s) and a maximum density of 1000 kg/m
3
(62.4 lb/ft
3
).” DOE agrees with these requirements and proposes to include them in the incorporation by reference of HI 40.6-2014. However, in section A.7 of appendix A, “Testing at temperatures exceeding 30 °C (86 °F),” HI 40.6-2014 addresses testing at temperatures above 30 °C (86 °F). DOE does not intend to allow testing with liquids other than those meeting the definition of clear water presented above, including water at elevated temperatures.
36
As such, DOE also proposes to exclude section A.7 from the incorporation by reference of HI 40.6-2014.
36
Testing at higher temperatures may be conducted by manufacturers when their pumps are designed for a specific, higher-temperature application. However, for DOE's purposes in developing a test procedure to determine the energy use of pumps, testing outside the nominal, standardized rating conditions is unnecessary.
DOE requests comment on its proposal to not incorporate by reference section 40.6.5.3, section A.7, and appendix B of HI 40.6-2014 as part of the DOE test procedure.
b. Data Collection and Determination of Stabilization
In order to ensure the repeatability of test data and results, the DOE pump test procedure must provide instructions regarding how to sample and collect data at each load point such that the collected data is taken at stabilized conditions that accurately and precisely represent the performance of the pump at that load point. HI 40.6-2014 provides that all measurements shall be made under steady state conditions, which are described as follows: (1) No vortexing, (2) margins as specified in ANSI/HI 9.6.1 Rotodynamic Pumps Guideline for NPSH Margin, and (3) when the mean value of all measured quantities required for the test data point remain constant within the permissible amplitudes of fluctuations defined in Table 40.6.3.2.2 over a minimum time of 10 seconds before data are collected. However, HI 40.6-2014 does not specify the frequency of data collection. As such, determining stabilization, as specified, could occur based on a minimum of two data points (as a minimum of two data points are necessary to calculate a mean) or many data points based on a 1 second or sub-second data sampling frequency. DOE believes that, at a minimum, two data points should be used to determine stabilization and, as such, data must be collected at least every 5 seconds. DOE believes that two data points are necessary because at least two data points are necessary to determine an average. DOE proposes to specify that data shall be collected at least every 5 seconds for all measured quantities.
As noted above, section 40.6.3.2.2 of HI 40.6-2014, “Permissible fluctuations,” provides permissible amplitude of fluctuations for various measured quantities throughout the test. As specified in that section, all measurements must be less than these thresholds for the duration of the measurement period for a valid measurement. The section also describes permissible dampening devices that may be used to minimize noise and large fluctuations in the data. DOE proposes to incorporate by reference section 40.6.3.2.2 except that dampening devices would only be permitted to integrate up to the data collection interval, or 5 seconds, to ensure that each data point is reflective of a unique measurement.
DOE requests comment on its proposal to require that data be collected at least every 5 seconds for all measured quantities.
DOE requests comment on its proposal to allow dampening devices, as described in section 40.6.3.2.2, but with the proviso noted above (
i.e.,
permitted to integrate up to the data collection interval, or 5 seconds).
c. Modifications Regarding Test Consistency and Repeatability
Sections 40.6.5.6 and 40.6.5.7 of HI 40.6-2014 specify test arrangements and test conditions. However, DOE finds that the standardized test conditions described in these sections are not sufficient to produce accurate and repeatable test results. Specifically, the nominal pump speed, the input power
characteristics, and the number of stages to test for multi-stage pumps are not addressed, all of which could impact the measured test result for a given pump unit. To address these potential sources of variability or ambiguity, DOE proposes to adopt several additional requirements to further specify the procedures for adjusting the test data to standardized rating conditions.
HI 40.6-2014 specifies that testing shall be done with clear water and defines clear water for the purposes of pump testing. HI 40.6-2014 also provides a standardized description of the method for configuring pumps for testing. However, additional specifications not present in HI 40.6-2014 are also required regarding the speed of rotation, the characteristics of the power supply, and the configuration of specific pump types for the purposes of testing pumps and for use in any subsequent calculations to determine the PEI
CL
or PEI
VL
.
Pump Speed
The rated speed of a pump affects the efficiency and PEI
CL
or PEI
VL
of that pump. To limit variability and increase repeatability within the test procedure, DOE is proposing to include nominal rating speeds of 3,600 and 1,800 rpm at 60 Hz. For pumps sold without motors, the nominal rating speed would be selected based on the speed of rotation for which the pump is designed. Specifically, pumps designed to operate at any speed of rotation between 2,880 and 4,320 rpm would be rated at 3,600 rpm and pumps designed to operate at any speed of rotation between 1,440 and 2,160 rpm would be rated at 1,800 rpm, as noted in Table III.5.
Table III.5—Nominal Speed of Rotation for Different Configurations of Pumps
Pump configuration
Pump design
speed of rotation
Style of motor
Nominal speed of rotation for rating
Bare Pump
2,880 and 4,320 rpm
N/A
3,600 rpm.
1,440 and 2,160 rpm
1,800 rpm.
Pump + Motor OR
N/A
2-pole Induction Motor
3,600 rpm.
Pump + Motor + Control
N/A
4-pole Induction Motor
1,800 rpm.
N/A
Non-Induction Motor Designed to Operate between 2,880 and 4,320 rpm
3,600 rpm.
N/A
Non-Induction Motor Designed to Operate between 1,440 and 2,160 rpm
1,800 rpm.
DOE proposes that pumps designed to operate at speeds that include both ranges would be rated at both nominal speeds of rotations. DOE notes that each nominal speed rating would represent a different basic model of pump. DOE selected these operating speed ranges consistent with the tolerance about the nominal rating speed allowed for in the test procedure. Specifically, section 40.6.5.5.2 of HI 40.6-2014 requires that the tested speed be maintained within 20 percent of the rated speed, or the specified nominal speed of rotation in this case. Therefore, any pump “designed for operation” at any speed of rotation between, for example, 2,880 and 4,320 rpm would be able to be tested under the proposed test procedure at the design speed of rotation and the results corrected to the rated nominal speed of rotation of 3,600 rpm.
DOE notes that these speed ranges are not exclusive. That is, if a pump were to be designed to operate from 2,600 to 4,000 rpm, such a pump would have a nominal speed of rotation of 3,600 rpm for the purposes of testing and rating the pump.
For pumps sold with motors, DOE proposes that the nominal speed of rotation be selected based on the speed(s) for which the motor is designed to operate. Specifically, as shown in Table III.5, pumps sold with 2-pole induction motors would be evaluated at 3,600 rpm, and pumps sold with 4-pole induction motors would be evaluated at 1,800 rpm. Pumps sold with non-induction motors (
e.g.,
DC motors and ECMs) would be evaluated at the nominal rating speed that falls within the operating range of the motor with which the pump is being sold. If the pump is sold with a non-induction motor that is designed to operate at any speed of rotation between 2,880 and 4,320 rpm, that pump would be rated at a nominal speed of rotation of 3,600 rpm. If the pump is sold with a non-induction motor that is designed to operate at any speed of rotation between 1,440 and 2,160 rpm, that pump would be rated at 1,800 rpm. If the operating range of the non-induction motor with which the pump is distributed in commerce includes speeds of rotation that are both between 2,880 and 4,320 rpm and between 1,440 and 2,160 rpm, the pump would be rated at both 3,600 and 1,800 rpm and each nominal speed of rotation would represent a separate basic model.
However, DOE acknowledges that it may not be feasible to operate pumps during the test at exactly 3,600 or 1,800 rpm. Therefore, DOE proposes that all data collected as a result of the test procedure at the speed measured during the test be adjusted to the nominal speed prior to use in subsequent calculations and that the PEI
CL
or PEI
VL
of a given pump be based on the nominal speed. For pumps sold with motors and continuous or non-continuous controls and that are tested using the testing-based method described in section III.E.2.c, this adjustment to the nominal rating speed would apply only at the 100 percent of BEP flow rating point—subsequent part load points would be measured at reduced speed and would not be adjusted. DOE proposes to use the methods in HI 40.6-2014 section 40.6.6.1.1, “Translation of the test results into data based on the specified speed of rotation (for frequency) and density” to adjust any data from the measured speed to the nominal speed.
In all cases, as required by HI 40.6-2014, the tested speed maintained during the test at each rating point must be maintained within 20 percent of the nominal speed and the speed of rotation recorded at each test point may not vary more than ±1 percent to ensure accurate and reliable results.
DOE requests comment on its proposal to require data collected at the pump speed measured during testing to be normalized to the nominal speeds of 1,800 and 3,600.
DOE requests comment on its proposal to adopt the requirements in HI 40.6-2014 regarding the deviation of tested speed from nominal speed and the variation of speed during the test. Specifically, DOE is interested if maintaining tested speed within ±1 percent of the nominal speed is feasible and whether this approach would produce more accurate and repeatable test results.
Power Supply Characteristics
Because pump power consumption is a component of the proposed metric, inclusive of any motor and continuous or non-continuous controls, measuring power consumption is an important element of the test. The characteristics of the power supplied to the pump affect the accuracy and repeatability of the measured power consumption of the pump. As such, to ensure accurate and repeatable measurement of power consumption, DOE is also proposing to specify nominal characteristics of the power supply. Namely, DOE is proposing nominal values for voltage, frequency, voltage unbalance, total harmonic distortion, and impedance levels, as well as tolerances about each of these quantities, that must be maintained at the input terminals to the motor, continuous control, or non-continuous control, as applicable.
To determine the appropriate power supply characteristics testing pumps with motors (but without continuous or non-continuous controls) and pumps with both motors and continuous or non-continuous controls, DOE examined applicable test methods for electric motors and VSD systems. DOE determined that IEEE Standard 112-2004 (“IEEE Standard Test Procedure for Polyphase Induction Motors and Generators”), which is the test method incorporated by reference at 10 CFR 431.16 for electric motors, is the most applicable test method for electric motors when considering testing and rated values for motors that are integrated with a pump. DOE identified both AHRI 1210-2011, “2011 Standard for Performance Rating of Variable Frequency Drives,” (AHRI 1210-2011) and the 2013 version of the Canadian Standards Association (CSA) Standard C838, “Energy efficient test methods for three-phase variable frequency drive systems,” (CSA C838-2013) as applicable methods for measuring the performance of VSD control systems.
IEEE 112-2004, AHRI 1210-2011, and CSA C838-2013 all specify that voltage and frequency must be maintained at the rated voltage and frequency of the motor ±0.5 percent. In addition, all three standards specify that the power source “voltage unbalance” shall not exceed 0.5 percent during the test. Voltage unbalance is calculated as the maximum voltage deviation from the average measured voltage divided by the average measured voltage.
DOE recognizes that any harmonics in the power system can affect the measured performance of the pump when tested with a motor or motor and continuous or non-continuous control. IEEE 112-2004 and CSA C838-2013 also include requirements to maintain total harmonic distortion below 5 percent. When measuring the input power to the continuous or non-continuous controls that are paired with an electric motor-driven pump, AHRI 1210-2011 and CSA C838-2013 also specify impedance levels of the incoming power supplied to the VSD. AHRI 1210-2011 requires that source impedance not exceed 1 percent, while CSA C838-2013 requires that source impedance shall be greater than 1 percent but not exceed 3 percent for VFDs under 500 hp.
DOE is also proposing to establish these requirements for voltage, frequency, voltage unbalance, total harmonic distortion, and impedance in the DOE pump test procedure when testing pumps that either have motors (but without controls) or pumps with motors with continuous or non-continuous controls.
While some pump manufacturers may be capable and equipped to accurately measure pumps sold with motors and continuous or non-continuous controls in accordance with the proposed power supply characteristics, DOE recognizes that there may be some variability among manufacturers in this regard. Consequently, these requirements may represent a significant incremental burden for some testing facilities. To lessen this burden, DOE proposes to require that power supply requirements would apply only to pumps being evaluated using a physical testing-based method or pumps being tested using a calibrated motor. Pumps evaluated based on the calculation method where the input power to the motor is determined using equipment other than a calibrated motor would not have to meet these requirements, as variations in voltage, frequency, and voltage unbalance are not expected to affect the tested pump's energy performance.
DOE requests comment on the proposed voltage, frequency, voltage unbalance, total harmonic distortion, and impedance requirements that must be met when performing a wire-to-water pump test or when testing a bare pump with a calibrated motor. Specifically, DOE requests comments on whether these tolerances can be achieved in typical pump test labs, or whether specialized power supplies or power conditioning equipment would be required.
Number of Stages for Multi-Stage Pumps
RSV and VTS pumps are typically multi-stage pumps that may be offered in a variety of stages (also known as bowls), each with its own energy consumption characteristics, which scale approximately linearly with each additional bowl. With these pump designs, any improvements in the hydraulic design of the bowl would be reflected in the measured performance of the pump with any number of stages. Thus, to simplify certification requirements and limit testing burden, DOE proposes t
This text is long and has been trimmed here. Open the source document for the complete record.
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.