Energy Conservation Program: Test Procedure for Commercial and Industrial Pumps

DEPARTMENT OF ENERGY

10 CFR Parts 429 and 431

[EERE-2020-BT-TP-0032]

RIN 1904-AC54

Energy Conservation Program: Test Procedure for Commercial and Industrial Pumps

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking and announcement of public webinar.

SUMMARY:

The U.S. Department of Energy (“DOE”) proposes to amend the test procedure for commercial and industrial pumps (“pumps”) to harmonize with updated industry standards, to expand the scope of clean water pumps covered by this test procedure, and to revise calculation methods for pumps sold with motors and controls to better represent field energy use. DOE is seeking comment from interested parties on the proposal and announcing a public meeting to collect comments and data on its proposal.

DATES:

DOE will accept comments, data, and information regarding this proposal no later than June 10, 2022. See section V, “Public Participation,” for details. DOE will hold a webinar on April 26, 2022, from 1:00 p.m. to 4:00 p.m. See section V, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants. If no participants register for the webinar, it will be cancelled.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at

www.regulations.gov,

under docket number EERE-2020-BT-TP-0032. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments by email to

pumps2020tp0032@ee.doe.gov.

Include docket number EERE-2020-BT-TP-0032 in the subject line of the message. No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on this process, see section V of this document.

Although DOE has routinely accepted public comment submissions through a variety of mechanisms, including postal mail and hand delivery/courier, the Department has found it necessary to make temporary modifications to the comment submission process in light of the ongoing COVID-19 pandemic. DOE is currently suspending receipt of public comments via postal mail and hand delivery/courier. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the COVID-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier.

Docket:

The docket, which includes

Federal Register

notices, public meeting attendee lists and transcripts (if a public meeting is held), comments, and other supporting documents/materials, is available for review at

www.regulations.gov.

All documents in the docket are listed in the

www.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.

The docket web page can be found at

www.regulations.gov/docket/EERE-2020-BT-TP-0032.

The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section V for information on how to submit comments through

www.regulations.gov.

FOR FURTHER INFORMATION CONTACT:

Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-2J, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-9870. Email

ApplianceStandardsQuestions@ee.doe.gov.

Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-8145. Email:

Michael.Kido@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in the webinar, contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:

ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

DOE proposes to update a previously approved standard by incorporating by reference the following industry standard into part 431: HI 40.6-2021, “Methods for Rotodynamic Pump Efficiency Testing.”

Copies of HI 40.6-2021 can be obtained from the Hydraulic Institute at 6 Campus Drive, First Floor North, Parsippany, NJ, 07054-4406, or by going to

www.pumps.org.

DOE proposes to maintain previously approved standards incorporated by reference into part 431, except for the following, which DOE proposes to remove from part 431:

ANSI/HI 1.1-1.2-2014, “American National Standard for Rotodynamic Centrifugal Pumps for Nomenclature and Definitions.”

ANSI/HI 2.1-2.2-2014, “American National Standard for Rotodynamic Vertical Pumps of Radial, Mixed, and Axial Flow types for Nomenclature and Definitions.”

For a further discussion of these standards, see section IV.M of this document.

Table of Contents

I. Authority and Background

A. Authority

B. Background

II. Synopsis of the Notice of Proposed Rulemaking

III. Discussion

A. Scope of Applicability

1. Pumps Not Designed for Clean Water Applications

2. Small Vertical Inline Pumps

3. Other Clean Water Pump Categories

a. Between-Bearing Pumps

b. Vertical Turbine Pumps

c. Radially-Split Multi-Stage Horizontal Pumps

d. End-Suction Pumps Similar to ESFM and ESCC Pumps

e. Line Shaft and Cantilever Pumps

4. Scope Limitations

a. Submersible Turbine Pumps With Bowl Diameter Greater Than 6 Inches

b. Pumps Designed To Be Operated at 1,200 RPM

c. Pump Horsepower and Design Speed

d. Horsepower and Number of Stages for Testing

e. Design Temperature Range

B. Definitions

1. Removing Certain References to Volute

2. HI Pump Class References

3. Bowl Diameter

4. Small Vertical Inline Pumps

5. Between-Bearing Pumps

6. Vertical Turbine Pump

7. Radially-Split, Multi-Stage Horizontal Pumps

8. Close-Coupled and Mechanically-Coupled Pumps

9. Tangential Discharge

10. Pump

C. Updates to Industry Standards

1. ANSI/HI 40.6

2. ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014

D. Metric

E. Proposed Amendments to Test Method

1. Nominal Speed

2. Testing of Multi-Stage Pumps

3. Best Fit Curve

4. Load Profile

5. Pumps With BEP at Run-Out

6. Calibration of Measurement Equipment

7. Calculations and Rounding

8. Test Procedure Credits

F. Calculation-Based and Testing-Based Options According to Pump Configuration (Table 1)

1. Calculation Method for Pumps Sold With Induction Motors and Controls

2. Calculation Method for Pumps Sold With Inverter-Only Motors (With or Without Controls)

3. Pumps Sold With Submersible Motors

G. Test Procedure for SVIL Pumps

H. Test Procedure for Other Expanded Scope Pumps

I. Sampling Plan, AEDMs, Enforcement Provisions, and Basic Model

1. Sampling Plan for Determining Represented Values

2. Alternative Efficiency Determination Methods

a. Background

b. Basic Criteria Any AEDM Must Satisfy

c. Validation

d. Records Retention Requirements

e. Additional AEDM Requirements

f. AEDM Verification Testing

3. Enforcement Provisions

4. Basic Model Definition

J. Representations of Energy Use and Energy Efficiency

K. Labeling Requirements

L. Test Procedure Costs and Harmonization

1. Test Procedure Costs and Impact

a. Scope Expansions

b. Calculation Method for Testing Pumps With Inverter-Only Motors

c. Updated Calculation Method for Testing Pumps With Induction Motors

d. Additional Amendments

2. Harmonization With Industry Standards

M. Compliance Date

IV. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

C. Review Under the Paperwork Reduction Act of 1995

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under Section 32 of the Federal Energy Administration Act of 1974

M. Description of Materials Incorporated by Reference

V. Public Participation

A. Participation in the Webinar

B. Procedure for Submitting Prepared General Statements for Distribution

C. Conduct of the Webinar

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VI. Approval of the Office of the Secretary

I. Authority and Background

Commercial and industrial pumps (collectively, “pumps”) are included in the list of “covered equipment” for which DOE is authorized to establish and amend energy conservation standards and test procedures. (42 U.S.C. 6311)(1)(A)) DOE's energy test procedures for pumps are currently prescribed at title 10 of the Code of Federal Regulations (“CFR”), § 431.464, and 10 CFR part 431 subpart Y appendix A (“appendix A”). The following sections discuss DOE's authority to establish test procedures for pumps and relevant background information regarding DOE's consideration of test procedures for this equipment.

A. Authority

The Energy Policy and Conservation Act, as amended (“EPCA”),

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authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part C of EPCA, added by Public Law 95-619, Title IV, section 441(a), established the Energy Conservation Program for Certain Industrial Equipment, which sets forth a variety of provisions designed to improve energy efficiency. This equipment includes pumps, the subject of this document. (42 U.S.C. 6311(1)(A))

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All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020), which reflect the last statutory amendments that impact Parts A and A-1 of EPCA.

The energy conservation program under EPCA consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. EPCA include definitions (42 U.S.C. 6311), test procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315), energy conservation standards (42 U.S.C. 6313), and the authority to require information and reports from manufacturers (42 U.S.C. 6316).

The Federal testing requirements consist of test procedures that manufacturers of covered equipment must use as the basis for: (1) Certifying to DOE that their equipment complies with the applicable energy conservation standards adopted pursuant to EPCA (42 U.S.C. 6316(a); 42 U.S.C. 6295(s)), and (2) making other representations about the efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE must use these test procedures to determine whether the equipment complies with relevant standards promulgated under EPCA. (42 U.S.C. 6316(a); 42 U.S.C. 6295(s))

Federal energy efficiency requirements for covered equipment established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6316(a) and 42 U.S.C. 6316(b); 42 U.S.C. 6297) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions of EPCA. (42 U.S.C. 6316(a))

Under 42 U.S.C. 6314, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered equipment. EPCA requires that any test procedures prescribed or amended under this section must be reasonably designed to produce test results which reflect energy efficiency, energy use or estimated annual operating cost of a given type of covered equipment during a representative average use cycle and requires that test procedures not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2))

EPCA also requires that, at least once every 7 years, DOE evaluate test procedures for each type of covered equipment, including pumps, to determine whether amended test procedures would more accurately or fully comply with the requirements for the test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle.

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(42 U.S.C. 6314(a)(1))

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EPCA also requires after DOE first prescribes a test procedure for regulated industrial equipment, to conduct an evaluation of that test procedure not later than three years after the prescribing of that test procedure—and from time to time thereafter.

See

42 U.S.C. 6314(c). DOE considers this rulemaking to be in satisfaction of this initial evaluation requirement.

In addition, if the Secretary determines that a test procedure amendment is warranted, the Secretary must publish proposed test procedures in the

Federal Register

, and afford interested persons an opportunity (of not less than 45 days' duration) to present oral and written data, views, and arguments on the proposed test procedures. (42 U.S.C. 6314(b)) If DOE determines that test procedure revisions are not appropriate, DOE must publish its determination not to amend the test procedures. (42 U.S.C. 6314(a)(1)(A)(ii)) DOE is publishing this Notice of Proposed Rulemaking (NOPR) in satisfaction of the 7-year review requirement specified in EPCA.

B. Background

DOE's established its test procedure for pumps in a final rule published on January 25, 2016. 81 FR 4086 (“January

2016 Final Rule”).

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The January 2016 Final Rule established definitions for the terms “pump,”

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“driver,”

5

and “controls,”

6

and identified several categories and configurations of pumps. The pumps test procedure currently incorporates by reference the Hydraulic Institute (“HI”) Standard 40.6-2014, “Methods for Rotodynamic Pump Efficiency Testing” (“HI 40.6-2014”), along with several modifications to that testing method related to measuring the hydraulic power, shaft power, and electric input power of pumps, inclusive of electric motors and any continuous or non-continuous controls.

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3

On March 23, 2016, DOE published a correction to the January 2016 Final Rule to correct the placement of the product-specific enforcement provisions related to pumps under 10 CFR 429.134(i). 81 FR 15426.

4

A “pump” means equipment designed to move liquids (which may include entrained gases, free solids, and totally dissolved solids) by physical or mechanical action and includes a bare pump and, if included by the manufacturer at the time of sale, mechanical equipment, driver, and controls.

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A “driver” provides mechanical input to drive a bare pump directly or through the use of mechanical equipment. Electric motors, internal combustion engines, and gas/steam turbines are examples of drivers. (10 CFR 431.462)

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A “control” is used to operate a driver. (10 CFR 431.462)

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A “continuous control” is a control that adjusts the speed of the pump driver continuously over the driver operating speed range in response to incremental changes in the required pump flow, head, or power output. A “non-continuous control” is a control that adjusts the speed of a driver to one of a discrete number of non-continuous preset operating speeds, and does not respond to incremental reductions in the required pump flow, head, or power output. 10 CFR 431.462.

On September 28, 2020, DOE published an early assessment review request for information (“RFI”) to determine whether to proceed with a rulemaking to amend the test procedure for commercial and industrial pumps. 85 FR 60734 (“September 2020 Early Assessment RFI”). Following review of the comments received in response to the September 2020 Early Assessment RFI, on April 16, 2021, DOE published an RFI in which it sought data and information pertinent to whether amended test procedures would (1) more accurately or fully comply with the requirement that the test procedure produces results that measure energy use during a representative average use cycle for the equipment without being unduly burdensome to conduct, or (2) reduce testing burden. 86 FR 20075 (“April 2021 RFI”). In response to requests from stakeholders,

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on May 5, 2021, DOE published an extension of the comment period for an additional 30 days. (86 FR 23875) DOE received comments in response to the April 2021 RFI from the interested parties listed in Table I.1.

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A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.

10

8

Price Pump, EERE-2020-BT-TP-0032, No. 10 at p. 1; Hydraulic Institute EERE-2020-BT-TP-0032, No. 11 at p. 1; Grundfos, EERE-2020-BT-TP-0032, No. 12, at p. 1; Xylem, EERE-2020-BT-TP-0032, No. 13 at p. 1.

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In addition to the comments listed in Table I.1, DOE also received one comment from an individual, which was unrelated to the test procedures for pumps.

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The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop test procedures for pumps (Docket No. EERE-2020-BT-TP-0032, which is maintained at

www.regulations.gov/#!docketDetail;D=EERE-2020-BT-TP-0032

). The references are arranged as follows: (Commenter name, comment docket ID number, page of that document).

EP11AP22.000

In their comments, Summit asserted that the industry as a whole has become more aware of DOE's energy standards for pumps since January 2020 when the pumps standards went into effect. (Summit, No. 16 at p. 7) Grundfos suggested that DOE consider eliminating multiple open notices that affect a given industry to ensure proper stakeholder engagement. (Grundfos, No. 17 at p. 1)

As noted, EPCA requires DOE to periodically review the test procedures of covered equipment, including pumps, to determine whether amended test procedures would more accurately or fully comply with the requirements for the test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle. (42 U.S.C. 6314(a)(1)) In order to provide stakeholders opportunities to engage as part of DOE's decision making, DOE provided opportunity for stakeholder comment to the September 2020 Early Assessment RFI and the April 2021 RFI. This NOPR provides further opportunity for comment on

proposed amendments to the test procedure for pumps, which are discussed in the following sections. DOE acknowledges that it has multiple open notices that may inordinately impact a given industry at any time. However, DOE notes that the purpose of the rulemaking process is to engage stakeholders. While notices have specific comment dates by which comments are due, stakeholders may submit material to the rulemaking docket at any time during the course of the rulemaking by contacting the DOE program manager.

II. Synopsis of the Notice of Proposed Rulemaking

In this NOPR, DOE is proposing to:

(1) Expand the scope of the test procedure to include additional clean water pumps, specifically:

(a) Between-bearing (“BB”) pumps;

(b) radially-split, multi-stage, horizontal,

(c) in-line diffuser casing (“RSHIL”) pumps;

(d) radially-split, multi-stage, horizontal, end-suction diffuser casing (“RSHES”) pumps;

(e) small vertical in-line (“SVIL”) pumps;

(f) vertical turbine (“VT”) pumps;

(g) pumps sold with 6-pole induction motors or motors with design speeds between 960 rpm and 1,440 rpm;

(h) submersible turbine (“ST”) pumps with bowl diameters larger than 6 inches; and

(i) end-suction pumps not covered by the current test procedure;

(2) Clarify the applicability of the design temperature range scope limitation and modify the range parameters;

(3) Add and modify certain definitions in 10 CFR 431.462 to accommodate the expansion of scope and clarify existing definitions;

(4) Incorporate by reference HI 40.6-2021 into 10 CFR 431.463 and make minor revisions to the test procedure to address provisions in the current DOE test procedure that have been added to HI 40.6-2021;

(5) Remove the incorporations by reference of ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014;

(6) Add specifications for stages for testing for expanded scope multi-stage pumps;

(7) Clarify test provisions for pumps with BEP at run-out;

(8) Clarify test provisions for calibration of measurement equipment;

(9) Update part-load loss factor equation coefficients in the calculation method for pumps sold with induction motors and controls;

(10) Provide a calculation method for pumps sold with inverter-only motors;

(11) Update the test procedure for submersible pumps to address proposed DOE coverage of submersible motors;

(12) Update the test procedure to address SVIL pumps;

(13) Add provisions for testing and rating pumps sold with a 6-pole induction motor or with design speeds between 960 rpm and 1,440 rpm; and

(14) Allow use of Alternative Efficiency Determination Methods (“AEDMs”).

DOE's proposed actions are summarized in Table II.1 compared to the current test procedure as well as the reason for the proposed change.

BILLING CODE 6450-01-P

EP11AP22.001

EP11AP22.002

BILLING CODE 6450-01-C

DOE has tentatively determined that the proposed amendments described in section III of this NOPR would not alter the measured efficiency of commercial and industrial pumps that are currently included in the scope of DOE's energy conservation standards for pumps. Therefore, DOE does not expect that retesting or recertification would be necessary for currently certified pumps as a result of DOE's adoption of the proposed amendments to the test procedures, if made final. Additionally, DOE has tentatively determined that the proposed amendments, if made final, would not increase the cost of testing for these pumps. As such, for pumps currently within the scope of DOE's energy conservation standards, any representations regarding the energy consumption of a pump or the cost of energy consumed by a pump would have to be made in accordance with the amended test procedure beginning 180 days after publication of the final rule. (42 U.S.C. 6314(d))

For pumps that are not currently within the scope of the test procedure and are not currently required to certify pump energy use, DOE is proposing that the test requirements proposed in appendix A, if adopted, would take place on the compliance date of amended energy conservation standards for pumps that DOE may ultimately decide to adopt as part of a separate rulemaking assessing the technological feasibility and economic justification for such standards. In other words, for pumps that DOE is proposing to include in the scope of the proposed test procedure, manufacturers would need to use the results of testing under appendix A to determine compliance with any new energy conservation standards that DOE may establish for these pumps.

Discussion of DOE's proposed actions are addressed in detail in section III of this NOPR.

III. Discussion

In the following sections, DOE proposes certain amendments to its test procedures for pumps. For each proposed amendment, DOE provides relevant background information, explains why the amendment merits consideration, discusses relevant public comments, and proposes a potential approach.

A. Scope of Applicability

The current DOE test procedure for pumps applies to five categories of “clean water pumps” with specific defined characteristics, and excludes certain defined categories

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of pumps. 10 CFR 431.464(a)(1).

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The excluded categories of pumps are fire pumps; self-priming pumps; prime-assist pumps; magnet driven pumps; pumps designed to be used in a nuclear facility subject to 10 CFR part 50, “Domestic Licensing of Production and Utilization Facilities”; and pumps meeting the design and construction requirements set forth in Military Specifications: MIL-P-17639F, “Pumps, Centrifugal, Miscellaneous Service, Naval Shipboard Use” (as amended); MIL-P-17881D, “Pumps, Centrifugal, Boiler Feed, (Multi-Stage)” (as amended); MIL-P-17840C, “Pumps, Centrifugal, Close-Coupled, Navy Standard (For Surface Ship Application)” (as amended); MIL-P-18682D, “Pump, Centrifugal, Main Condenser Circulating, Naval Shipboard” (as amended); and MIL-P-18472G, “Pumps, Centrifugal, Condensate, Feed Booster, Waste Heat Boiler, And Distilling Plant” (as amended). 10 CFR 431.464(a)(1)(iii).

DOE defines “clean water pump” as a pump that is designed for use in pumping water with a maximum non-absorbent free solid content of 0.016 pounds per cubic foot, and with a maximum dissolved solid content of 3.1 pounds per cubic foot, provided that the total gas content of the water does not exceed the saturation volume, and disregarding any additives necessary to prevent the water from freezing at a minimum of 14 °F. 10 CFR 431.462.

The five categories of clean water pumps to which the current test procedure applies are: End-suction close-coupled (“ESCC”); end-suction frame mounted/own bearings (“ESFM”); in-line (“IL”); radially-split, multi-stage, vertical, in-line diffuser casing (“RSV”); and submersible turbine (“ST”). 10 CFR 431.464(a)(1)(i). The defined characteristics specify limits on flow rate, maximum head, design temperature range, motor type, bowl diameter, and speed.

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10 CFR 431.464(a)(1)(ii). In the context of the energy conservation standards, pumps are further delineated into equipment classes based on nominal speed of rotation and operating mode (

i.e.,

constant load or variable load). 10 CFR 431.465.

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More specifically, these characteristics include: (A) flow rate of 25 gpm or greater at BEP and full impeller diameter; (B) maximum head of 459 feet at BEP and full impeller diameter and the number of stages required for testing; (C) design temperature range from 14 to 248 °F; (D) designed to operate with either (1) a 2- or 4-pole induction motor, or (2) a non-induction motor with a speed of rotation operating range that includes speeds of rotation between 2,880 and 4,320 revolutions per minute (rpm) and/or 1,440 and 2,160 rpm, and in either case, the driver and impeller must rotate at the same speed; (E) For ST pumps, a 6-inch or smaller bowl diameter; and (F) For ESCC and ESFM pumps, a specific speed less than or equal to 5,000 when calculated using U.S. customary units. 10 CFR 431.464(a)(1)(ii).

In the April 2021 RFI, DOE requested comment on the percentage of pump models that fall within the scope of DOE's current test procedure. 86 FR 20075, 20079. Additionally, DOE also sought information regarding how manufacturers communicated performance in catalogs and other related literature for out-of-scope pumps.

Id.

DOE also requested shipment and market performance data for SVIL pumps, pumps operating with motors at speeds different than 1,800 rpm or 3,600 rpm, submersible turbine pumps with a bowl diameter greater than 6 inches, and other pumps that are currently excluded from scope based on the pump characteristics provided at 10 CFR 431.464(a)(1)(ii).

Id.

In response, Grundfos generally recommended that an expansion to the

pumps test procedure scope should be addressed through a negotiated rulemaking process. (Grundfos, No. 17 at p. 3) Similarly, HI commented that manufacturers and other stakeholders should be involved in creating new pump categories. (HI, No. 20 at p. 3) HI also stated that significant changes to the test procedure and scope may lead to market confusion and result in additional testing burden (HI, No. 20 at p. 1) DOE notes that it published a notice on October 29, 2021 announcing a meeting of the Appliance Standards and Rulemaking Federal Advisory Committee (“ASRAC”) held on December 14, 2021 to discuss and prioritize topic areas for which ASRAC can assist the Appliance and Equipment Standards Program. 86 FR 60020. At this meeting, pumps themselves were not suggested as a category for negotiation, but extended equipment systems (

i.e.,

motor, drive, and driven load) inclusive of the pump were discussed for possible negotiation.

Summit responded that eight percent of their models are within scope of the DOE test procedure and that pump performance information is published in catalogs, pump curves, and brochures. (Summit, No. 16 at p. 3) Additionally, Summit stated that all in-scope pumps are labeled as meeting the DOE standard.

Id.

Grundfos stated that it has 27 basic models that it does not certify based on the scope limitations in the DOE test procedure. (Grundfos, No. 17 at p. 2) HI estimated that approximately 14 percent of manufacturer basic models would not be included in the scope of the current DOE standards because they are SVILs or because of the limitations included in 10 CFR 431.464(a)(1)(ii). (HI, No. 20 at p. 3) HI also stated that for products not within scope, manufacturers generally do not make representations of the pump energy index (“PEI”) value. (HI, No. 20 at p. 3) NEEA stated that it found that 16 percent of pumps reported by distributors (which are typically heating, ventilation, and air conditioning (“HVAC”) and domestic water equipment companies) are not included in DOE's current test procedure scope. (NEEA, No. 21 at p. 3) NEEA asserted that nearly all of the pumps sold by these distributors pump clean water and therefore should be in scope.

Id.

Although stakeholders did not respond to DOE's request for data on pumps operating with motors at speeds other than 1,800 rotations per minute (“rpm”) or 3,600 rpm in the April 2021 RFI, DOE did receive comments on this issue in response to the August 9, 2021 pumps energy conservation standards early assessment review RFI (“August 2021 ECS RFI”, Docket EERE-2021-BT-STD-0018, No. 1). 86 FR 43430. Specifically, the CA IOUs stated that for one pump distributor, 27 percent of its commercial pump sales were either pumps with motors running at 1,200 rpm or double suction pumps

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(both of which are not included in the scope of DOE's current test procedure). (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 3)

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A double-suction pump is one whose impeller is designed to draw flow from both sides, as opposed to a single-suction pump whose impeller only draws flow from one side.

DOE considered expanding scope to the following pump categories: Chemical process and wastewater pumps, small vertical inline pumps, certain additional clean water pumps (between-bearing, vertical suction, radially-split, multi-stage horizontal, line shaft and cantilever pumps), and pumps sold with motors that operate at 1,200 rpm. The following sections provide additional information and responses to stakeholder comments specific to the pumps that DOE considered for inclusion in the test procedure scope.

DOE notes that it is proposing changes to the current test procedure applicable to currently regulated pumps. Any representations regarding the energy consumption of these pumps or the cost of energy consumed by these pumps would have to be made in accordance with the amended test procedure beginning 180 days after publication of the final rule. (42 U.S.C. 6314(d)) The proposed changes to the test procedure would also apply to those pumps that DOE is proposing to include in its scope; however, for these pumps, the revised test procedure would be required in conjunction with the compliance date of any future amended energy conservation standards that DOE may set.

1. Pumps Not Designed for Clean Water Applications

The scope of the current DOE test procedure, as described previously, excludes both chemical process and wastewater pumps.

See

10 CFR 431.464(a)(1)(i). Chemical process pumps are designed to pump fluids other than water, and wastewater pumps are designed for water with a higher level of free solids than clean water pumps.

In response to the April 2021 RFI, NEEA stated that there is functional overlap between pumps that are within the scope of the current DOE test procedure and those pumps that are excluded because they are certified under ASME/ANSI B73. (NEEA, No. 21 at p. 6) NEEA also stated that distributors report that a “significant portion” of ASME/ANSI B73 pumps are installed in clean water applications and that without this certification designation these pumps would be included in the scope for the DOE test procedure.

Id.

Summit stated that if DOE were to include ASME/ANSI B73 pumps within scope of the DOE test procedure, 80 percent of their pumps would be covered rather than the eight percent currently covered. (Summit, No. 16 at p. 4) ASAP and NRDC recommended that DOE consider how the DOE test procedure could facilitate greater market adoption of wastewater pumps with variable-speed drives, similar to what has been done for clean water pumps. (ASAP and NRDC, No. 18 at p. 2)

DOE also received comments pertaining to non-clean water pumps in the August 2021 ECS RFI. HI stated that the current definition of clean water pumps and the exclusion of non-clean water pumps from the test procedure scope aligns with regulations in both Canada and the EU. (HI, Docket EERE-2021-BT-STD-0018, No. 8 at p. 2) HI asserted that maintaining harmonization between the United States, Canada and the EU is important to minimize burden for manufacturers that distribute their pumps outside of the U.S.

Id.

HI stated that a large number of additional pump categories would need to be added to the DOE test procedure in order to appropriately characterize non-clean water pumps.

Id.

HI explained that there is not a clear distinction between a pump being designed for clean water or for wastewater or chemicals. Instead, HI explained that pump designs constitute a range of operation based on a liquid's chemical compatibility and containment requirements, in addition to the concentration, and hardness of the solids being pumped.

Id.

HI stated that it was not aware of any established definitions that characterize non-clean water pumps into unique groupings, and that any definitions would need to define each pump group and include distinct design features that affect their efficiency.

Id.

HI stated that DOE would need to establish many definitions and classes for non-clean water pumps to accurately develop standards.

Id.

HI also commented that the specificity necessary to group pumps with similar design options and loss characteristics would leave little data in each category to develop C-values, making it difficult to develop energy conservation standards.

Id.

Finally, HI stated that

ASME/American Petroleum Institute, solids handling, slurry, positive displacement, and magnet driven pumps could not be tested with the HI 40.6 standard. (HI, Docket EERE-2021-BT-STD-0018, No. 8 at p. 4)

Also in response to the August 2021 ECS RFI, Grundfos recommended against expanding the DOE scope beyond clean water pumps, asserting that uses for pumping other fluids are too varied. (Grundfos, Docket EERE-2021-BT-STD-0018, No. 9 at p. 2)

DOE acknowledges that certain non-clean water pumps may be used in clean water applications; however, DOE expects the number of non-clean water pumps used in the clean water applications to be relatively small. DOE notes that the scope of HI 40.6-2014, which is currently incorporated by reference into the DOE test procedure, includes clean water pumps only. The scope of the HI 40.6 standard changed in the 2016 version to state that the standard covers pumps that are included in DOE's energy conservation standards and therefore does not provide requirements for testing pumps designed for non-clean water applications. The scope of HI 40.6-2021 is identical to that of HI 40.6-2016. To test non-clean water pumps, DOE would need to reference or develop an alternate test procedure. While this test procedure might enable comparison between non-clean water pumps, it is unlikely that a clean water and non-clean water test procedure would provide comparable results.

Additionally, DOE notes that non-clean water pumps, specifically wastewater pumps, must meet specific performance requirements to ensure the health of the U.S. population. DOE would need to carefully evaluate how the performance of non-clean water pumps could be impacted by energy conservation standards and ensure that public health and safety would not be negatively affected. As such, additional investigation is needed to understand the market, energy savings potential, test procedure implications, and performance requirements of non-clean water pumps (

i.e.,

chemical process and wastewater). DOE notes that because “C-value” is specified in the energy conservation standard (

see

10 CFR 431.465(b)(4)) and C-value is required for determining PEI

CL

and PEI

VL

, there would be limited use of the test procedure without corresponding standards. Therefore, DOE has determined that it will continue to limit the applicability of this test procedure to clean water pumps at this time.

2. Small Vertical Inline Pumps

As discussed, the scope of the current DOE test procedure is limited to five categories of pumps designed for clean water applications. 10 CFR 431.464(a)(1)(i). One of these categories is in-line (IL) pumps, which are limited to shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter, and in which liquid is discharged in a plane perpendicular to the impeller shaft. 10 CFR 431.462. In 2016, a Circulator Pump Working Group

14

recommended a test procedure and energy conservation standard for circulator pumps, which DOE is addressing in a separate rulemaking, and also made recommendations for SVIL pumps. SVIL pumps have characteristics identical to those for in-line pumps but SVIL pumps have shaft input power of less than 1 hp. The Circulator Pump Working Group recommended that (1) SVIL pumps be evaluated using the PEI

CL

or PEI

VL

metric, and (2) SVIL pumps should be tested using the DOE pump test procedure, with any needed modifications determined by DOE. (Docket No. EERE-2016-BT-STD-0004, No. 58 Recommendation #1B at pp. 1-2)

14

On February 3, 2016, DOE published its intention to establish a working group under the Appliance Standards and Rulemaking Federal Advisory Committee (“ASRAC”) to negotiate a test procedure and energy conservation standards for circulator pumps. 81 FR 5658. Throughout this document this working group shall be referred to as “the Circulator Pumps working Group”.

In response to the April 2021 RFI, NEEA, Grundfos, ASAP and NRDC, the CA IOUs, and HI recommended that DOE address SVIL pumps in the commercial and industrial pumps test procedure and energy conservation standards rulemakings, rather than in a rulemaking for circulator pumps (NEEA, No. 21 at p.7; Grundfos, No. 17 at p. 3; ASAP and NRDC, No. 18 at p. 2; CA IOUs No. 19 at p. 11; HI, No. 20 at p. 3) NEEA stated that there is confusion in the market as to whether SVIL pumps are subject to the DOE test procedure and energy conservation standards, and that SVIL pumps may be in the same family as, or have overlapping pump curves with, larger pumps that are currently subject to the test procedure and standards. (NEEA, No. 21 at p. 6) NEEA also stated that there is a trend in the HVAC industry to move away from distributing large central pumps to distributing smaller pumps, and that therefore unregulated SVIL pumps compete with larger regulated pumps.

Id.

DOE also received comments relative to SVIL pumps in the August 2021 ECS RFI. The CA IOUs stated that in discussions with distributors, one recommended adding fractional SVIL pumps to the scope of regulated equipment. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 5) According to the CA IOUs, this distributor stated that the lack of coverage currently causes confusion since some pumps within a given product line are covered and some are not.

Id .

For example, 7 percent of Taco's SVIL pump sales are fractional horsepower (“hp”) and are therefore uncovered.

15

Id.

The CA IOUs also reported that SVIL pump use in hydronic HVAC systems is increasing and asserted that this means that SVIL pumps are competing with larger regulated pumps.

Id.

15

The use of the term SVIL here implies such pumps can be over 1 horsepower. The current DOE definition of in-line (“IL”) pumps, and the proposed definition of SVIL in section I.B.6 clarify that IL pumps under one horsepower are SVIL pumps. DOE assumes that the comment may have intended that 7 percent of IL pumps are SVIL pumps.

Finally, DOE received comments relative to SVIL pumps in the May 7, 2021 Circulator Pumps Test Procedure and Energy Conservation Standard RFI (“May 2021 Circulator Pumps RFI”). 86 FR 24516, 24521. The CA IOUs supported NEEA's comments on SVIL pumps from the April 2021 RFI. (CA IOUs, Docket EERE-2016-BT-STD-0004, No. 116 at p. 6) The CA IOUs supported the incorporation and development of SVIL pump standards based on the PEI metric.

Id.

In the April 2021 RFI, DOE also requested shipment and market performance data for SVIL pumps. 86 FR 20075, 20079. In response, Grundfos and HI recommended that DOE conduct manufacturer interviews to obtain specific market performance data. (Grundfos, No. 17 at p. 3; HI, No. 20 at p. 4)

Issue 1:

Consistent with the Circulator Pump Working Group recommendation and based on the concerns expressed in the comments summarized above regarding SVILs being a part of the same model family as IL pumps and serving as an unregulated alternative to pumps currently subject to DOE test procedures and energy conservation standards, DOE proposes to include SVIL pumps within the test procedure's scope. DOE has tentatively determined that SVIL pumps can be tested using the current DOE pumps test procedure with certain additional modifications. The proposed test procedure and metric for SVIL pumps are discussed in sections III.G

and III.D of this NOPR. Moreover, DOE expects that including SVIL pumps within the scope of the pumps test procedure would reduce confusion over which inline pumps are and are not regulated. DOE requests comment on its proposal to expand the scope of the test procedure to cover SVIL pumps.

3. Other Clean Water Pump Categories

In the April 2021 RFI, DOE requested comment on whether the five pump categories currently included in DOE's regulations sufficiently represent the market and technology available for clean water pumps; whether these categories are sufficiently defined in order to ensure that the categories are mutually exclusive; or whether any of these categories or descriptions should be amended. 86 FR 20075, 20078.

In response to DOE's request for comment in the April 2021 RFI, Grundfos and HI supported the current pump equipment categories, and Grundfos stated that these pump categories represent the current market. (Grundfos, No. 17 at p. 1; HI, No. 20 at p. 2) NEEA and ASAP and NRDC recommended that DOE expand the scope of the pumps test procedure to cover additional pumps used in clean water applications. (ASAP and NRDC, No. 18 at p. 1; NEEA, No. 21 at p. 2) NEEA identified four categories of pumps that it stated may have overlapping uses and therefore may compete with pumps that are currently within scope of DOE regulations; specifically: Single and two stage axially-split pumps, end-suction multi-stage pumps, vertical turbine pumps, and American Society of Mechanical Engineers (“ASME”)/ANSI B73 certified pumps,

16

(NEEA, No. 21 at p. 2) NEEA stated that having similar pumps that compete in the market but that do not use PEI as a performance metric is confusing for distributors and end users. (NEEA, No. 21 at p. 3) NEEA reiterated its points about pump scope expansion in its comments to the August 2021 ECS RFI. (NEEA, Docket EERE-2021-BT-STD-0018, No. 11 at p. 2)

16

Pumps certified under the ASME B73 designation include: B73.1 (“Specification for Horizontal End-suction Centrifugal Pumps for Chemical Process”), B73.2 (“Specification for Vertical In-Line Centrifugal Pumps for Chemical Process”), B73.3 (“Specification for Sealless Horizontal End-suction Centrifugal Pumps for Chemical Process”), and B73.5 (“Thermoplastic/thermoset Polymer Material Horizontal End-suction Centrifugal Pumps Chemical Process”). All B73 pumps are designed for use as chemical process pumps, which have specific design requirements related to reliability and performance such as maximum shaft deflections, bearing frame lubrication, sealing requirements, and vibration limits.

Similarly, ASAP and NRDC recommended adding double suction pumps, multi-stage end-suction pumps, vertical turbine pumps, and pumps tested at a nominal speed of 1,200 rpm. (ASAP and NRDC, No. 18 at p. 2) ASAP and NRDC stated that this would ensure consistent pump efficiency information is available for purchasers. (ASAP and NRDC, No. 18 at p. 1) ASAP and NRDC additionally commented that some unregulated pumps can be used in the same applications as some regulated pumps.

Id.

ASAP and NRDC contended that including additional pump categories in the test procedure scope would provide a more level playing field for manufacturers.

Id.

In response to the August 2021 ECS RFI, ASAP and NRDC reiterated the points they made in response to the April 2021 RFI. (ASAP and NRDC, Docket EERE-2021-BT-STD-0018, No. 7 at pp. 1-2)

In response to the August 2021 ECS RFI, the CA IOUs supported NEEA's recommendation to expand the scope of the pumps test procedure to the four categories listed above. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 2) Grundfos stated that DOE should limit its focus of scope expansion to radially-split multi-stage horizontal pumps; and that positive displacement, axial/mixed flow, double suction, multi-stage axially-split, multi-stage radial split vertical immersible, non-submersible vertical turbine, and VS4/VS5 pumps

17

should remain excluded from the DOE scope. (Grundfos, Docket EERE-2021-BT-STD-0018, No. 9 at pp. 1-2) HI commented that DOE should not expand the scope of its regulation to either non-clean water pumps or to clean water pumps that may serve diverse markets and applications and therefore may have multiple design variants within each pump type. (HI, Docket EERE-2021-BT-STD-0018, No. 8 at p. 1). Additionally, HI stated that significant changes to the scope would cause market confusion since current standards and labeling requirements for pumps went into effect only recently in early 2020.

Id.

17

VS4 and VS5 are pump categories defined in HI 14.1-14.2-2019 that both refer to vertically separate discharge pumps. VS4 pumps are line shaft pumps and VS5 pumps are cantilever pumps.

The following sections discuss DOE's consideration of additional categories of clean water pumps within the scope of the test procedure, including the specific categories suggested by commenters.

a. Between-Bearing Pumps

Section 1.2.9.2 of ANSI-HI 14.1-14.2-2019 describes between-bearing (“BB”) pumps as pumps that are one- or two-stage, axially-split, mounted to a baseplate, driven by a motor via a flexible coupling, and with bearings on both ends of the rotating assembly.

In the April 2021 RFI, DOE requested comment on whether pumps that meet the description of BB pumps might fall within the current test procedure scope and if BB pumps could be tested with the current DOE test procedure. 86 FR 20075, 20079. In response, ASAP and NRDC and NEEA recommended evaluating double suction pumps for inclusion in the test standards, and stated that most of these pumps are BB1 pumps,

18

many are used in chilled clean water applications, and these pumps are often below 200 hp. (ASAP and NRDC, No. 18 at p. 1; NEEA, No. 21 at p. 2) In addition, DOE understands that NEEA's recommendation that DOE cover single and two-stage axially-split pumps to also refer to BB1 pumps. The CA IOUs also seemed to offer support for NEEA's comments. (CA IOUs, No. 19 at pp. 10-11)

18

BB1 pumps are a pump class defined by HI 14.1-14.2-2019 that are 1 and 2 stage, axially-split pumps with the impeller(s) mounted between bearings at either end. BB1 pumps are a specific sub-category of BB pumps.

Summit and Grundfos recommended a new category of double suction pumps/between-bearing pumps if DOE decides to expand its scope beyond clean water pumps. (Summit, No. 16 at p. 2; Grundfos, No. 17 at p. 4) Additionally, Grundfos specifically stated that BB1 pumps have different inlet/outlet configurations and losses when compared to IL pumps that are currently within the scope of the DOE test procedure. (Grundfos, No. 17 at p. 4) Summit stated that although they supply BB pumps, none are used in clean water applications, and that testing these pumps would be burdensome. (Summit, No. 16 at p. 3) Grundfos and HI commented that some BB1 pumps are designed for clean water applications and may be rated under 200 hp. (Grundfos, No. 17 at p. 3-4; HI, No. 20 at p. 4) Grundfos agreed that BB1 pumps can be tested according to the current DOE test procedure. (Grundfos, No. 17 at p. 4) While HI also agreed that BB1 pumps can be tested according to the DOE test procedure, they stated that BB1 pumps do not share the same physical and functional characteristics affecting energy consumption of any pump category currently defined by DOE. (HI, No. 20 at p. 4)

DOE also received comments on the August 2021 ECS RFI relevant to BB pumps. The CA IOUs stated that in discussions with distributors, two distributors suggested that split case and double suction pumps should be included in the scope of the pumps rulemaking. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 3) It is DOE's understanding that the recommendations to include split case and double suction pumps refer to BB pumps, since these two characteristics synonymous with between-bearing pumps.

Based on a review of the market, BB pumps tend to generally be larger than the pumps currently subject to the DOE test procedure. Many BB pumps exceed the head and horsepower limits in the current DOE test procedure. Additionally, BB pumps are not typically designed for clean water applications. Despite these generalities, DOE has identified certain clean water BB pumps under 200 hp and 459 feet of head that could be viewed as potentially interchangeable with those pumps that fall within the scope of the current DOE test procedure.

In order to address the potential for pumps that provide unregulated alternatives to the pumps currently subject to the DOE test procedure, DOE proposes to include BB pumps within the scope of the DOE test procedure. However, DOE does not propose to expand beyond clean water pumps and does not propose to expand the head or horsepower limitations currently listed in 10 CFR 431.464(1)(ii). Additional investigation is needed to understand the market, energy savings potential, test procedure implications, and performance requirements of non-clean water pumps. DOE has determined that it will continue to limit the applicability of this test procedure to clean water pumps at this time. An expansion of the head and horsepower restrictions has the potential to increase test burden by requiring larger laboratory equipment to test pumps according to the DOE test procedure. Through its literature review DOE has found few BB pumps that exceed the head and horsepower limits and are designed for clean water, leading DOE to tentatively determine that the burden of expanding head and horsepower restrictions outweigh the benefits of expanded scope.

Based on stakeholder comments, literature reviews, and reviews of pump schematics, DOE has tentatively determined that BB pumps can be tested using the methodology in HI 40.6-2021; therefore, DOE is not proposing any modifications specific to testing BB pumps in this test procedure NOPR.

Specific proposals for a definition of BB pumps are detailed in section III.B.5 of this document.

Issue 2:

DOE requests comment on its proposal to expand the current test procedure's scope to include BB pumps. Additionally, DOE requests comment on the repeatability and representativeness of testing BB pumps using the current DOE test procedure. DOE also requests comment on any additional burdens associated with testing BB pumps that are different from those burdens associated with pumps currently covered by the DOE test procedure.

b. Vertical Turbine Pumps

Section 1.3.3.1.2 of HI 14.1-14.2-2019 defines VS1 and VS2 pumps as vertically suspended, wet pit pumps with a single casing and discharge through the suspension column. VS1 pumps use a diffuser, while VS2 use a volute.

19

VS1 and VS2 pumps are generally known as vertical turbine pumps. These pumps are generally not designed for clean water applications, and often exceed head and horsepower limits laid out in the current test procedure.

19

Both diffusers and volutes diffuse velocity energy into pressure as the flow exits a pump's impeller. A volute is a one or two scroll shaped diffusing passageway, while a diffuser is characterized by many radially-symmetric diffusing passageways.

In response to the April 2021 RFI, DOE received comments from ASAP and NRDC and NEEA recommending the inclusion of vertical turbine pumps in the scope of the current DOE test procedure. (ASAP and NRDC, No. 18 at pp. 1-2; NEEA, No. 21 at p. 2) NEEA stated that these pumps present a compliance loophole in DOE's pump regulations and create market confusion. (NEEA, No. 21 at pp. 2-3) The CA IOUs encouraged DOE to evaluate vertical turbine pumps for inclusion in the test procedure. (CA IOUs, No. 19 at p. 11)

Based on a review of literature, DOE has tentatively determined that ST pumps and vertical turbine pumps have similar end uses. Additionally, DOE has tentatively determined that ST and vertical turbine pumps have similar bowl and impeller assemblies, and that vertical turbine pumps may even share an identical assembly with an ST pump produced by the same manufacturer. To address the potential of pumps that provide unregulated alternatives to the pumps currently subject to the DOE test procedure, DOE proposes to include vertical turbine pumps within the scope of the DOE test procedure. However, as discussed previously, DOE does not propose to expand beyond clean water pumps and does not propose to expand the head or horsepower limitations currently listed in 10 CFR 431.464(1)(ii). An expansion of the head and horsepower restrictions has the potential to increase test burden by requiring larger laboratory equipment to test pumps according to the DOE test procedure. Through its literature review, DOE has found few vertical turbine pumps that exceed the head and horsepower limits and are designed for clean water. Therefore, DOE has tentatively determined that the burden of expanding head and horsepower restrictions outweigh the benefits of expanded scope.

Based on literature reviews and reviews of pump schematics, DOE has tentatively determined that vertical turbine pumps can be tested using the methodology in HI 40.6-2021; therefore, DOE is not proposing any modifications specific to testing vertical turbine pumps in this test procedure NOPR.

Specific proposals for a definition of VT pumps are detailed in section III.B.6 of this document.

Issue 3:

DOE requests comment on its proposal to expand the current test procedure's scope to include VT pumps. Additionally, DOE requests comment on the repeatability and representativeness of testing VT pumps using the current DOE test procedure. DOE also requests comment on any additional burdens associated with testing VT pumps that differ from those burdens associated with pumps currently covered by the DOE test procedure.

c. Radially-Split Multi-Stage Horizontal Pumps

The current scope of the DOE test procedure includes radially-split, multi-stage, vertical, in-line casing diffuser (RSV) pumps, but does not include radially-split horizontal pumps, which are also multistage pumps used primarily in heating, cooling, and pressure boosting applications. In response to the April 2021 RFI, NEEA and ASAP and NRDC recommended that multi-stage end-suction pumps (specifically OH1j, OH7j, and OH13j)

20

should be included in the scope of the pumps test procedure. (NEEA, No. 21 at p. 2; ASAP and NRDC, No. 18 at p. 1) The CA IOUs supported NEEA's comment and recommended that DOE evaluate multi-stage end-suction pumps

for inclusion in the pumps test procedure. (CA IOUs, No. 19 at p. 10-11) NEEA additionally stated that multi-stage end-suction pumps are often in direct competition with RSV pumps in pressure boosting applications. (NEEA, No. 21 at p. 3) NEEA also provided a list of applications for multi-stage end-suction pumps to demonstrate the similarities between these pumps and those that are included in the scope of the current test procedure. (NEEA, No. 21 at p. 4)

20

OH1J, OH7J, and OH13J are HI 14.1-14.2-2019 pump class definitions that refer to the multi-stage versions of OH1, OH7, and OH13 end-suction pumps. OH pumps are generally classified as overhung meaning the impeller shaft is only supported by bearings on one side of the impeller. OH1 pumps are horizontal, flexibly coupled, and have a centerline mount. OH7 pumps are horizontal and close coupled. OH13 pumps are horizontal and rigidly/short coupled.

DOE also received comments in response to the August 2021 ECS RFI relevant to multi-stage end-suction pumps. The CA IOUs stated that many distributors sell water booster pumps, which are often multi-stage end-suction pumps. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 3) Grundfos recommended that DOE focus its scope expansions on radially-split multi-stage horizontal pumps. (Grundfos, Docket EERE-2021-BT-STD-0018, No. 9 at p. 2) Grundfos also suggested that, like RSV pumps, RSH pumps should be limited to in-line flow, and that DOE should consider new categories for multi-stage products that do not have in-line connections.

Id.

DOE has surveyed materials and product literature available online and has tentatively determined that the multi-stage end-suction pumps discussed by NEEA, ASAP and NRDC, and the CA IOUs would be classified as radially-split, multi-stage, horizontal, (“RSH”) end-suction pumps. DOE's literature survey also tentatively concluded that RSV and RSH pumps were marketed for similar applications, and that RSH could therefore serve as an unregulated loophole to RSV pumps. In addition, through reviews of product literature and HI 14.1-14.2-2019 pump schematics, DOE has tentatively determined that RSH pumps can be tested using the current DOE test procedure. Based on DOE's research, DOE proposes to include RSH pumps with both in-line and end-suction flow configurations in its test procedure scope. Specific proposals for definitions or RSH pump categories are detailed in section III.B.7 of this document.

Issue 4:

DOE requests comment on its proposal to expand scope to include RSH pumps. Additionally, DOE requests comment on the repeatability and representativeness of testing RSH pumps using the current DOE test procedure. DOE also requests comment on any additional burdens associated with testing RSH pumps which are different from those burdens associated with pumps currently covered by the DOE test procedure.

d. End-suction Pumps Similar to ESFM and ESCC Pumps

DOE defines a “close-coupled pump” as a pump having a motor shaft that also acts as the impeller shaft, and defines a “mechanically-coupled pump” as a pump that has its own impeller shaft and bearings separate from the motor shaft. 10 CFR 431.462. As discussed in the April 2021 RFI, DOE is aware that certain pumps may have their own shaft, but with no bearings to support that shaft. 86 FR 20075, 20078. Additionally, while the close-coupled pump definition describes a pump in which the motor shaft also serves as the pump shaft, the definition does not provide detail on how the motor and pump shaft may be connected. DOE has observed that some manufacturers describe close-coupled pumps as using an adapter to mount the impeller directly to the motor shaft. The coupling type is the only differentiator between ESCC pumps, which are “close-coupled pumps,” and ESFM pumps, which are “mechanically-coupled pumps.” In the January 2016 Final Rule, DOE noted that it intended for ESFM and ESCC pumps to be mutually exclusive in order to ensure that pumps that are close-coupled to the motor and have a single impeller and motor shaft would be part of the ESCC equipment category, while all other end-suction pumps that are mechanically-coupled to the motor and for which the bare pump and motor have separate shafts would be part of the ESFM equipment category. 81 FR 4086, 4096. Despite this intention DOE is aware that these definitions may have left some end-suction pumps out of scope.

In the April 2021 RFI, DOE requested comment on whether there are pumps being sold in commerce that may not meet the “close-coupled” or “mechanically-coupled” definitions but would otherwise meet the definition for an “end-suction” pump. 86 FR 20075, 20078.

HI stated that there are currently pumps that have impellers not directly connected to the motor shaft, with all pump loads supported by the motor bearings, which do not meet either the definition of close-coupled or mechanically-coupled pumps. (HI, No. 20 at p. 3)

Based on HI's response and DOE's review of ESCC and ESFM pumps, DOE has tentatively determined that there is a group of end-suction pumps that do not currently fall into either the ESFM or ESCC definition, but which may be competitors to the currently regulated pumps. Therefore, DOE proposes to include all end-suction pumps within the coverage of this test procedure by modifying the definitions of ESFM and ESCC pumps. The details of this proposal are outlined in section III.B.8 of this document. DOE has tentatively determined that no test procedure revisions would be needed to accommodate these additional end-suction pumps.

Issue 5:

DOE requests comment on its tentative determination that there are certain ends suction pumps excluded from the current test procedure due to the ESFM and ESCC definitions. DOE also requests comment on the number of pump models that may fall into this category and whether they are currently being tested according to the DOE test procedure.

e. Line Shaft and Cantilever Pumps

ANSI/HI 14.1-14.2-2019 includes design criteria for different pump configurations, and section 14.1.3.3.1.3 describes vertically separate discharge sump pumps, a category of pump that includes line shaft (“VS4”) pumps and cantilever (“VS5”) pumps. Both VS4 and VS5 pumps are vertically-suspended pumps with a single casing and with a discharge column that is separate from the shaft column. The pump equipment categories defined by DOE do not explicitly reference VS4 or VS5 pumps, and some pumps may be covered by both the DOE definition of an ESFM pump and the HI definition of a VS4 or VS5 pump. 86 FR 20075, 20079.

In the April 2021 RFI, DOE requested comment on whether the test procedure should be amended to explicitly address line shaft and cantilever pumps as described in the ANSI/HI 14.1-14.2-2019. 86 FR 20075, 20079. In response, Grundfos stated that line shaft pumps and cantilever pumps have designs similar to ESFM and ESCC pumps and that some are sold for clean water applications. (Grundfos, No. 17 at p. 3) Grundfos also commented that if DOE were to include line shaft and cantilever pumps within its scope, DOE should create a new equipment class since these pumps have different losses, and DOE would need to define a standard sump depth for testing since these products have a wide variance in sump depth.

Id.

HI stated that VS4 and VS5 are not clean water pumps and therefore there is no need to address their potential test procedures. (HI, No. 20 at p. 4)

Consistent with the comments from HI, DOE's literature survey indicates all cantilever pumps are primarily designed for non-clean water applications including liquids and slurries containing large solids. Therefore, DOE

has tentatively determined that it will not expand the scope of its test procedure to include line shaft or cantilever pumps at this time. This proposed approach is consistent with DOE's tentative decision not to expand the current test procedure's scope to pumps designed for non-clean water applications. DOE agrees that a standard sump depth must be defined for testing of these products but a representative sump depth could be determined for the purpose of this test procedure. DOE has not, however, assessed what a representative depth would be as it is not proposing a test procedure for line shaft and cantilever pumps.

4. Scope Limitations

Within the categories of clean water pumps included in the current DOE test procedure and proposed for inclusion in this notice, DOE also considered potential expansion to scope limitations related to bowl diameter, nominal speed, horsepower, and design temperature range.

a. Submersible Turbine Pumps With Bowl Diameter Greater Than 6 Inches

As discussed previously, the scope of the current DOE test procedure includes submersible turbine pumps with a bowl diameter of 6 inches or smaller. 10 CFR 431.464(a)(1)(i)(E) and (a)(1)(ii)(E). In response to the September 2020 Early Assessment RFI, NEEA listed submersible turbine (ST) pumps with a bowl diameter greater than 6 inches as an example of pumps that DOE should consider including as part of an expanded scope. (NEEA, No. 7 at p. 8) NEEA's reasoning was that pumps within a regulated family may not be rated because they have a bowl diameter greater than 6 inches.

21

(NEEA, No. 7 at p. 8) In the April 2021 RFI, DOE requested shipment data for submersible turbine pumps with a bowl diameter greater than 6 inches. 86 FR 20075, 20079. DOE received no shipment information on submersible turbine pumps with bowl diameters greater than 6 inches.

21

ST pumps with a bowl diameter greater than 6 inches are currently excluded from the scope of the DOE test procedure.

However, in response to the April 2021 RFI, HI stated that submersible turbine pumps with a flow rate less than 25 gpm at BEP are used in residential well applications and should remain out of scope since they have limited operating time. (HI, No. 20 at p. 3) DOE is not considering expanding scope to pumps with a flow rate less than 25 gpm at this time, due to the limitations leading to the current scope provision. However, DOE understands that flow rate typically increases with bowl diameter, so it is DOE's understanding that HI's comment is unrelated to a potential scope expansion to pumps with a bowl diameter greater than 6 inches.

As discussed in section III.A.3.b, DOE is proposing to include vertical turbine pumps within the scope of the DOE test procedure. These pumps are similar in design to ST pumps and commenters have indicated that the two pump categories can be used in overlapping applications. Stakeholder comments about the addition of vertical turbine pumps did not indicate a suggested bowl diameter limitation. As such DOE is not proposing one. To maintain consistency across pump categories, and in response to NEEA's early assessment RFI comments, DOE is proposing to remove the 6-inch bowl diameter limitations for ST pumps.

Issue 6:

DOE requests comment on its proposal to remove the 6-inch maximum bowl diameter restriction from ST pumps, including whether there are any testing limitations for larger bowl diameters.

b. Pumps Designed To Be Operated at 1,200 RPM

As discussed, DOE limits the scope of pumps under the current test procedure to those designed to operate with a 2- or 4-pole induction motor, or a non-induction motor with an operating range that includes speeds of rotation between 2,880 and 4,320 rpm and/or 1,440 and 2,160 rpm. 10 CFR 431.464(a)(1)(ii). In either case, the driver and impeller must rotate at the same speed. 10 CFR 431.464(a)(1)(ii)(D). The current DOE test procedure does not include pumps designed to operate with 6-pole induction motors or with non-induction motors that have a speed of rotation operating range exclusively outside the ranges defined.

In response to the April 2021 RFI, ASAP and NRDC recommended evaluating pumps sold with 6-pole, 1,200 rpm motors and pumps designed to be operated at 1,200 rpm. (ASAP and NRDC, No. 18 at pp. 1-2) Summit stated that if DOE were to expand the nominal motor speeds included in its test procedure, 1,200 rpm would be the best nominal speed to add. (Summit, No. 16 at p. 5)

In addition, DOE received comments in response to the August 2021 ECS RFI pertaining to this topic. The CA IOUs stated that it contacted several distributors, two of whom recommended adding pumps designed to operate at 1,200 rpm. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 3) The CA IOUs added that one of these distributors stated that 1,200 rpm pumps have a longer life than higher rpm pumps, while the other stated that not including them within the test procedure's scope is confusing to customers.

Id.

Based on a review of pump performance curves available online, DOE has tentatively determined that unregulated pumps tested with a nominal speed of 1,200 rpm are part of the same pump families as those pumps that currently fall within the scope of the DOE test procedure.

22

To ensure equitable treatment among these pumps, DOE is proposing to extend the scope of this test procedure to cover pumps designed to operate with 6-pole induction motors, and pumps designed to operate with non-induction motors with an operating range that includes speeds of rotation between 960 rpm and 1,440 rpm.

23

DOE proposes test provisions to accommodate these pumps in sections III.E.1 and III.H of this document.

22

See

https://www.regulations.gov/document/EERE-2020-BT-TP-0032-0024.

(Docket No. EERE-2020-BT-TP-0032-0024.)

23

960 and 1440 rpm are ± 20 percent of 1,200 rpm. The acceptable non-induction motor ranges for 1800 and 3600 rpm pumps are also ± 20 percent of the nominal value.

Issue 7:

DOE requests comment on its proposal to expand the scope of the test procedure to include pumps designed to operate with a 6-pole induction motor, and pumps designed to operate with non-induction motors with an operating range that includes speeds of rotation between 960 rpm and 1,440.

c. Pump Horsepower and Design Speed

As discussed, the current DOE test procedure's scope is limited to covered pump categories with a 2- or 4-pole induction motor; or a non-induction motor with an operating range that includes speeds of rotation between 2,880 and 4,320 rpm and/or between 1,440 and 2,160 rpm, and for which the driver and impeller rotate at the same speed. 10 CFR 431.464(a)(1)(ii)(D). In addition, DOE's definitions for the five pump categories are limited to pumps with shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter. 10 CFR 431.462.

DOE received comments on the August 2021 ECS RFI from the CA IOUs, who stated that in discussions with distributors one stated that some pumps sold with electronically commutated motors (“ECMs”) and intended to run at higher speeds, such as 4,320 rpm, must be normalized to rate at 3,600 rpm and this adjustment causes the power of the

motor to fall below 1 hp. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 4) The CA IOUs asserted that this limits purchasers from comparing PEI

VL

values across product lines.

Id.

The CA IOUs argued that this exclusion of ECM pump products from the DOE test procedure is caused by adjusting operation to the BEP operating point and does not consider the real-world use of this product, which is expected to provide similar head and flow as many IL pumps that are within the scope of the current DOE test procedure. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 7) The CA IOUs commented that ECM pumps would be considered a highly efficient pump, and the aforementioned test issue limits consumer comparison of these pumps with non-ECM pumps, which in turn creates a market distortion that will slow the adoption of more efficient technologies and makes it difficult for PEI pump rebate programs to include this product subset.

Id.

The CA IOUs recommended that DOE revise the inclusion and exclusion criteria for these products to be based on the driver horsepower of the full operating window of the unit.

Id.

The CA IOUs also stated that this issue might be addressed if SVIL pumps are included in the pumps test procedure. (CA IOUs, Docket EERE-2021-BT-STD-0018, No. 10 at p. 6)

As stated previously, the definitions of the pump categories within the scope of the test procedure reference horsepower limitations based on shaft input power at BEP and full impeller diameter. 10 CFR 431.462. DOE defines “BEP” as the pump hydraulic power operating point (consisting of both flow and head conditions) that results in maximum efficiency and defines “full impeller diameter” as the maximum impeller diameter with which a given pump basic model is distributed in commerce. 10 CFR 431.462. DOE's test procedure for pumps at appendix A to subpart Y of part 431 also includes test provisions for determining both BEP and pump input power (also known as shaft input power), as well as provisions for normalizing all measured data to the specified nominal speed of rotation. As such, while the definitions themselves do not specify that shaft input power is determined at nominal speed, DOE understands the CA IOUs concern that the pump definitions could be read to exclude pumps with shaft input power greater than or equal to 1 HP at BEP at their design speed, but less than 1 HP when tested and corrected to nominal speed. In addition, DOE understands that the value of maximum efficiency varies little with speed, and is often assumed to be constant, and as such the definition of BEP alone would not be sufficient to assume that it must be determined at a certain speed different from that in the test procedure. For these reasons, DOE believes there could be value in clarifying the current scope limitations regarding horsepower that are embedded in the pump category definitions.

However, DOE also notes that, as previously discussed, it is proposing to expand the current test procedure's scope to include SVIL pumps, which the CA IOUs noted might address this issue. Specifically, the proposed inclusion of SVIL pumps would be for fractional horsepower pumps, so even when corrected to nominal speed, the pumps in question would be included in scope. DOE understands that use of high frequency (circa 4,000 rpm) ECMs is likely more prevalent on SVILs than on other pumps in this horsepower range, particularly as a result of their applications and competition with the circulator market. This means that including SVILs in this proposed test procedure would include most, if not all, pumps where motor power decreases below 1 hp when rated at BEP. For these reasons, DOE is not proposing to change the specified horsepower limitations within the pump category definitions at this time.

Issue 8:

DOE requests comment on its tentative determination that incorporating SVILs into the test procedure will largely eliminate the issue of higher speed 1 hp pumps falling out of scope when they rate at a nominal speed of 3600 rpm.

d. Horsepower and Number of Stages for Testing

In response to the April 2021 RFI, Grundfos urged DOE to clarify how to handle certification of equipment where some equipment is regulated while others are not and provided the example of an RSV basic model sold with a 1 horsepower (“hp”) motor tested at 3 stages. Grundfos continued that if a similar pump is 2-stage and uses a 0.75 hp motor, it's partially out of scope. Grundfos recommended that equipment that straddles the scope of the test procedure should be considered to be out of scope. (Grundfos, No. 17 at p. 10-11)

DOE understands that the same model of RSV pump may be sold with two stages, three stages, or some other number of stages. DOE's RSV pump definition includes those pumps that have a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter and at the number of stages required for testing. 10 CFR 431.462. DOE's testing provisions for RSV in section C.2 of appendix A to subpart Y of part 431 specify that the number of stages required for testing is three—or, if the basic model is only available with fewer than three stages, to test the basic model with the maximum number of stages with which it is distributed in commerce in the United States. Therefore, the RSV pump model sold with 2 or 3 stages would be included in the scope of the test procedure (and standards) if it has a shaft input power greater than or equal to 1 hp when tested at 3 stages, and the resulting PEI would apply to all stages with which the pump model is sold. For this reason, DOE is not making any changes to the scope of the test procedure.

e. Design Temperature Range

The current scope for the pumps test procedure is limited to pumps with a design temperature range between and including 14 to 248 °F. This range was derived from the original negotiation term sheet for pumps, which recommended limiting the scope to pumps with a design range from -10 °C to 120 °C. (Docket EERE-2013-BT-NOC-0039-0092). For the purposes of its regulations, DOE translated this range to Fahrenheit. DOE has received inquires as to whether a pump marketed for temperatures up to 250 °F is outside of the current test procedure's scope. DOE has reviewed marketing materials for a number of pumps and found that common upper limits of temperature are 212, 225, 248, 250, and 300 °F. Some marketing materials state that standard seals may have one high temperature limit while optional seals provide a higher limit (typically 250 or 300 °F). DOE understands the original intent of the scope limitation was to exclude pumps designed exclusively for low or high temperatures from the test procedure. However, if a manufacturer is offering a pump model across all temperature ranges in order to minimize SKUs, rather than offering separate low temperature and high temperature models, DOE considers that such a pump model should be subject to the regulations. Only pumps designed and marketed for temperatures exclusively outside the range of DOE's scope would be excluded from the test procedure and energy conservation standards. DOE has also recognized that rounding to a temperature limit of 250 °F when translating from °C to °F would be preferable to using the exact value of 248 °F since manufacturers commonly use rounded temperature values in their marketing materials. Similarly, DOE

proposes rounding the lower temperature limit from 14 °F to 15 °F.

To clarify the scope of the pumps test procedure and to improve the enforceability of the regulation, DOE is proposing to change the wording and the values, such that the scope would include pumps with a design temperature inclusive of any part of the range from 15 to 250 °F.

Issue 9:

DOE seeks comment on its proposal to clarify the scope of the pumps test procedure with respect to design temperature. Specifically, DOE requests comment on whether 15 °F and 250 °F are more appropriate than 14 °F and 248 °F, or whether other minor adjustments could be made to the range to assist with clarity and enforceability.

B. Definitions

1. Removing Certain References to Volute

Pumps generally have one of two common discharge types, either a volute or a diffuser. A volute is made up of one or two scroll-shaped channels, whereas a diffuser has 3 or more passages that diffuse the liquid that is being pumped. The current definitions for end-suction and in-line pumps use the term “volute,” when in practice either volutes or diffusers may be used for these categories of pumps. For example, DOE's current definition for end-suction pump includes the following: “The liquid is discharged through a volute in a plane perpendicular to the shaft,” while the definition for ESCC pump, which is an end suction pump, specifically references OH7 pumps. 10 CFR 431.462. However, Table 14.1.3.7 of HI 14.1-14.2-2019 specifies a diffuser as the standard casing for OH7 pumps. Similarly, DOE's current definition for IL pump includes the following: “in which liquid is discharged through a volute in a plane perpendicular to the shaft,” and specifically references OH4 and OH5 pumps as examples of end-suction pumps.

Id.

In contrast, Table 14.1.3.7 of HI 14.1-14.2-2019 specifies a diffuser as the standard casing for OH4 and OH5 pumps. DOE notes that HI 1.1-1.2-2014 did not make these casing distinctions.

DOE interprets the term “volute” in its definitions for “end-suction pump” and “in-line pump” to mean the part of the pump casing through which liquid is discharged generally, rather than to reference a specific type of discharge. To avoid this unintentional inconsistency between DOE's terminology and the terminology used by the updated industry standard, DOE proposes to amend the definitions of in-line pump and end-suction pump to remove the distinction that liquid is discharged “

through a volute

in a plane perpendicular to the shaft” [emphasis added] by specifying instead that liquid is discharged “in a plane perpendicular to the shaft.”

Issue 10:

DOE requests comment on the proposed changes to the definitions for “in-line pump” and “end-suction pump” to remove the distinction that liquid is discharged “through a volute”.

2. HI Pump Class References

The current DOE definitions for ESCC pump, ESFM pump, IL pump, RSV pump, and ST pump all include references to ANSI/HI 2.1-2.2-2014 pump configurations as examples of pumps that would meet the given definition. DOE has tentatively determined that it will be beneficial if the definitions are self-contained, and that these examples may have been causing confusion as to which pumps the definitions applied to. Therefore, DOE proposes to remove references to specific pump configurations as defined in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 in the definitions for ESCC, ESFM, IL, RSV, and ST pumps.

Issue 11:

DOE requests comment on the proposed changes to the definitions for ESCC, ESFM, IL, RSV, and ST pumps to remove references to ANSI/HI 1.1-1.2-2014 pump classes. Specifically, DOE requests comment on the ability of the modified definitions to clearly communicate the intended pump categories to industry stake holders.

3. Bowl Diameter

The current DOE definition for “bowl diameter” references the definition of “intermediate bowl” in ANSI/HI 2.1-2.2-2014. This is the sole remaining reference to ANSI/HI 2.1-2.2-2014 in the test procedure if the proposed changes to eliminate the HI pump class references are adopted. DOE has tentatively determined it would be more helpful for readers if the bowl diameter definition was self-contained, particularly since HI 2.1-2.2-2014 would not be referenced elsewhere. To disassociate the definition of “bowl diameter” from ANSI/HI 2.1-2.2-2014, DOE is proposing to define “bowl diameter” as referring to “the maximum dimension of an imaginary straight line passing through, and in the plane of, the circular shape of the intermediate bowl of the bare pump that is perpendicular to the pump shaft and that intersects the outermost circular shape of the intermediate bowl of the bare pump at both of its ends.” With respect to “intermediate bowl,” DOE proposes to define this term as “the enclosure within which the impeller rotates and which serves as a guide for the flow from one impeller to the next.”

The proposed definitions would be added to 10 CFR 431.462.

Issue 12:

DOE requests comment on the proposed change to the definition of bowl diameter to include a more specific definition of intermediate bowl instead of referring to the term as defined in ANSI/HI 1.1-1.2-2014.

4. Small Vertical Inline Pumps

As discussed in section III.A.2, DOE is proposing to expand the scope of the test procedure to include SVIL pumps, which are identical to IL pumps except for having a shaft input power less 1 hp. The Circulator Pump Working Group recommended the following definition for SVIL pumps:

“Small vertical in-line pump means a single stage, single-axis flow, dry rotor, rotodynamic pump that: (1) Has a shaft input power less than 1 hp at best efficiency point at full impeller diameter, (2) is distributed in commerce with a motor that does not have to be in a horizontal position to function as designed, and (3) discharges the pumped liquid through a volute in a plane perpendicular to the shaft.”

(Docket No. EERE-2016-BT-STD-0004, No. 58 Recommendations #3C at p. 3)

In the May 2021 Circulator Pumps RFI, DOE requested comment on the suitability of the above definition. 86 FR 24516, 24522. In response, HI and NEEA supported the circulator pumps working group definition of SVILs. (HI, Docket EERE-2016-BT-STD-0004, No. 112 at p. 4; NEEA, Docket EERE-2016-BT-STD-0004, No. 115 at p. 4)

The recommended definition would distinguish SVIL pumps from DOE's current IL pump definition

24

in that SVIL pumps have a reduced shaft power input range (IL pump is constrained to greater than or equal to 1 hp and less than or equal to 200 hp; SVIL must be less than 1 hp) and a different maximum pump power output limitation (IL pump has a limit of 5 hp at BEP; SVIL pumps have no hp limitation). The change to

shaft input power is the primary distinction between IL and SVIL pumps. DOE has tentatively determined this distinction is necessary to adequately separate the two categories. The pump power output is a consequence of the shaft power limitations. DOE has tentatively determined that SVIL pumps do not require a 5 hp pump power output limitation as their shaft input power is already capped below 1 hp.

24

An “in-line (IL) pump” means a pump that is either a twin-head pump or a single-stage, single-axis flow, dry rotor, rotodynamic pump that has a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter, in which liquid is discharged through a volute in a plane perpendicular to the shaft. Such pumps do not include pumps that are mechanically-coupled or close-coupled, have a pump power output that is less than or equal to 5 hp at BEP at full impeller diameter, and are distributed in commerce with a horizontal motor. Examples of in-line pumps include, but are not limited to, pumps within the specified horsepower range that comply with ANSI/HI nomenclature OH3, OH4, or OH5, as described in ANSI/HI 1.1-1.2-2014. 10 CFR 431.462.

Another difference is that the IL definition includes a group of three parameters to exclude circulator pumps—namely that they are either mechanically-coupled or close-coupled, have a pump power output that is less than or equal to 5 hp at BEP at full impeller diameter, and are distributed in commerce with a horizontal motor. In contrast, the recommended SVIL definition is meant to exclude circulator pumps through clause (2)—

i.e.,

“related to distribution in commerce with a motor that does not have to be in a horizontal position to function as designed.” On December 20, 2021, DOE published a notice of proposed rulemaking to establish a test procedure for circulator pumps (“Circulator Pumps TP NOPR”). 86 FR 72096. In the NOPR, DOE proposed to define a circulator pump as consisting of a wet rotor circulator pump; dry rotor, two-piece circulator pump; or dry rotor, three-piece circulator pumps. The NOPR also included proposed definitions for these subcategories of circulator pumps.

Id.

at 86 FR 72139. For clarity, DOE proposes that for the SVIL definition, rather than including the recommendation in clause (2), to instead exclude circulator pumps. Should a test procedure not be finalized for circulator pumps, DOE could instead finalize an SVIL definition using clause (2). For consistency, DOE also proposes to revise the IL pump definition to explicitly include circulator pumps instead of including the clauses meant to implicitly exclude them. Should a test procedure not be finalized for circulator pumps, DOE would retain the existing relevant clauses of the IL definition.

DOE notes that clause (3) of the recommended SVIL definition (“discharges the pumped liquid through a volute in a plane perpendicular to the shaft”) refers to a volute. For the reasons discussed in section III.B.1 of this document, DOE proposes excluding this reference from the proposed SVIL definition.

The recommended SVIL pump definition, through clause (2), also requires that these pumps be distributed into commerce with a motor, meaning SVIL pumps cannot be sold as a bare pump. Based on a literature search, DOE has tentatively determined that all SVIL pumps are sold with a motor. However, by proposing to replace clause (2) with an exclusion for circulator pumps, this requirement would be eliminated.

Although not addressed in the recommendation from the Working Group, the defined term “twin-head pump” (10 CFR 431.462) would be applicable to SVIL pumps. Specifically, in the January 2016 Final Rule, DOE adopted a test procedure for “twin-head pumps”, where a twin-head pump is defined as a: “dry rotor, single-axis flow, rotodynamic pump that contains two impeller assemblies, which both share a common casing, inlet, and discharge, and each of which (1) Contains an impeller, impeller shaft (or motor shaft in the case of close-coupled pumps), shaft seal or packing, driver (if present), and mechanical equipment (if present); (2) Has a shaft input power that is greater than or equal to 1 hp and less than or equal to 200 hp at best efficiency point (BEP) and full impeller diameter; (3) Has the same primary energy source (if sold with a driver) and the same electrical, physical, and functional characteristics that affect energy consumption or energy efficiency; (4) Is mounted in its own volute; and (5) Discharges liquid through its volute and the common discharge in a plane perpendicular to the impeller shaft.” 81 FR 4086, 4095-4096 and 4115-4116 (Jan. 25, 2016).

Since SVIL pumps are similar to IL pumps but operate at a smaller horsepower, and also are available in twin-head configurations DOE proposes to define a new term—“small vertical twin-head pump”—and to extend the twin-head pump test procedure adopted in the January 2016 Final Rule to small vertical twin-head pumps. Accordingly, the proposed definition would read as: “small vertical twin-head pump” as a dry rotor, single-axis flow, rotodynamic pump that contains two equivalent impeller assemblies, each of which:

(1) Contains an impeller, impeller shaft (or motor shaft in the case of close-coupled pumps), shaft seal or packing, driver (if present), and mechanical equipment (if present); and

(2) Has a shaft input power that is less than or equal to 1 hp at BEP and full impeller diameter; and

(3) Has the same primary energy source (if sold with a driver) and the same electrical, physical, and functional characteristics that affect energy consumption or energy efficiency; and

(4) Is mounted in its own volute; and

(5) Discharges liquid through its volute and the common discharge in a plane perpendicular to the impeller shaft.

To summarize, DOE is proposing to define SVIL pumps based on the recommended definition from the Circulator Pump Working Group with modifications to include SVILs that are small vertical twin-head pumps; to exclude pumps that are circulator pumps; and to remove the current reference to a volute. Specifically, DOE is proposing to define a “small vertical in-line pump” as a small vertical twin-head pump or a single stage, single-axis flow, dry rotor, rotodynamic pump that: (1) Has a shaft input power less than 1 hp at best efficiency point at full impeller diameter, (2) in which liquid is discharged in a plane perpendicular to the shaft; and (3) is not a circulator pump.

Issue 13:

DOE also proposes to revise the IL definition to explicitly exclude circulator pumps. DOE requests comment on its proposed definitions for “small vertical in-line pumps” and “small vertical twin-head pump.”

Issue 14:

DOE requests comment on the percentage of SVIL pumps, if any, that are not sold with a motor, and whether the definition of SVIL pump should be limited to those sold with a motor.

Issue 15:

DOE requests comment on its proposed revision to the IL pump definition to explicitly exclude circulator pumps.

5. Between-Bearing Pumps

As discussed in section III.A.3.a, DOE is proposing to add between-bearing pumps to the scope of this test procedure and is therefore proposing a definition for this pump category.

ANSI/HI 14.1-14.2-2019 defines between-bearing pump as a rotodynamic pump with the impeller(s) mounted on a shaft between-bearings on either end. In addition, all between-bearing pumps described in ANSI/HI 14.1-14-2-2019 are mechanically-coupled and dry rotor. Through a literature review, DOE has tentatively determined that the between-bearing pumps that are most similar to the pumps currently regulated by DOE have axially-split casings and 1 or 2 stages. Accordingly, using ANSI/HI 14.1-14.2-2019 as the basis for its approach, DOE is proposing to use the defined terms “dry rotor pump”, rotodynamic pump”, and “mechanically-coupled pump” to define a between-bearing pump,—

i.e.,

“an axially-split, mechanically-coupled, one- or two-stage, dry rotor, rotodynamic pump with bearings on both ends of the rotating assembly that has a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller

diameter and at the number of stages required for testing.”

Issue 16:

DOE requests comment on its proposed definition for between-bearing pumps, specifically if it is sufficient to identify the intended scope.

In addition to proposing a definition for between-bearing pump, DOE is also proposing to define the associated term “axially-split pump.” The term “axially-split” refers to a design of pump casing that can be separated, for maintenance and assembly, in a plane parallel to the impeller shaft. DOE proposes to define an “axially-split pump” based on ANSI/HI 14.1-14.2-2019 as “a pump with a casing that can be separated or split in a plane that is parallel to and which contains the axis of the impeller shaft.”

Issue 17:

DOE request comment on the proposed definition for axially-split pump.

6. Vertical Turbine Pump

As discussed in section III.A.3.b, DOE is proposing to add vertical turbine pumps to the scope of its test procedure and is therefore proposing a definition for this pump category. ANSI/HI 14.2-14.2 -2019 defines vertical turbine pumps as “single-casing, non-submersible, pumps with impellers mounted in a vertically suspended shaft, that discharge liquid through the column.” Based on this definition and existing DOE defined terms and proposed defined terms, DOE is proposing to define the term “vertical turbine pump” as a vertically-suspended, single-stage or multi-stage, dry rotor, rotodynamic pump:

(1) That has a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter and at the number of stages required for testing;

(2) For which no external part of such a pump is designed to be submerged in the pumped liquid;

(3) That has a single pressure containing boundary (

i.e.,

is single casing), which may consist of but is not limited to bowls, columns, and discharge heads; and

(4) That discharges liquid through the same casing in which the impeller shaft is contained.

Issue 18:

DOE requests comment on the proposed definition for vertical turbine pump.

7. Radially-Split, Multi-Stage Horizontal Pumps

DOE currently defines a RSV pump as a vertically-suspended, multi-stage, single axis flow, dry rotor, rotodynamic pump:

(1) That has a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter and at the number of stages required for testing; and

(2) In which liquid is discharged in a place perpendicular to the impeller shaft; and

(3) For which each stage (or bowl) consists of an impeller and diffuser;

(4) For which no external part of such a pump is designed to be submerged in the pumped liquid; and

(5) Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature VS8, as described in ANSI/HI 2.1-2.2-2014.

As discussed in section III.A.3.c, DOE is proposing to include within the scope of the DOE test procedure RSH pumps with both end-suction and in-line flow configurations. RSH pumps are nearly identical to RSV pumps except for the mounting orientation and flow configurations. In their comments to the August 2021 ECS RFI, Grundfos recommended that DOE consider new categories for products similar to RSV and RSH with connections that are not in line. (Grundfos, Docket EERE-2021-BT-STD-0018, No. 9 at p. 2) As discussed in section III.A.3.c, RSH pumps may have different flow configurations that are expected to impact pump efficiency; therefore, DOE is proposing three definitions for RSH pumps based on the existing DOE definition for pumps: One for an overarching category of RSH pumps, which does not characterize flow; one for in-line RHS pumps; and one for end-suction RSH pumps. The three definitions would be modified to read as follows:

Radially-split, multi-stage, horizontal, diffuser casing (RSH) pump means a horizontal, multi-stage, dry rotor, rotodynamic pump:

(1) That has a shaft input power greater than or equal to 1 hp and less than or equal to 200 hp at BEP and full impeller diameter and at the number of stages required for testing; and

(2) In which liquid is discharged in a plane perpendicular to the impeller shaft; and

(3) For which each stage (or bowl) consists of an impeller and diffuser; and

(4) For which no external part of such a pump is designed to be submerged in the pumped liquid.

Radially-split, multi-stage, horizontal, in-line diffuser casing (“RSHIL”) pump means a single-axis flow RSH pump in which the liquid enters the pump in a plane perpendicular to the impeller shaft.

Radially-split, multi-stage, horizontal, end-suction diffuser casing (“RSHES”) pump means a RSH pump in which the liquid enters the bare pump in a direction parallel to the impeller shaft and on the side opposite of the bare pump's driver-end.

Issue 19:

DOE requests comment on the proposed definitions for RSH, RSHIL, and RSHES pumps—particularly whether they are sufficient to identify the intended scope of such pumps as discussed in section III.A.3.c of this document.

8. Close-Coupled and Mechanically-Coupled Pumps

As discussed in section III.A.3.d, DOE defines a close-coupled pump as a pump having a motor shaft that also acts as the impeller shaft, and defines a mechanically-coupled pump as a pump that has its own impeller shaft and bearings separate from the motor shaft. DOE has tentatively determined that these definitions leave a gap in the end-suction pump category and is proposing to modify the definitions to eliminate that gap.

In the April 2021 RFI, DOE requested comment on the definitions of “close-coupled pump” and “mechanically-coupled pump” and whether the terms should be revised. 86 FR 20075, 20078.

Summit stated that it has no concerns with the current definitions for ESCC and ESFM and that they are definitive enough. (Summit, No. 16 at p. 3) Summit's comments also addressed energy conservation standards topics, which DOE will address in the pumps standards rulemaking. HI suggested the following change to the definitions: (1) A close-coupled pump, for the purposes of this regulation, is defined as a pump in which the driver's bearings absorb the pump axial load; and (2) A mechanically-coupled pump, for the purposes of this regulation, is defined as a pump in which bearings external to the driver absorb the pump axial load. (HI, No. 20 at p. 3) Grundfos agreed with HI's recommendation to modify the definitions for close-coupled pump and mechanically-coupled pump and emphasized that products that do not have bearings and have an impeller that is not on the motor shaft should be covered by these definitions. (Grundfos, No. 17 at p. 2) Grundfos additionally stated that the definitions for these products should utilize how the axial loads are handled as a differentiating factor for these terms.

Id.

Grundfos added that DOE's definitions are not necessarily aligned with standard industry definitions, and therefore recommended that DOE preface its definitions with the phrase, “For the purposes of this regulation, [product] pump means . . .”.

Id.

DOE acknowledges that a definition that addresses how the axial load is

absorbed may better differentiate close-coupled and mechanically-coupled pumps. DOE notes that regardless of whether its definitions align with industry definitions, the text in the CFR takes precedence over definitions in industry standards that may be incorporated by reference.

See

10 CFR 431.462. Based on responses received from stakeholders and DOE's review of ESCC and ESFM pumps, DOE has tentatively determined that there is a group of end-suction pumps that do not currently fall within the ESFM or ESCC definitions. To address this issue, DOE proposes revising its definitions for “close-coupled pump” and “mechanically-coupled pump” as follows:

A close-coupled pump means a pump in which the driver's bearings absorb the pump's axial load.

A mechanically-coupled pump means a pump in which bearings external to the driver absorb the pump's axial load.

In DOE's view, these revised definitions should capture all end-suction pumps whose axial loads are supported with bearings. This change should encompass the previously uncovered end-suction pumps and clarify the definitions sufficiently to avoid future confusion.

Issue 20:

DOE requests comment on the proposed definitional changes to ESFM and ESCC pumps in defining both categories based on the location of the bearings which bear the axial load of the pump. Specifically, DOE seeks comment on whether these proposed changes will capture the end-suction pumps identified by stakeholders as not currently meeting the ESCC or ESFM definitions.

9. Tangential Discharge

The definition for IL pump applies to pumps for which the liquid is discharged from the pump in a plane (

i.e.,

direction) perpendicular to the impeller shaft, and for which the entering and exiting flows are along the same axis (

i.e.,

single-axis flow).

See

10 CFR 431.462. The definition for end-suction pump applies to pumps for which the liquid enters the pump in a direction parallel to the impeller shaft and exits the pump in a plane perpendicular to the shaft.

Id.

DOE also currently defines the term “single axis flow pump” as “a pump in which the liquid inlet of the bare pump is on the same axis as the liquid discharge of the bare pump.”

Id.

As discussed in the April 2021 RFI, the “single axis flow pump” definition does not explicitly state whether the axis is defined by the suction opening to the volute or the suction opening at the perimeter of the pump. 86 FR 20075, 20078. Close-coupled pumps can be designed with a perpendicular discharge volute which is also tangential (

i.e.,

a design in which the suction and discharge openings do not share a common axis).

See

10 CFR 431.462 (defining “single axis flow pump”).

In the April 2021 RFI, DOE requested comment on how manufacturers are currently categorizing close-coupled pumps with tangential discharge volutes relative to the five pump categories defined at 10 CFR 431.464 and whether DOE should provide additional detail in the definitions for single-axis flow pump and/or end-suction pump regarding tangential discharge volute configurations. 86 FR 20075, 20078. Summit, Grundfos, and HI all commented that the existing definitions of end-suction pump and IL pump are sufficient. (Summit, No. 16 at p. 3; Grundfos, No. 17, at p. 2; HI, No. 20 at p. 3) Summit additionally stated that it assumes end-suction was relative to suction and parallel to the shaft, and that tangential discharge pumps are included in end-suction type pumps (Summit, No. 16 at p. 3) DOE interpreted this to mean Summit interprets end-suction as suction parallel to the impeller shaft. HI and Grundfos stated that tangential discharge is not a concern for IL pumps and RSV pumps because of the requirement for single axis flow included in the definitions for IL pump and RSV pump. (HI, No. 20 at p. 3; Grundfos, No. 17 at p. 2) HI and Grundfos additionally stated that tangential discharge is not a design characteristic for ST pumps, since this would imply a pump discharge perpendicular to the pump shaft, and that tangential discharge is already covered in both the ESCC pump and ESFM pump definitions.

Id.

Grundfos recommended that DOE specify whether tangential discharge is the location of the discharge outlet or the discharge exit from the volute.

Id.

After further reviewing the definitions for single axis flow pump, ESCC pump, ESFM pump, IL pump, and RSV pump, and taking into account stakeholder comments, DOE has tentatively determined that the current definitions are sufficient and is not proposing to revise the definitions for end-suction pump or in-line pump at this time.

10. Pump

DOE currently defines a “pump” as “equipment designed to move liquids (which may include entrained gases, free solids, and totally dissolved solids) by physical or mechanical action and includes a bare pump and, if included by the manufacturer at the time of sale, mechanical equipment, driver, and controls.” 10 CFR 431.462. DOE currently defines “bare pump” as “a pump excluding mechanical equipment, driver, and controls.”

Id.

As discussed in the April 2021 RFI, some manufacturers distribute kits of unassembled components that customers (including end users or distributors) may purchase and assemble into finished equipment that meets the definition of a pump or a bare pump. 86 FR 20075, 20078 DOE requested comment on the definitions of “pump” and its components and whether any of the terms should be amended, and if so, how the terms should be amended.

Id.

In particular, DOE requested comment on whether the terms are sufficient to identify which equipment is subject to the test procedure and whether any test procedure amendments are required to ensure that all such equipment can be appropriately tested in accordance with the test procedure.

Id.

In response to the April 2021 RFI, Grundfos and HI supported the definition of a pump as written. (Grundfos, No. 17 at p. 1; HI, No. 20 at p. 2) Summit commented that the pump definition could better describe what pump parts are subject to regulation. (Summit, No. 16 at p. 2) Specifically, Summit stated that it interpreted the definition such that if the parts in a kit alone will only be used to make a pump, with no other kits or parts needed, such a kit would be considered a pump.

Id.

Summit stated that determining the end use of a pump kit can be extremely burdensome.

Id.

Summit additionally commented that if a pump does not meet the PEI standard, Summit will no longer distribute its impeller/casing kit; however, Summit does not consider these spare parts to be covered by the DOE regulation.

Id.

DOE acknowledges that determining the end use of a pump kit, or a pump part can be burdensome. DOE currently interprets the term “bare pump” to include any kit that contains all the parts necessary for an operating pump, barring mechanical equipment, driver, and controls. Replacement parts are not the subject of this regulation.

C. Updates to Industry Standards

The current DOE test procedure for pumps incorporates the following industry test standards: HI 40.6-2014, ANSI/HI 1.1-1.2-2014, and ANSI/HI 2.1-2.2-2014. 10 CFR 431.463. The following sections describe updates to these industry standards and discuss what industry standards DOE is proposing to incorporate by reference in

the NOPR and the relevant provisions of those industry standards that DOE is proposing to reference.

1. ANSI/HI 40.6

As discussed in the April 2021 RFI, the DOE test procedure for pumps generally incorporates HI 40.6-2014. 86 FR 20075, 20080. Since publication of the January 2016 Final Rule, the Hydraulics Institute updated HI 40.6-2014 with the publication of HI Standard 40.6-2016, “Methods for Rotodynamic Pump Efficiency Testing” (“HI 40.6-2016”). The definitions and procedures in HI 40.6-2016 align with the DOE test procedure for pumps published in the January 2016 Final Rule. HI published another updated version of HI 40.6 in 2021, “Methods for Rotodynamic Pump Efficiency Testing” (“HI 40.6-2021”). HI 40.6-2021 includes the following modifications as compared to HI 40.6-2014 (relevant sections of HI 40.6-2021 are included in parentheses after a summary of the modification):

(1) Clarified that the industy testing standard covers efficiency testing of rotodynamic pumps that are subject to DOE's energy conservation standards. (Section 40.6.1 “Scope”)

(2) Updated the calculation of bare pump efficiency to match the current DOE test procedure requirements for plotting test data to determine the best efficiency point (“BEP”) rate of flow. (Section 40.6.6.3 “Performance curve”)

(3) Updated the description and requirements of the pressure tap configuration for measurement sections at inlet and outlet of the pump. (Section A.3.1.3 “Pressure taps”)

(4) Added an informative appendix for determining, applying, and calculating measurement instrument uncertainty. (Appendix H “Determination, application, and calculation of instrument (systematic) uncertainty (informative)”)

(5) References ANSI/HI 14.1-14.2 “Rotodynamic Pumps for Nomenclature and Definitions” (“ANSI/HI 14.1-14.2”) which supersedes ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014. (Section 40.6.4.1 “Vertically suspended pumps”; Section 40.6.4.3 “All other pump types”)

(6) Includes a new appendix (Appendix E) for the testing of circulator pumps. (Appendix E “Testing Circulator Pumps”)

DOE noted in the April 2021 RFI that comments in response to the September 2020 Early Assessment RFI suggested that DOE adopt HI 40.6-2021 instead of HI 40.6-2016, with commenters stating that the 2021 version includes clarifying edits, is no more burdensome to conduct, and includes a section for testing circulator pumps. 86 FR 20075, 20080. In the April 2021 RFI, DOE again requested comment on whether it should adopt HI 40.6-2016 or HI 40.6-2021.

Id.

Grundfos, the CA IOUs, HI, and NEEA all supported the adoption of HI 40.6-2021, stating that the 2021 version does not change the measured test values as compared to HI 40.6-2014 as referenced by the DOE test procedure, and that testing according to the 2021 version would not be more burdensome to conduct. (Grundfos, No. 17 at p. 4; CA IOUs, No. 19 at p. 11; HI, No. 20 at p. 2; NEEA, No. 21 at p. 2)

DOE has tentatively determined that with respect to the provisions of HI 40.6-2014, the corresponding provisions of HI 40.6-2021 are substantively the same and adopting such provisions would not change the current test procedure. As such, in order to reference the most current industry test procedure, DOE is proposing to incorporate by reference HI 40.6-2021 in place of HI 40.6-2014.

While DOE proposes to incorporate by reference HI 40.6-2021 as the basis for its proposed test procedure, DOE has tentatively determined that certain sections of the industry testing standard are not applicable to the DOE test procedure. Specifically, Section 40.6.1, Scope, provides the scope specific to the test methods outlined in HI 40.6; Section 40.6.5.3 provides provisions regarding the generation of a test report; appendix “B” provides informative guidance on test report formatting; appendix “E” provides normative test procedures for circulator pumps; and appendix “G” compares HI 40.6 and DOE's nomenclature. None of these sections are required for testing and rating pumps in accordance with DOE's proposed procedure. As such, DOE is not proposing to adopt Section 40.6.1, Section 40.6.5.3, appendix B, appendix E, and appendix G.

Additionally, certain provisions of HI 40.6-2021 are consistent with the additional provisions established by DOE in appendix A. As such, DOE is proposing to maintain those provisions through reference to HI 40.6-2021, specifically:

(1) Section I.D.1 of appendix A, which addresses damping devices, would be amended to reference the corresponding provisions in HI 40.6.3.2.2;

(2) Section I.D.2 of appendix A, which addresses stabilization, would be amended to reference the corresponding provisions in HI 40.6.5.5.1;

(3) Section I.D.3 of appendix A, which addresses calculations and rounding, would be amended to reference the corresponding provisions in HI 40.6.6.1.1;

(4) Sections III.D.1, IV.D.1, V.D.1, VI.D.1, and VII.D.1 of appendix A, which outline testing the BEP of different pump configurations, would be amended to reference the corresponding provisions in HI 40.6.5.5.1.

2. ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014

Subpart Y to part 431 currently incorporates by reference ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014. DOE references ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 in defining certain terms in 10 CFR 431.462. In 2019, ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 were updated and combined into ANSI/HI 14.1-14.2-2019, “American National Standard for Rotodynamic Pumps for Nomenclature and Definitions” (“ANSI/HI 14.1-14.2-2019”). The notable additions to ANSI/HI 14.1-14.2 which were absent in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 are outlined below:

(1) ANSI/HI 14.1-14.2-2019 includes additonal figures and tables to represent information included in ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014;

(2) ANSI/HI 14.1-14.2-2019 adds new pump definitions and pump classifications;

(3) ANSI/HI 14.1-14.2-2019 includes configuration definitions for vertical in-line, vertical end-suction, vertical self-priming, seal-less, magnetic drive, canned motor, and multi-stage pumps;

(4) ANSI/HI 14.1-14.2-2019 adds new definitions for discharge casing, volute,concentric casing, modified concentric casing, vaned diffuser/collector, bowl, and stage casing; and

25

25

A volute may also be referred to as a “housing” or “casing.”

(5) ANSI/HI 14.1-14.2-2019 includes a new “preferred operating region” section to define a guideline for reccomended operating flow rates.

In the April 2021 RFI, DOE requested comment on incorporating ANSI/HI 14.1-14.2-2019 by reference into the DOE test procedure. 86 FR 20075, 20080-20081. Grundfos and HI encouraged DOE to incorporate ANSI/HI 14.1-14.2-2019 (Grundfos, No. 17 at p. 4; HI, No. 20 at p. 2). However, stakeholders did not address whether adoption of ANSI/HI 14.1-14.2-2019 would substantively change currently defined terms and equipment classes.

As stated previously, in general the current DOE test procedure incorporates pump designations from ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 as examples for the definitions of end-suction close-coupled (ESCC); end-

suction frame mounted/own bearings (ESFM); in-line (IL); radially-split, multi-stage, vertical, in-line diffuser casing (RSV); and submersible turbine (ST) pump categories under the DOE test procedure. 10 CFR 431.462. DOE notes that generally, the references to ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 are in the context of providing non-limiting examples. DOE is concerned that continued inclusion of HI pump designations as examples of specific pump categories may cause confusion in the market or be misunderstood to limit the scope of the relevant definitions. To avoid any such misreading, DOE is proposing to remove the references to ANSI/HI 1.1-1.2-2014 and ANSI/HI 2.1-2.2-2014 as examples of certain pump category definitions. Additional detail on the proposed changes to the definitions is discussed in section III.B.2 of this document.

Additionally, DOE's current test procedure definition of “bowl diameter” relies on the “intermediate bowl” definition in ANSI/HI 2.1-2.2-2014. DOE is proposing to modify its definition for “bowl diameter” and add a DOE definition for “intermediate bowl” to remove the current reference to ANSI/HI 2.1-2.2-2014. These proposed changes will create a more self-contained definition. These proposed changes are discussed in section III.B.3 of this document.

D. Metric

The current energy efficiency standards for pumps are based on the PEI metric. 10 CFR 431.465. The PEI metric is a ratio of the pump energy rating (“PER”) of the tested pump to the PER of a minimally-compliant pump (“PER

STD

”).

See

section II of appendix A. The current test procedure defines the metric PEI

CL,

the pump energy index for a constant load, as applicable to pumps rated as bare pumps or sold with motors; and the metric PEI

VL

, the pump energy index for a variable load, as applicable to pumps sold with motors and continuous controls or noncontinuous controls. Appendix A, section II.A. A “continuous control” is a control that adjusts the speed of the pump driver continuously over the driver's operating speed range in response to incremental changes in the required pump flow, head, or power output. 10 CFR 431.462. A “non-continuous control” is a control that adjusts the speed of a driver to one of a discrete number of non-continuous preset operating speeds and does not respond to incremental reductions in the required pump flow, head, or power output.

Id.

The PEI metric is a ratio of the pump energy rating (“PER”) of the tested pump to the PER of a minimally-compliant pump (“PER

STD

”).

See

appendix A. The pump energy rating for constant load pumps (“PER

CL”

) is calculated as the average of driver power input at 75 percent, 100 percent, and 110 percent of flow at the BEP, where the flows are achieved by varying the operating head to follow the pump performance curve.

See

appendix A, section II.A.1 and subsequently referenced sections. The pump energy rating for variable load pumps (“PER

VL”

) is calculated as the average of driver power input at 25%, 50%, 75%, 100% of flow at BEP, where the flows are achieved by speed reduction to follow a specified system curve.

See

appendix A, section II.A.2 and subsequently referenced sections. BEP is defined as the pump hydraulic power operating point (consisting of both flow and head conditions) that results in the maximum efficiency. 10 CFR 431.462.

In response to the April 2021 RFI, NEEA stated that DOE's current pump test procedure generally provides a good representation of pump energy consumption and that the current pump metrics are good indicators of relative efficiency. (NEEA, No. 21 at p. 2)

This section discusses the proposed regulatory metric for SVIL pumps and additional clean water pumps that DOE is proposing to incorporate into its test procedure scope. In the May 2021 Circulator Pumps RFI, DOE discussed that the Circulator Pump Working Group recommended evaluating SVIL pumps using the PEI

CL

or PEI

VL

metrics, similar to commercial and industrial pumps, and using the commercial and industrial pump test procedure to measure performance, with any additional modifications necessary as determined by DOE. 86 FR 24516, 24527.

In their comments to the May 2021 Circulator Pumps RFI, the CA IOUs reiterated their support for SVILs to be rated using the PEI

CL

or PEI

VL

metric, consistent with the Circulator Pump Working Group term sheet. (CA IOUs, EERE-2016-BT-STD-0004, at No. 10 p. 6)

DOE reviewed the PEI

CL

and PEI

VL

metrics and has tentatively determined that, in general, use of PER

CL

and PER

VL

and indexing the results against PER

STD

would be a reasonable and consistent way to evaluate SVIL performance. This tentative determination is based largely on the similarities between SVILs and in-line pumps, which are evaluated using the PER

CL

and PER

VL

metrics. As such, DOE is proposing that the rating metric for SVIL pumps would be PEI

CL

for constant load pumps and PEI

VL

for variable load pumps, equivalent to the metric already in use for currently covered commercial and industrial pumps.

For the additional clean water pump categories that DOE is proposing to include within the scope of the test procedure (

i.e.,

vertical turbine pumps, between-bearing pumps, and radially-split, multi-stage horizontal pumps), DOE has tentatively determined that its proposed test procedure would measure energy efficiency during a representative average use cycle and not be unduly burdensome to conduct. This determination is based on the similarities between the pump categories that are addressed in the current test procedure and those that DOE is proposing to add. Therefore, DOE tentatively determines that PEI

CL

and PEI

VL

are appropriate metrics for use these pumps. DOE tentatively determines that using PEI

CL

and PEI

VL

for the additional pump categories would ensure a consistent rating approach in the market. Thus, DOE proposes that the PEI

CL

and PEI

VL

metric would be used for rating the performance of small vertical in-line pumps, vertical turbine pumps, between-bearing pumps, and radially-split multi-stage horizontal pumps.

E. Proposed Amendments to Test Method

As discussed in section III.C.1, DOE is proposing to utilize HI 40.6-2021 in its test procedure for pumps with certain exceptions. HI 40.6-2021 specifies calculating pump power input,

26

driver power input (for testing-based methods),

27

pump power output,

28

pump efficiency,

29

bowl efficiency,

30

overall efficiency,

31

and other relevant values at

the specified load points necessary to determine PEI

CL

and PEI

VL

. HI 40.6-2021 also contains specifications regarding test methodology, standard rating conditions, equipment specifications, uncertainty calculations, and tolerances.

26

The term “pump power input” in HI 40.6-2021 is defined as “the power transmitted to the pump by its driver” and is synonymous with the term “pump shaft input power,” as used in this document.

27

The term “driver power input” in HI 40.6-2014 is defined as “the power absorbed by the pump driver” and is synonymous with the term “pump input power to the driver,” as used in this document.

28

The term “pump power output” in HI-40.6 is defined as “the mechanical power transferred to the liquid as it passes through the pump, also known as pump hydraulic power.” It is used synonymously with “pump hydraulic power” in this document.

29

The term “pump efficiency” is defined in HI 40.6-2014 as a ratio of pump power output to pump power input.

30

The term “bowl efficiency” is defined in HI 40.6-2014 as a ratio of pump power output to bowl assembly power input and is applicable only to VTS and RSV pumps.

31

The term “overall efficiency” is defined in HI 40.6-2014 as a ratio of pump power output to driver power input and describes the combined efficiency of a pump and driver.

Sections II through VII of the DOE test procedure specify methods for determining PEI

CL

and PEI

VL

for pumps based on whether they are distributed into commerce with a motor and or with controls and are summarized below:

•

Section II:

Calculation of PEICL or PEIVL for all pumps based on the pump energy rating for a minimally-compliant reference pump (PERCL or PERVL, respectively);

•

Section III:

Test procedure for bare pumps;

•

Section IV:

Testing-based approach for pumps sold with motors;

•

Section V:

Calculation-based approach for pumps sold with motors;

•

Section VI:

Testing-based approach for pumps sold with motors and controls; and

•

Section VII:

Calculation-based approach for pumps sold with motors and controls.

See

appendix A, sections I.A.2 through I.A.6.

In response to the April 2021 RFI, NEEA recommended against any modifications to the test procedure that would minimally improve its representation of efficiency but that would require manufacturers to retest and rerate. (NEEA, No. 21 at p. 2) Similarly, HI recommended making only clarifications to the test procedure, except for the addition of a calculation method for power drive system losses for inverter-only motors. (HI, No. 20 at p. 1) The following sections discuss proposed amendments to the test procedure.

1. Nominal Speed

The scope of the current test procedure is limited to pumps designed to operate with either a 2- or 4-pole induction motor or a non-induction motor with a speed of rotation operating range between 2,880 and 4,320 rpm and/or 1,440 and 2,160 rpm. 10 CFR 431.464(a)(1)(ii). Section I.C.1 of appendix A specifies the selection of nominal speed of rotation of either 1,800 or 3,600 rpm depending on the number of poles of the motor or the operating range of non-induction motors.

As discussed in section III.A.4.b, DOE is proposing to include in the scope of the test procedure pumps that operate between 960 and 1,440 rpm or are designed to operate with 6-pole motors. DOE proposes that these pumps would be tested with a nominal speed of 1,200 rpm. DOE is also proposing updates to the calculation and rounding sections of the test procedure to address this additional nominal speed.

Issue 21:

DOE requests comment on its proposal that pumps designed to operate between 960 and 1,440 rpm or with 6-pole motors be assigned a nominal speed of 1,200 rpm.

In the April 2021 RFI, DOE requested comment on whether the nominal motor speeds of 1,800 rpm and 3,600 rpm used in the current DOE test procedure appropriately represent the operation and energy use of pumps that are capable of higher speeds. 86 FR 20075, 20083. If these motor speeds are not representative, DOE requested comment on whether a testing-based or calculation-based approach would provide more representative energy use values and the expected cost burden of each.

Id.

Additionally, DOE requested test data at speeds other than the nominal speeds specified in the current test procedure in order to determine if a calculation-based method is appropriate.

Id.

HI commented that the test procedure has a gap in regard to pumps sold with higher speed motors but asserted that the comment period did not allow enough time to fully develop a recommendation to modify the test procedure. (HI, No. 20 at p. 7). HI stated that they would continue to work on a recommendation and requested that DOE involve stakeholders in the solution.

32

Id.

Grundfos supported the work of HI in creating a recommendation for how to handle this equipment. (Grundfos, No. 17 at p. 7) Given that many of the motors in this category would be included in the inverter-only motor category for which a new calculation method is being proposed, and that DOE has not identified any data indicating what nominal speed would be more representative of higher design speeds, DOE has tentatively decided not to propose a higher nominal speed for testing.

32

DOE notes that HI's supplemental comments responding to the April 2021 RFI did not provide input on this issue. (HI, No. 22)

2. Testing of Multi-Stage Pumps

The current DOE test procedure specifies that RSV pumps shall be tested with three stages and that ST pumps shall be tested with nine stages. If the unit under test is only available with fewer than the required number of stages, the pump is tested with the maximum number of stages with which the unit is distributed in commerce in the United States. If the unit under test is only available with greater than the number of required stages, the pump is tested with the lowest number of stages with which the unit is distributed in commerce in the United States. If the unit under test is available with both fewer and greater than the required number of stages, but not the required number of stages, the pump is tested with the number of stages closest to the required number of stages. If both the next lower and next higher number of stages are equivalently close to the required number of stages, the pump is tested with the next higher number of stages.

See

appendix A, section I.C.2.

RSH and VT pumps are sold with a varying number of stages, in which the same pump may have options for multiple different stages for multiple applications. To reduce testing burden and mirror the practice established for RSV pumps, DOE proposes that RSH pumps be tested with three stages. To reduce testing burden and mirror the practice established for ST pumps, DOE proposes testing VT pumps with nine stages. If units of the basic model of pump being tested are not distributed in commerce with the number of stages prescribed for testing, the existing instructions for selection of the correct number of stages to use during testing would be followed.

As defined in section IIIB.5, BB pumps can have either one or two stages. For BB basic models that are distributed into commerce with both one and two stages, DOE proposes that the pump would be tested at two stages. This proposed approach would maintain consistency with DOE's current test procedure requiring that multi-stage pumps be tested with more than one stage.

Issue 22:

DOE requests comment on the proposed number of stages for testing RSH, VT, and BB pumps.

3. Best Fit Curve

In the current DOE test procedure, BEP flow rate is determined as the flow rate at which maximum pump efficiency is achieved on the pump efficiency curve, as determined in accordance with Section 40.6.6.3 of HI 40.6-2014. Appendix A, Sections III.D.2, IV.D.2, V.D.2, VI.D.2, and VII.D.2. Section 40.6.6.3 of HI 40.6-2014 provides instruction for determining the best fit curve for pump flow rate versus efficiency. Specifically, the best fit curve may be either (1) up to a 6th order polynomial, or (2) a spline function with a single slow reversal in the region of the BEP rate of flow. HI 40.6.6.3.

In response to the April 2021 RFI, Summit recommended better defining

“best fit curve” to the speed corrected data, possibly specifying a degree of polynomial required. (Summit, No. 16 at p. 2) Summit also recommended defining a minimum number of data points required per setpoint, or clarifying that a confidence interval—such as 95%—for each setpoint. (Summit, No. 16 at p. 2)

DOE tentatively concludes that the provisions in Section 40.6.6.3 of HI 40.6-2021 are sufficient for defining the best fit curve. When testing a pump, data relating to flow rate and efficiency can be fit using the allowed methods under HI 40.6-2021 in order to find the method with the best fit. DOE notes that, in general, “best fit” refers to a curve that best expresses the relationship between the data, and that can be determined through a least squares method. However, DOE does not fully understand Summit's request regarding the minimum number of data points required per setpoint. The test procedure requires taking a minimum of seven flow points and using a least squares regression to determine a linear relationship between pump power input or driver power input at measured flow points, which is then used to determine pump power input or driver power input at the specified load points.

See, e.g.,

appendix A, section III E.1.1. Because the specified load points are determined from the measured flow points, it is not essential for multiple data points to be taken per measured flow point. DOE notes that appendix A section VI.E.2.1 and section VI.E.2.2, which are relevant to the testing-based approach for pumps sold with motors and controls, provide tolerances and correction equations for the load points that must be measured at reduced speed. For these reasons, DOE is not proposing any changes in response to Summit's comment.

4. Load Profile

The current test procedure requires that constant load pump energy rating be determined using 75, 100 and 110 percent of BEP flow with each value multiplied by 0.33 and the results summed to determine PER

CL

. Appendix A, sections III.E, IV.E, V.E. Similarly, for variable load pumps, energy ratings are determined at 25, 50, 75, and 100 percent of BEP flow with each point weighted by 0.25 and summed to obtain a value for PER

VL

. Appendix A, sections VI.E, VII.E. In the April 2021 RFI, DOE sought additional comment on the load profile distribution for constant and variable load pumps and the effect of the distribution on PEI value. 86 FR 20075, 20083.

HI stated that the actual load profile of a pump in use is application specific and will vary widely for the applications covered by clean water pumps. HI stated that the current load profiles are sufficient for calculation of the PEI. (HI, No. 20 at p. 7) Grundfos supported keeping the existing load profiles and stated that given the large number of applications in which regulated pumps are used, the current profiles are sufficient to evaluate general pump performance. (Grundfos, No. 17 at p. 7) NEEA stated that they had no additional comment beyond their response to the September 2020 Early Assessment RFI, which DOE summarized in the April 2021 RFI. (NEEA, No. 21 at p. 11)

The existing load profiles provide a consistent method for comparing the performance of different pumps, which, as noted by stakeholders, exhibit a range of load profiles across the wide range of installation environments. At this time, DOE does not have any indication that the current load profiles are not appropriately representative. Therefore, DOE is not proposing changes to the current test procedure's load profiles.

5. Pumps With BEP at Run-Out

To determine a pump's BEP, the DOE test procedure references testing provisions included in HI 40.6-2014 (excluding sections 40.6.5.3, section A.7 and appendix B) at the following seven flow points: 40, 60, 75, 90, 100, 110, and 120 percent of the expected BEP flow rate of the pump at the nominal speed of rotation. Appendix A, section III.D.1. All pumps have a maximum flow rate which is termed “run out.” For pumps where the BEP is expected to be within 20 percent of the maximum flow rate of the pump (BEP at run out), section I.D.4 of appendix A provides alternative flow points, with the maximum flow point equal to 100 percent of the expected maximum flow rate so that the pump may safely operate. As discussed in section III.C.1, Sections 40.6.5.5.1 and 40.6.6.3 of HI 40.6-2021 now include provisions related to pumps with BEP at run-out. Section 40.6.5.5.1 provides alternate test points based on the expected BEP rate of flow for pumps with a maximum allowable flow rate as specified by the manufacturer that is less than 120 percent of the BEP flow rate. Section 40.6.6.3 also provides alternate tested load points for the driver input power as a percentage of BEP flow rate for pumps that cannot be safely tested to flows greater than 120 percent of BEP. However, these provisions are based on flow points with respect to expected BEP flow rate rather than expected maximum flow rate.

In the January 2016 Final Rule, DOE responded to a comment from HI that in order to determine the location of BEP, testing must occur at rates of flow greater than 100 percent of expected BEP flow. 81 FR 4086, 4117. DOE stated that its proposal to use flow points only up to 100 percent was with respect to the expected maximum allowable flow rate rather than with respect to expected BEP.

Id.

DOE notes that the existing regulatory text contains an omission in which section I.D.4(1) of appendix A only refers to “the expected” while section I.D.4(2) refers to “the expected maximum flow rate of the pump.” DOE proposes to include “expected maximum flow rate of the pump” in both section I.D.4(1) and I.D.4(2) of appendix A and would not reference Sections 40.6.5.5.1 or 40.6.6.3 of HI 40.6-2021.

Issue 23:

DOE requests comment on whether the alternate flow points for pumps with BEP at run-out should be determined with respect to expected maximum flow rate or expected BEP flow rate.

In addition, upon review and in response to previous stakeholder questions, DOE has tentatively determined that the current regulatory text would benefit from additional detail as to how the revised loading points should be applied in the determination of PER

STD.

DOE proposes to specify that the revised loading points would only be used in application of the α

i

coefficient values when determining pump power input, and not when determining specific speed (“Ns”) or the minimally-compliant pump efficiency (“η

pump,STD

”), which should always be based on 100% of BEP flow for standardization purposes.

DOE has also identified that the current provisions for pumps with BEP at run-out do not address how to perform motor sizing for bare pumps, which is based on the horsepower equivalent to, or the next highest horsepower greater than, the pump power input to the bare pump at 120 percent of the BEP flow rate of the tested pump. DOE proposes that for pumps with BEP at run-out, motor sizing would be based on 100 percent of the BEP flow rate of the tested pump, as there are no flow rates available higher than that level. However, DOE acknowledges that this proposed change could result in inequitable motor sizing as compared to pumps not subject to these provisions.

Issue 24:

DOE requests comment on how manufacturers are currently

performing motor sizing for bare pumps with BEP at run-out, and whether using 100 percent of the BEP flow rate is appropriate.

6. Calibration of Measurement Equipment

HI 40.6-2014 Appendix D, which the current DOE test procedure adopts, specifies the frequency of measurement equipment calibration. Table D.1 of HI 40.6-2014 provides that manufacturer's recommendations on calibration intervals should be followed if they differ from those in Table D.1. However, DOE notes that its test procedure does not explicitly reference Table D.1 of HI 40.6-2021.

In the dedicated-purpose pool pump test procedures included in appendix B and appendix C to 10 part 431 subpart Y (“appendix B”, “appendix C”), DOE has, for clarity, included the calibration requirements contained in Appendix D of ANSI/HI 40.6-2014, with modification allowing for calibration periods up to 3 times longer than those specified in Table D.1 of ANSI/HI 40.6-2014 if justified by historical calibration data.

See

appendix B, section I.B.2 and appendix C, section I.B.2.

Similar to the approach DOE has followed with appendices B and C, DOE proposes to specifically reference the calibration requirements in Appendix D of HI 40.6-2021 in section I.B of appendix A to improve the overall clarity of its test procedure.

7. Calculations and Rounding

The DOE test procedure includes provisions for calculations and rounding in section I.D.3 of appendix A. Generally, all measured data must be normalized such that it represents performance at nominal speed of rotation in accordance with HI 40.6-2014, and all calculations must be carried out using raw measured values without rounding.

See

appendix A, section I.D.3. PER is rounded to three significant digits and PEI is rounded to the hundredths place.

Id.

Explicit rounding directions are not provided for other parameters. In the April 2021 RFI, DOE requested comment as to whether the test procedure should specify rounding requirements on parameters other than PER and PEI, and if so, what those rounding requirements should be. 86 FR 20075, 20079 and 20083.

HI stated that rounding is not a concern for parameters other than PER and PEI and that DOE does not need to specify rounding requirements for these parameters. (HI, No. 20 at p. 7) Grundfos commented that additional rounding requirements might result in unnecessary data manipulation and would increase manufacturer burden for data reporting. (Grundfos, No. 17 at p. 7)

With respect to the current rounding provisions for PER and PEI, Summit recommended rounding PER to 3 decimal places and rounding PEI to two decimal places. (Summit, No. 16 at p. 5). Summit also stated that the number of significant figures is dependent on measurement devices and measurement uncertainty.

Id.

In response to Summit's suggestion for PER, DOE notes that three decimal places represent three significant figures for values less than 1. DOE has not identified any reason why three decimal places would be necessary for values greater than one and has tentatively determined that three significant figures is sufficient. DOE also notes that Summit's recommendation for two decimal places for PEI is consistent with the current test procedure's instruction to round to the hundredths place. For these reasons, DOE is not proposing any changes to its current rounding requirements, except for updates to reference the appropriate section of HI 40.6-2021, as discussed in section III.C.1 of this document.

8. Test Procedure Credits

In response to the April 2021 RFI, NEEA recommended that DOE add a credit for self-sensing “smart” pumps with continuous controls. NEEA stated that “smart” pump technologies use self-sensing technologies to measure power draw and speed to calculate load and then adjust speed to maximize performance and reduce energy consumption required to meet the load, and that the drive is programmed with the specific pump curve with which it is installed. NEEA stated that these features potentially reduce energy consumption by optimizing pump performance compared to traditional control strategies. NEEA commented that the potential performance improvements of such technology is not reflected in the test procedure. NEEA recommended that DOE investigate the potential for energy savings from such controls and develop minimally burdensome ways to incorporate them in the test procedure, such as the Controls Verification Procedure for Variable Refrigerant Flow (“VRF”) Systems or credit for occupancy systems given to certain beverage vending machines (“BVM”). (NEEA, No. 21 at p. 12)

According to DOE research, at this time the technology referenced by NEEA is proprietary, and DOE is unable to conduct sufficient testing on available proprietary technologies in applications to determine achievable energy savings. Furthermore, NEEA has not presented data demonstrating the viability of the asserted potential energy savings. For these reasons, DOE is not proposing a test procedure accommodation for pumps that incorporate self-sensing technologies at this time.

F. Calculation-Based and Testing-Based Options According to Pump Configuration (Table 1)

The DOE test procedure for pumps includes calculation-based and testing-based options that apply based on pump configuration (including style of motor and control) as distributed in commerce.

See

appendix A, Table 1. The calculation-based options rely on a bare pump test, whereas the testing-based options rely on a “wire-to-water” test. The calculation-based options may reduce test burden by allowing a manufacturer to test a sample of bare pumps and use that data to rate multiple pump configurations using calculation-based methods. On the other hand, wire-to-water testing may more accurately represent pump, motor, and control performance.

In order to further assess opportunity for reducing burden, DOE requested additional information on how manufacturers are implementing Table 1 of appendix A. Specifically, DOE sought comment on the extent to which pumps sold with multiple motor and control configurations are evaluated multiple times using physical testing-based methods (rather than a calculation-based approach); the extent to which pumps sold with single-phase motors are being rated as bare pumps (using a calculation-based approach); and the extent to which pumps sold with motors (other than inverter-only motors) are having their efficiency being evaluated using a calculation-based approach as opposed to a testing-based approach. 86 FR 20075, 20082. DOE also requested comment on whether any revisions to Table 1 of appendix A could be considered to maintain or improve the information derived from the test procedure while reducing burden with no impact on the PEI rating for currently regulated pumps.

Id.

HI stated that testing burdens typically cause manufacturers to calculate losses based on the standard motor efficiency and that approximately 1 percent of pumps are wire-to-water tested according to section IV of the test procedure. HI stated that no products were reported with wire-to-water testing on induction motors with controls per section VI of the test procedure. (HI, No. 20 at p. 5) HI stated that a majority of pumps with single-phase motors use the

bare pump PEI

CL

value; however, there are a small number of these products that were wire-to-water tested.

Id.

Grundfos stated that it utilized calculated methods wherever it was allowed, given what Grundfos characterized as the overly burdensome testing required to qualify the most efficient products running inverter-only motors. Grundfos stated that it conducted no testing using Section IV or Section VI for any product using an induction motor and reported all single-phase equipment using Section III. (Grundfos, No. 17 at p. 5) Summit stated that it filed its certification reports using only Section III, as they saw only minimal PEI improvement with section V, and using section IV for ESCC pumps would be burdensome. (Summit, No. 16 at p. 5)

NEEA encouraged DOE to ensure the information derived from the test procedure is maintained when considering possible changes to Table 1 to reduce burden. Specifically, NEEA recommended against DOE removing options for wire-to-water testing as a way to reduce burden and asserted that wire-to-water testing may result in more accurate ratings. NEEA also recommended that DOE not require wire-to-water testing but keep the option to use calculation-based or wire-to-water testing approaches. (NEEA, No. 21 at p. 10-11)

HI recommended amending Table I to allow use of section IV for pumps + single-phase induction motor and to require section VI for pumps + single-phase induction motor + continuous or non-continuous controls. (HI, No. 20 at pp. 5-6). HI also recommended amending Table 1 to require section IV for pump + motor + controls other than continuous or non-continuous controls (

e.g.,

ON/OFF switches). (HI, No. 20 at pp. 5-6) Grundfos supported the edits to Table 1 as recommended by HI. (Grundfos, No. 17 at p. 5-6) Grundfos additionally stated that because single-phase motors are not completely regulated (currently only open drip-proof motors are regulated), using section III for pump + motors should remain, and section IV should be optional but not mandatory. Grundfos commented that section VI testing for single-phase product using a variable frequency drive (“VFD”) should be mandatory. (Grundfos, No. 17 at p. 9)

DOE has reviewed the ways in which manufacturers are utilizing the various options in Table 1 as well as the recommended edits to Table 1. In response to NEEA, DOE is not proposing to remove wire-to-water testing options from Table 1. In response to HI and Grundfos, DOE agrees that Table 1 would benefit from providing more explicit instruction, particularly by moving information out of footnotes and into the table itself. However, DOE does not agree with the specific changes requested. Specifically, commenters provided no reason that a “pump + motor + controls,” other than continuous or non-continuous controls, must use a test method rather than a calculation method, or why single-phase products using a VFD must use a test method rather than the bare pump calculation method. Neither of these constraints are currently included in appendix A Table 1. DOE maintains that the existing allowances to use a calculation method for these products are appropriate and consistent with stakeholders' general desire to use calculation methods where possible. In particular, controls other than continuous or non-continuous controls—such as ON/OFF switches—would not be expected to impact the results of the test method. As such, the calculation method should adequately represent performance. Similarly, the current procedure permits single-phase equipment to be tested using the bare pump method, which eliminates the possibility of penalizing this equipment for using these less efficient motors compared to pumps sold with polyphase motors. While manufacturers could choose to use a testing-based approach when evaluating pumps sold with single-phase induction motors that use continuous or non-continuous controls in order to get a better rating than a bare pump rating, this is not necessary. For these reasons, DOE is not proposing to remove the calculation-based option, but is proposing to clarify Table 1 by moving information out of footnotes and into the table itself.

NEEA encouraged DOE to consider developing a calculation-based testing approach that would apply to any new or future pump configurations not covered by the current Table 1. NEEA recommended that DOE consider a hybrid approach to testing and calculation, similar to the test method included in Appendix H of ANSI/AMCA Standard 214-21, “Test Procedure for Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans and Blowers” (“AMCA 214”), which stipulates a one-time test of the motor at multiple load points, which can be used to determine the input power at the appropriate pump test procedure load points and then used to calculate a rating. With this method, each motor need only be tested once, and the results used for multiple pump configurations. (NEEA, No. 21 at p. 10)

The hybrid method as suggested by NEEA would require use of a test procedure that may be dependent on the type of motor. As such, DOE would be unable to implement such a method for unknown future pump configurations without specifying all possible test methods that might be appropriate for various motor types. Accordingly, DOE is declining to adopt this suggested approach. DOE addresses a similar request related to a specific motor type in section III.F.3 of this document.

Issue 25:

DOE requests comment on whether manufacturers would use a hybrid mapping approach, and if so, whether manufacturers would conduct the motor tests or request the tests from their suppliers. In addition, DOE requests comment on what additional provisions would need to be added to Appendix H of AMCA 214 to make it applicable to pumps, such as speed and load corresponding to pump rating points.

In relation to Table 1, Grundfos asked DOE to clarify how manufacturers are expected to report pumps using single-phase motors. Grundfos commented that these are sold as a pump + motor but reported using section III data, and that it was unclear whether they should be reported as a bare pump. (Grundfos, No. 17 at p. 5)

Under the current scope, actual pump configuration should be certified for pumps sold with single-phase motors. These pumps should not be certified as a bare pump.

1. Calculation Method for Pumps Sold With Induction Motors and Controls

In the April 2021 RFI, DOE noted that while its test procedure for pumps incorporates by reference HI 40.6-2014, it also includes additional provisions related to measuring the hydraulic power, shaft power, and electric input power of pumps, inclusive of electric motors and any continuous or non-continuous controls. 86 FR 20075, 20081. DOE also noted the publication of the International Electrotechnical Commission (“IEC”) standard IEC 61800-9-2:2017 “Adjustable speed electrical power drive systems—Part 9-2: Ecodesign for power drive systems, motor starters, power electronics and their driven applications—Energy efficiency indicators for power drive systems and motor starters,” (“IEC 61800-9-2:2017”), which addresses test methods and reference losses for power drive systems, comparable to the approach in section VII of appendix A.

Id.

DOE noted that the majority of commenters responding to the

September 2020 Early Assessment RFI urged DOE to maintain the current test approach in section VII of appendix A and that substituting IEC 61800-9-2 would add burden without achieving additional energy savings.

Id.

DOE also noted the publication of the American Movement and Control Association (“AMCA”) standard, AMCA 207-17 “Fan System Efficiency and Fan System Input Power Calculation” (“AMCA 207-17”) in the April 2021 RFI and requested comment on the applicability of the VFD/motor efficiencies in AMCA 207-17 to pumps, and whether DOE should consider replacing the calculations in section VII of appendix A with those in AMCA 207-17. 86 FR 20075, 20081. DOE additionally requested comment on whether adoption of the AMCA 207-17 approach would be representative for pumps, and whether such a change would impact PEI ratings, manufacturer testing burden, or manufacturer pump designs.

Id.

Finally, DOE requested comment on whether it should consider incorporating any aspect of ISO/ASME 14414 “Pumps System Energy Assessment” (“ISO ASME 14414”) into its test procedure for pumps, and if so, which aspects and why.

Id.

As stated previously, the DOE test procedure for pumps includes calculation-based and testing-based options that apply based on pump configuration (including style of motor and control) as distributed in commerce.

See

appendix A, Table 1. The calculation-based options rely on a bare pump test, whereas the testing-based options rely on a wire-to-water test. Section VII of appendix A provides the calculation-based testing method for pumps sold with motors and continuous controls—specifically polyphase motors covered by DOE's electric motor energy conservation standards or submersible motors. Section VII includes four separate algorithms for determining part-load losses of the motor and continuous controls together. These algorithms account for part-load losses of the motor as well as additional losses that result from continuous control inefficiencies and from increased inefficiencies in the speed-controlled motor due to harmonic distortion as a function of motor horsepower.

HI stated that the current calculation methodology should remain consistent, but that HI would provide recommendations for updates to coefficients that would not increase testing burden on pump manufacturers. (HI, No. 20 at p. 4) HI additionally commented that ISO/ASME 14414 is a pump system assessment standard and is not applicable to individual bare pumps or pumps sold with motors and/or controls. (HI, No. 20 at p. 5) Grundfos stated that there is no need to modify or replace the Section VII calculation method. Grundfos supported the HI recommendation to use updated coefficients in section VII for induction equipment. (Grundfos, No. 17 at p. 4)

NEEA recommended that DOE continue using the current motor loss calculation approach, including the motor and drive loss equation and required test points for pump manufacturers. NEEA stated that the AMCA 207-17 approach would result in an average 3 to 6 percent reduction in calculated motor and drive losses, and also PEI

VL

, in comparison to the current DOE pumps test procedure. NEEA also commented that, while the AMCA 207-17 approach could be considered more representative of typical losses in comparison to test data, AMCA 207-17 was developed specifically for fans. NEEA added that IEC 61800-9-2 results in a similar change in motor and drive losses and appears to be achieving wider adoption in the industry. NEEA suggested that if DOE were to consider updating the motor and drive losses in the test procedure, NEEA would support aligning with IEC 61800-9-2 (and the embedded standard IEC 60034-2, “Rotating electrical machines—part 2-3: Specific test methods for determining losses and efficiency of converter-fed AC motors”). NEEA stated that updating the loss calculations to reference AMCA 207-2017 or IEC 61800-9-2 would require manufacturers to re-rate pumps for a difference in PEI

VL

of only about 0.01. Instead, NEEA recommended that if DOE elects to pursue updates to the losses, DOE should do so by updating the coefficients or the calculations and make no changes to pump, motor, or drive testing. NEEA stated that it is important that the calculation-based approach result in conservative ratings so that manufacturers are not disincentivized from testing equipment, which provides a more accurate result, and are not able to overstate product performance based on the calculation-based approach. (NEEA, No. 21 at pp. 7-8)

The CA IOUs stated that cost of wire-to-water testing can result in the use of the calculation method for some efficient products, even though the calculated PEI would be reduced via this method, creating a market distortion in which efficient products are scored with PEIs worse than would be representative. The CA IOUs commented that this highlights the need for a calculation method to be as representative as possible, while requiring some conservativeness in the calculation methodology to prevent scores higher than wire-to-water testing of conventional products. The CA IOUs stated that the actual motor drive system performance is approximately 3 to 14 percent better in practice than estimated with the current methodology and encouraged DOE to make adjustments to the calculation method to improve the representativeness and align across industries. (CA IOUs, No. 19 at p. 2)

The CA IOUs expressed support for the use of AMCA 207-17, stating that it was designed for predictions based solely on variable-torque curves, which apply to pumps, that it provides accurate and somewhat conservative default losses, and that it has been directly or indirectly adopted by various industry consensus standards. The CA IOUs stated that the adoption of the AMCA 207-17 method would result in manufacturers reporting lower PEIs without actually improving the efficiency of the pump, but that they believe it is more important that DOE adopt a loss calculation method that is representative and can be used across all product lines that employ VFD power drive systems. The CA IOUs included a figure comparing the percent PER improvement with AMCA 207 losses compared to DOE losses, with PER improvements ranging between 6 and 14 percent. (CA IOUs, No. 19 at pp. 2-4)

The CA IOUs also commented that industry stakeholders highlighted IEC 61800-9-2 as a potential framework that could apply motor VFD losses in an industry and product independent manner, and stated that they provided a spreadsheet comparing this method, the AMCA 207 method, and the existing DOE methods.

33

The CA IOUs also stated that IEC 61800-9-2 provides high reference VFD losses that they expect to be dealt with in the International Energy Agency

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