DOE FAQs

HI assembled a committee of 10 members, partners and staff with expertise on the subject to collect, review and share frequently asked questions on the DOE final rules, their scope, compliance and test procedure.

Committee Members:

Jamie Watkins (Chair) – Crane Pumps & Systems
Mark Chaffee – Taco Inc.
Michael Coussens – Peerless Pump Company
Kevin Fulton – Ebara International Corp
Peter Gaydon – Hydraulic Institute
Mark Handzel – Xylem Inc. – Applied Water Systems
Al Iseppon – Pentair – Berkeley
Paul Ruzicka – Xylem Inc. – Applied Water Systems
James Volk – Franklin Electric Company, Inc.

The responses to the questions have been submitted to DOE for confirmation, but have not been endorsed or approved by the department of energy.

GENERAL FAQS / SCOPE FAQS / COMPLIANCE FAQS / TEST PROCEDURE FAQS

Disclaimer

The DOE Final Rules for Energy Conservation Standards and test procedure for certain clean water pumps are lengthy and complex documents intended to improve pump energy efficiencies.  The Rule contains numerous complex provisions relating to a number of equipment classes relating to thousands of specific pump models.  Inevitably, there are areas where the Rule leaves unclear its precise scope, leaving pump manufacturers having to determine on their own the Rule’s applicability to a particular pump model.  In an attempt to assist manufacturers, the Hydraulic Institute (“HI”) offers answers to frequently asked questions in a good-faith effort to clarify the intended scope of the Rule so that proper compliance can be obtained.

HI submitted this material to DOE for its approval or comment, but DOE did not respond.  Therefore, this material has not been approved by the DOE, which is the primary government entity responsible for enforcement of the provisions of the Rule.  HI cannot provide assurance that the DOE will agree with HI’s reasoning.

Those who rely on this material do so at their own risk.  This material is based upon information that HI believes is reliable, but may contain technical inaccuracies or other errors.  HI makes no representation or warranty as to the suitability of the information provided or the validity of any conclusions drawn, or decisions made, on the basis of this material.  Decisions based upon this material are the exclusive responsibility of the user.  HI assumes no responsibility for any direct, indirect, special, incidental or consequential damages arising from reliance on this material.

General FAQs

• Where can I get a copy of the final rule?
  • There are two rules that were published into law.
    1. Energy conservation program: Energy conservation standard for pumps can be found at: https://www.federalregister.gov/articles/2016/01/26/2016-00324/energy-conservation-program-energy-conservation-standards-for-pumps
    2. Energy conservation program: Test procedure for pumps can be found at: https://www.federalregister.gov/articles/2016/01/25/2016-00039/energy-conservation-program-test-procedure-for-pumps
  • Additionally the regulatory text for the standard, test procedure and certification can be found in the electronic CFR at:
    1. http://www.ecfr.gov/cgi-bin/retrieveECFR?n=pt10.3.431#sp10.3.431
    2. http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=10:3.0.1.4.17#se10.3.429_159
• When do I need to comply with the Energy Conservations Standard and Test Procedure for Pumps?
  • On January 25th & 26th, 2016, the US DOE published final rules in the Federal Register for the Energy Conservation Standard & Test Procedure for Pumps.
  • The rules became effective on March 28, 2016
  • Compliance is required on January 27, 2020
  • Annual filing requirements
    • Certification reports are due September 1st of each year
    • Submittal procedure yet to be determined
  • Starting on July 25, 2016, any representations made with respect to the energy use or efficiency of covered pumps must be made in accordance with (431.464 Appendix A).
• Will there be a common directory to review where distribution curves and percentile rankings can be determined?

  DOE common directory (CCMS database) will not present the data in this manner.  DOE will have a database and make certain data public for all basic models listed.

• What is a basic model?
  • The basic model is the designation given to a pump or group of pumps of the same equipment class by the manufacturer when the pump is certified with a PEI_CL/VL to the DOE.
  • The regulation says: Basic model means all units of a given class of pump manufactured by one manufacturer, having the same primary energy source, and having essentially identical electrical, physical, and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency, water consumption, or water efficiency; except that:
    1. For RSV and ST pumps, all variations in numbers of stages of the bare pump must be considered a single basic model;
    2. Pump models for which the bare pump differs in impeller diameter, or impeller trim, may be considered a single basic model; and
    3. Pump models for which the bare pump differs in number of stages or impeller diameter and which are sold with motors (or motors and controls) of varying horsepower may only be considered a single basic model if
       • for ESCC, ESFM, IL, and RSV pumps, each motor offered in the basic model has a nominal full load  motor efficiency rated at the Federal minimum (see the current table for NEMA Design B motors at 10 CFR 431.25) or the same number of bands above the Federal minimum for each respective motor horsepower (see Table 3 of Appendix A to Subpart Y of Part 431); or
       • for ST pumps, each motor offered in the basic model has a full load motor efficiency at the default nominal full load submersible motor efficiency shown in Table 2 of appendix A to subpart Y of part 431 or the same number of bands above the default nominal full load submersible motor efficiency for each respective motor horsepower (see Table 3 of Appendix A to Subpart Y of Part 431).In summary HI believes:

  • The Basic Model is the unit(s) of the same equipment class whose performance is reported to the DOE under a single PEI value.
  • Basic Model(s) listed as a bare pump can be sold with reduced diameter impeller trims or number of stages (RSV & ST) and all would have the same PEI value.
  • Basic Model(s) listed as a pump and motor can be sold with reduced diameter impeller trims or number stages (RSV & ST) and all would have the same PEI value, provided any trimmed or different stage count is distributed with a motor of an equivalent or higher efficiency level compared to its nominal.
• Is the PER[STD] being defined by the DOE EL2 C-values?
  • Yes, DOE has set the standard level for ESCC, ESFM, IL and ST-3600 pumps based on the EL2 C-values.
  • However, the RSV pump standard level was harmonized with the European standard level and the ST-1800 standard level is set equal to the EL0 level of the ST-3600.
• Will the PER[STD] be regularly re-evaluated with manufacturers hopefully improving their pumps, would the baseline increase?

  Law requires DOE to review Energy Conservation Standards and test procedures periodically (every 6-7 years).  DOE is also required to publish all amendments in the federal register and address public comments.

• DOE provided an Excel spreadsheet for PEI[CL] and PEI[VL] calculations. Are current versions available w/ latest “C” values?
  • To HI’s knowledge DOE has not released an updated calculator that is consistent with the final rule
  • HI has requested that DOE provide an updated calculator so that it is accurate when used
  • HI has developed a calculator consistent with the methods outlined in 10 CFR 431 Subpart Y and the Uniform Test Procedure Appendix A to Subpart Y. The calculator is available at er.pumps.org/pei.
• Does the pump regulation mean that motors will now be produced with their minimum efficiency (which is same as NEMA Table 12-12 nominal efficiency) given as stated in Table 5 of 10 CFR § 431.25 – Energy conservation standards as against NEMA Table 12-12 efficiency table which stipulates minimum efficiency and Nominal efficiency.

  The energy conservation standards for pumps at 10 CFR 431.465 do not set any new or amended standards for motors. DOE established separate energy conservation standards for electric motors (See Subpart B of Part 431) and small electric motors (See Subpart X of Part 431).

Scope FAQs

• What pump types are included in the scope of the regulations?
  • The scope of the standards are specified precisely at 10 cfr 431.464 and 10 cfr 431.465 respectively.

  In summary:

  • Five types of “clean water” rotodynamic pumps at two nominal speeds for each type have defined standard levels.
    • Clean water pump means 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.
  • Each pump type (equipment category) is defined in the uniform test procedure.
    The covered types are:
    • End suction Closed Coupled (ESCC)
    • End Suction Frame Mounted (ESFM)
    • In-line (IL)
    • Radially Split Multi-stage in-line diffuser casing (RSV)
    • Submersible Turbine (ST)
  • A summary with equipment class definitions and images can be found here.
• Are BB1 pumps covered under the definitions of in-line pumps?

  DOE Response: DOE implemented the working group’s decision to exclude BB1 pump types by limiting applicability of standards and test procedures to clean water pumps within a specific HP range. [10 CFR 431.465(b), (d)] However, a manufacturer should compare the characteristics of a given basic model to DOE’s regulations to determine specific applicability based on the definitions provided.

• If one of the parameters for establishing scope outlined by DOE is not met, then is the pump excluded from the regulations? For example is a below 1HP pump excluded?
  • If any of the performance scope parameters are not met in the determination of the basic model at full diameter impeller, number of stages for testing and at the nominal speed of rotation, the pump would then be out of scope.  However, for RSV and ST pumps, all variations in numbers of stages of the bare pump must be considered a single basic model.  In this case (for example) a RSV pump is to be tested and rated with 3 stages or an ST pump is to be tested and rated with 9 stages, could include a model with greater and less stages and shaft hp at full diameter below 1 hp or above 200 hp under the same basic model and it would require labeling.
  • DOE set certain performance criteria applied to a basic model that limits the clean water pumps within scope of this rulemaking which are:
    • 1 – 200 shaft hp at full impeller diameter for the number of stages required for testing at the nominal speed of rotation.
    • 25 gallons per minute or greater at best efficiency point with full diameter impeller at the nominal speed of rotation.
    • 459 feet of head maximum at best efficiency point with full diameter impeller and for the number of stages required for testing at the nominal speed of rotation.
    • Design temperature range between 14 °F and 248 °F
    • Designed for 1800 RPM (1440 RPM – 2160 RPM) or 3600 RPM (2880 RPM – 4320 RPM) nominal speed of rotatio
    • For ST pumps, bowl diameter 6 inches or less
    • Specific speed 5000 or below (U.S. Units)
• Does the rule include pumps with three-phase and single-phase motors?
  • Yes, the regulation applies to pumps within scope driven by any motor or other prime mover.
  • Applicability of calculation and testing based procedure options for pumps with motors or other prime movers is outlined in Table 1 of Appendix A to Subpart Y of 10 CFR 431.
• We make pumps that are used in clean water applications but have been designed to suit multiple non-clean water applications including the passage of a certain amount of solids. Are my pumps within scope because they are used for clean water in addition to many other applications?
  • DOE Response: DOE defines “clean water pump” in 10 CFR 431.462. In that section, DOE also states: “In cases where definitions reference design intent, DOE will consider marketing materials, labels and certifications, and equipment design to determine design intent.” Pumps that do not meet the clean water pump definition are excluded from the applicability of standards and the test procedure. [10 CFR 431.465(b)]HI Committee: DOE established scope based on product definition, design intent and performance parameters, not the application it is used in.
    • The determination of if the pump is within scope is based on the manufacturers determination if it meets DOE’s definition of clean water pump.
    • If the pump is designed for clean water per the definition of clean water pump and it satisfies the equipment class definitions as well as performance parameters, it is within scope.
    • If the manufacturer has made design considerations for the pump to enable it to safely handle liquids other than water or water with additional solids content or dissolved solids or water outside the temperature range that impact the power consumption of the pump, it would then potentially serve a different utility and not meet the definition of “clean water pump”. If the manufacturer has a question regarding scope, inquiries can be sent to the U.S. DOE and they will be considered on a case by case basis.
• Are refinery and chemical process pumps included in the rules coverage?
  • DOE established scope based on product definition, design intent and performance parameters not the application it is used in.
  • Pumps designed for clean water are within scope (See Scope FAQ 1). If a pump designed to pump clean water is used in a refinery or chemical process then it is within scope.
  • If a pump was designed for fluids other than clean water and is used in a refinery or chemical process, then it would NOT be covered. For example pumps complying with API 610 or ASME B73 would be designed for a utility other than clean water and would not be in scope of this regulation. For further information refer to Scope question 5 above.
• Do the new rules apply to pumps used for low consistency (0.5% consistency) paper stock?
  • DOE established scope based on product definition, design intent and performance parameters not the application it is used in.
  • Refer to Scope FAQ 5 and 6.
• We are trying to determine if we can offer certain options in non-clean water applications only to avoid having to test every possible material and accessory configuration of every pump. Specifically, we are interested in only offering bronze impellers and inducers for non-clean water applications and updating the marketing material as such. We have seen inducers to have both a positive and negative impact on efficiency so if they were to be included in the scope of testing requirements it would double the number of tests required if you wanted to be certain the most consumptive option is tested. Since we do not see inducers typically used in clean water applications, we do not feel they should be included within the scope. The same can be said of bronze impellers, as we have seen parts produced by different patterns impact efficiency.

  Committee Response:

  • See scope question #5
  • DOE does not define an inducer so it is recommended that you check with DOE at ApplianceStandardsQuestions@ee.doe.gov to determine how an inducer will impact a pump’s scope.

  DOE Response:

  • • If a pump meets the definition of clean water pump at 10 CFR 431.462, is one of the equipment classes listed at 10 CFR 431.465(b)(4), is not listed at 10 CFR 431.465(c), and meets the characteristics listed in 10 CFR 431.465(d), then it is subject to standards.
• Will repairs or retrofits of existing pumps sold prior to January 27, 2020 need to meet efficiency standards and will the repaired pumps require testing?
  • It is HI’s understanding that the regulation applies to newly manufactured pumps that are manufactured in or imported into, the United States on or after January 27, 2020.
  • Manufacture means to manufacture, produce, assemble, or import.
  • Manufacturer means any person who manufactures a consumer product.
  • HI does not believe a repair part for an existing pump manufactured prior to or after the compliance date is within scope of the standard and would not require testing or labeling.
• Is a kit of pump parts considered a pump or a part?

  If the manufacturer sells a kit that can be assembled into a bare pump, it is a pump and must comply with the requirements of the regulations.

• If an ST pump at 250 gpm exceeds 459 feet of head at BEP with 9 stages, is the entire 250 gpm offering (even with fewer stages) excluded?
  • DOE Response: Correct, based on 10 CFR 431.465(d)(2) and Appendix A to Subpart Y of Part 431, I.C.2. The exception would be if a pump is not offered with 9 stages, the head requirement would apply at a different number of stages per the same test procedure section.
  • HI Committee: In addition, HI believes that a 9 stage ST or 3 stage RSV pump that exceed 200 shaft horsepower at the best efficiency point, would not fall within scope when sold with fewer impellers. This would also apply to single stage (ESCC, ESFM & IL) basic models where the full impeller diameter exceeds 200 shaft horsepower or 459 ft of head at the best efficiency point.
• Our vertical pumps are essentially a VS4 style pump. We take one of our ESCC centrifugal pumps and mount them on a column which has bushing supports for a motor coupling shaft. Are VS4/VS5 pumps within scope of the regulation?
  • DOE Response: DOE understands that the majority of VS4 and VS5 pumps are not designed for clean water and would not fall into the scope of applicability adopted for standards [10 CFR 431.465(b)]. However, a manufacturer should compare the characteristics of a given basic model to DOE’s regulations to determine specific applicability based on the definitions provided.
  • HI Committee: HI understands that most VS4/VS5 pumps are not designed for clean water, but if a manufacturer has a VS4 or VS5 pump that they are unsure if it is within scope, they should lay out the differences between a VS4/VS5 pump compared to ESFM pumps within scope of the regulations and if necessary request a test procedure waiver from DOE to address the additional shafting and bearings that consume energy, which are not present on typical frame mounted pumps. Please review the specific waiver provisions found at 10 CFR 431.401.
• Are multistage centrifugal pumps covered by the Department of Energy regulations or are they exempt. I understand that multi-stage RSV and ST pumps are addressed, but I have been unable to find where multistage centrifugal ESFM might be addressed or exempted.
  • ESFM and ESCC pumps (refer to scope question #1) are defined as “end-suction” pumps.  The definition of end suction (included below) defines them as “single-stage”; therefore, multi-stage versions of these pumps are excluded.
  • End suction pump means a rotodynamic pump that is single-stage and in which the liquid enters the bare pump in a direction parallel to the impeller shaft and on the end opposite the bare pump’s driver-end.
• For a close coupled pump with a tangential discharge volute (i.e. the suction and discharge openings do not share a common axis) such as the casing shown below, would this be an in-line (IL) or end suction close coupled pump (ESCC), and subsequently be within scope of the regulation?

  DOE Response:

  • A close coupled pump with a tangential discharge volute as described above would be subject to standards if it meets the definition of ESCC = end suction close-coupled, ESFM = end suction frame mounted/own bearing, IL = in-line, RSV = radially split, multi-stage, vertical, in-line diffuser casing, or ST = submersible turbine; all as defined in §431.462.
  • A close coupled pump with a tangential discharge volute as described above does not meet the definition of an ESCC and ESFM because the liquid would not enter the bare pump in a direction parallel to the impeller shaft.  It also does not meet the definition of an IL pump and of a RSV pump because it is not a single axis flow pump.
• Is a pump that is designed to run above 4320 rpm, but can also be operated between 2880 rpm and 4320 rpm, within scope of the regulation, and how should it be rated?

  HI Committee Response:

  • Generally, If a pump meets the definition of clean water pump at 10 CFR 431.462, is one of the equipment classes listed at 10 CFR 431.465(b)(4), is not listed at 10 CFR 431.465(c), and meets the characteristics listed in 10 CFR 431.465(d), then it is subject to standards.
  • Per 10 CFR 431.465 (d)(4), The energy conservation standards apply only to pumps that have the following motor characteristics:
    • ii. Designed to operate with either:
      • A 2- or 4-pole induction motor; or
      • 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 and/or 1,440 and 2,160 revolutions per minute; and
      • In either case, the driver and impeller must rotate at the same speedBased on the regulatory text, the committee believes the pump would be within scope if it is also offered to operate between 2880 rpm and 4320 rpm (i.e. published curves within range).
      • The pump would need to be tested in the speed range outlined in HI 40.6, and would be rated at the appropriate pole speed

Compliance FAQs

• How will manufacturers submit certification data to DOE?

  Certification reporting templates and all public data will be made available on DOE’s certification and enforcement website at https://www.regulations.doe.gov/ccms.  The manufacturer will register with the CCMS and will login to upload data electronically through the website.

• When will the certification template be made available?

  DOE Response: The U.S. DOE has made the certification template available at https://www.regulations.doe.gov/ccms/templates/product_templates

• What data is required to be submitted for certification?
  • Data for certification is covered in §429.59 (b) certification reports.  In this section the requirements of §429.12 are also invoked.  429.12 outlines the general requirements applicable to certification and 429.59 outlines the pump specific requirements applicable to certification.
    1. The general requirements are things such as a compliance statement, the product or equipment type and class, Manufacturers’ name and address, brand name, and for each brand the basic model number, and individual model number(s) in that basic model, etc.  HI recommends referencing the eCFR for a full list of general requirements. http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=10:3.0.1.4.17#se10.3.429_112  and
    2. The product specific data outlined in 429.59 varies depending configuration of the pump as distributed in commerce and corresponding section of the test procedure used to rate the pump.  HI recommends referencing the eCFR for the full list of product specific information.  http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=10:3.0.1.4.17#se10.3.429_159 
• For ESCC pumps, can pumps with the same impeller and casing, but with different motors and case covers, be considered a single “basic model” and therefore get qualified only once?
  • Refer to General FAQ #4 for the definition of basic model and the use of multiple motors.
  • HI believes, as long as the basic model rating is based on the most consumptive motor and case cover, multiple motors and case covers can be offered under a single basic model.
  • The test procedure does not say anything specific about case covers, but the definition of basic model might give you an answer.  Basic Model encompasses all the units of a given class of pump manufactured by one manufacturer, having the same primary energy source, and essentially identical electrical, physical, and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency, water consumption, or water efficiency
• Does a manufacturer have to have their test lab certified?

  The DOE regulation does not require an approved laboratory.

• How can pumps installed into a system be regulated?

  10 CFR 431 Subpart Y only regulates the pump, and not the equipment it is installed in.  This applies to newly manufactured or imported pumps into the U.S. on or after January 27, 2020.

• Does the pump manufacturer have to show / callout the pump model’s PEI value on pump’s nameplate?

  Yes, the PEI is required on the pump nameplate and on each page of a catalog that lists the pump and in other materials used to market the pump.

• The regulatory text at § 431.466 (a) (1) (ii) indicates the “bare pump model number” is required on the pump nameplate and not the basic or individual model number. Without including the basic model number or individual model number how can the pump be traced back to DOE’s certification site?
  • DOE Response: Per 10 CFR 429.59(c), the individual model number reported for any equipment configuration should include the individual model number of the bare pump (or should otherwise provide sufficient information to identify the specific driver model/and or controls model(s) with which a bare pump is distributed).
  • HI Committee: HI believes that including only the “bare pump” model number on the label would not be enough to identify the individual model or basic model that the PEI is certified for. However, HI does not believe that manufacturers will only list the bare pump model number because it is not descriptive enough for the customer or support the PEI value on the label.
• When using the calculation methods to determine PEICL/VL, what information must be supplied for certification with regards to the driver and/or controls to comply with 429.59 (c)?

  For pumps with drivers and or controls you have to provide either the individual model number for the driver and control or sufficient information to identify the specific driver model and or control model with which a pump is distributed.

• How are the representative PEI, flow rate, head and powers to be determined that are submitted for certification?
  • The representative PEI is determined per a sampling plan at 10 CFR §429.11 and as outlined §429.59 Pumps.
    (a) Determination of represented value.
    • http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=10:3.0.1.4.17#se10.3.429_159
  • This section of the eCFR outlines the determination of the PEI representative value, but does not explicitly state how the representative flow rate, head and power values are to be determined.
  • DOE Response: Currently, the regulations do not specify a particular method to determine these (flow rate, head, and power) representative values of a multi-unit sample. In these situations, DOE believes the mean of the sample is reasonable to use to represent these values.
• What about when reporting values (like pump total head at BEP and nominal speed, flow rate at BEP and nominal speed, calculated driver power input at each load point, etc.) to DOE, how many significant figures should be reported?

  Currently the DOE regulation does not specify these rounding values.  Unless DOE specifies otherwise you should use the number of digits that is reasonable based upon the measurement resolution.

• For a pump motor combination sold by a manufacturer where the motor is inverter duty (variable speed capable) but not sold with a control. How does the pump manufacturer rate and label the pump?
  • The regulation indicates that rating and labeling is based on the configuration that the pump is sold.  In this case, bare pumps sold with electric motors (including inverter duty) but not with controls must be rated and labeled with a constant load pump energy index (PEI_CL).
  • Labeling requirements are shown in Table VI.1.

  

• Is it possible for a non-compliant bare pump to be installed with a prem. motor and variable speed drive to then qualify as compliant?
  • Yes, in such a case the pump must be tested, certified with DOE and distributed in commerce with the motor/controls and could not be sold as a bare pump after January 27, 2020.
  • The pump would not be able to be sold as a bare pump or bare pump kit.
• If the pump only passes via test per Section V test (pump and motor, where motor losses are determined based on the nameplate efficiency), can it be sold as a spare part as a bare pump?
  • If manufactured on or after January 27, 2020, it would not be able to be sold as a bare pump because it would not meet the minimum requirement utilizing default motor losses as outlined per section III.
  • Per the definition outlined by DOE a “bare pump” meets the definition of a pump and would need to meet the standard levels set.
  • If the manufacturer sells a kit that can be assembled into a bare pump, it is a pump and must comply with the requirements of the regulations
  • HI does not believe the regulation covers individual spare parts
• If a pump was manufactured prior to 2020, can it be sold/grandfathered after 2020?
  • If the pump is manufactured (assembled complete & labeled and not the manufacture date of the components) in the United States as it will be sold in commerce before January 27, 2020, it is HI’s understanding that the regulation does not apply.
  • For imported products, HI understands that the manufacture date is the date the product goes through U.S. customs.
  • Manufacture means to manufacture, produce, assemble, or import.
  • Manufacturer means any person who manufactures a consumer product.
• Is it assumed that when 2020 rolls around, pump warehouses should be empty of all pumps that don’t comply?
  • If the pump was manufactured in or imported to the United States prior to January 27, 2020, it can be sold after January 27, 2020 without complying with the standard.
  • Manufacture means to manufacture, produce, assemble, or import.
  • Manufacturer means any person who manufactures a consumer product.
• Is the manufacturer or the distributor responsible for updating the PEI when the distributor makes changes?
  • The Original Equipment Manufacturer (OEM) is responsible for rating and labeling the pump with a PEI
  • If the distributor adds a motor and/or drive, the PEI on the nameplate does not need to be updated.  In this case, the OEM nameplate must be used on the pump.  The distributor can add additional identification without reference to PEI.
• How does this regulation affect a pump sales company that builds and assembles pumps in their shop? i.e., mix of trimming impellers, different pump manufacturers and multiple motor type and manufactures.
  • Assuming the bare pump (wet end) is rated with a PEI when the sales company receives it….
    • For trimmed impellers the PEI can remain, but the sales company will be responsible for adding the impeller diameter as distributed in commerce to the nameplate.
    • Multiple motors that are compliant with DOE regulations (10 CFR 431.25) may be sold with the bare pump.
• If the distributor wants to update the PEI for a previously rated pump and become the manufacturer, can they?
  • DOE Response: DOE assumes this is referring to the case where an OEM rated the pump as a bare pump and a distributor adds a motor and/or control. If a distributor wishes to rate this combination with a specific PEI, it must certify it as a new basic model and follow the regulations accordingly.
  • HI Response: This would require the distributor to fully test the pump per the uniform test procedure, sampling plan, determine representative values and submit certification data to DOE as a new basic model. This would require the distributor to update the nameplate with the new manufacturer name, basic model and PEI.
• Is it possible for a pump to be sold to an end-user that comes with a VFD but the pump label has a PEICL rating?

  Yes, for example if a motor and control is added to a PEICL rated bare pump basic model, the PEICL can remain on the nameplate and no additional reporting to DOE is required.

• How will the DOE enforce these requirements? Are there inspectors required at every installation? What local jurisdiction will be handling compliance of the DOE regulation?

  DOE enforces standards.  DOE’s assessment and enforcement process is laid out at 10 CFR 429 – subpart C.  See http://energy.gov/gc/conservation-standards-enforcement-useful-links for some useful info.

• If one uses the calculations to determine PERCL/VL rather than actual testing, how will those methods be verified? Do you have to verify your calculations with a certain number of tests to use the method?
  • It is up to the manufacturer to verify that all testing and calculations are done per Appendix A to Subpart Y of 10CFR 431
  • At a minimum the bare pump must be tested to determine the best efficiency point and the pump power input at the required load points.  Per the sampling plan at least 2 pumps must be tested so that a mean PEI can be calculated.
  • The term “calculation” applies to the test method that uses default driver and control losses as outlined in sections III, V and VII of Appendix A to Subpart Y of 10 CFR 431.
  • The representative PEI is per a sampling plan as outlined §429.59   Pumps (a) Determination of represented value. http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=10:3.0.1.4.17#se10.3.429_159
  • The manufacturer is required to list the method used to determine PEI in the certification reporting and DOE will use the same method that is listed in the certification when any auditing is conducted.
• Is the PEI rating done for full diameter impellers only or can a pump be rated with a trimmed impeller?
  • PEI is determined based on the full impeller diameter of the basic model that is rated and subsequent trimmed impellers can be distributed in commerce under the same rated basic model number.
  • The manufacturer has the option to trim the impeller and re-designate the trimmed impeller as the full diameter under a new basic model.
  • Full impeller diameter means the maximum diameter impeller with which a given pump basic model is distributed in commerce.
• If a pump has a PEI of 0.99, it passes and the product is able to be sold. Due to the testing tolerances (flow/head/power), this product could be tested independently or in the same lab at a later date and actually have a PEI of 1.01 which fails. How does the DOE address variation in tolerance other than a simple average of sample pumps? Is there a risk of “near miss” that requires special attention?
  • Enforcement testing for compliance to the Energy Conservation Standards for Pumps 10 CFR Parts 429 and 431 does not allow any pump with a calculated or tested value PEI  greater than 1.00.  There currently is no upper tolerance or upper control limit permitted by the DOE
  • Each manufacturer must assess how comfortable they are with borderline certification cases and the number of samples tested and understand potential lab to lab variability that could occur within the test procedure limits that could go the other way.  In all cases, but especially in these borderline certification testing cases, it is prudent for the manufacturer to thoroughly document their test personnel, all measured values and results including calculation of values in HI 40.6, calibration records, etc. along with laboratory certifications, in the case DOE does enforcement testing and challenges the manufacturer’s certification.
  • The determination of the PEI value to be represented to the DOE is to be calculated using the statistical methods presented in 429.59, which states to use the higher of the arithmetic mean of the sample or the upper 95 percent confidence limit of a one tailed interval.  It is up to the manufacturer to verify that the number of samples tested and the values reported to the DOE are compliant, consistent and accurately reported to avoid injunctions and potential civil penalties for either under reporting of the PEI value or exceeding 1.00.  For pumps, DOE will use an initial sample size of not more than four units and will determine compliance based on the arithmetic mean of the sample. For a marginal pass condition during certification testing, there is a possibility that when DOE does enforcement testing a failure of the arithmetic mean could occur.  For example if four pumps are tested with the following values of PEI: 0.99, 1.01, .99, 1.01; the arithmetic mean of 1.00 is larger than the upper 95 percent confidence limit of a one tailed interval divided by 1.05 (for this example is 0.97).  Per the regulation the manufacturer could certify the pumps with the larger of the two numbers or in this case the arithmetic mean of 1.00 to DOE.  Even without considering various test laboratory uncertainties, there is a high possibility that the mean PEI determined during DOE enforcement testing will be above 1.0.
• For pumps where the “wet end” is used on both on ESCC and ESFM pumps, do we need to test this both on frame (ESFM) and direct coupled motor (ESCC) or can it be tested in only the most consumptive configuration (ESFM) and certified separately as an ESFM and ESCC pump based on the most consumptive data?
  • DOE Response: Because ESCC and ESFM are two separate equipment classes, the manufacturer needs to certify compliance of the pump in both configurations (see 10 CFR 429.12).
  • HI Committee: The review committee believes that to reduce testing burden, the manufacturer could choose to limit testing to one configuration, that through their engineering judgement they believe will yield the most consumptive PEI score, but still certify them separately. If this is done, the manufacturer is taking a risk that the configuration (ESFM or ESCC) tested is actually the most consumptive.

   

• In the definition for in-line pumps (ref page 4094) we see a conflict for item (b) “the pump requires attachment to a rigid foundation to function as designed and cannot function as designed when supported only by the supply and discharge piping to which it is connected.” We believe this was intended to exclude circulators but some manufactures statement claim that traditional in-line product does not require foundations. Is this a loop hole that could be used to exclude in-line product by a manufacturer.
  • DOE’s final regulatory definitions are listed in the Code of Federal Regulations (10 CFR 431.462) and all manufacturers should use the CFR and NOT the Federal Register documents when referencing DOE’s regulations.  The CFR will ALWAYS have the most recent and currently effective language.
  • HI does not believe there is a loop hole because in the Federal Register publication on page 4100, DOE indicates that after considering all comments, definitions for pump equipment categories subject to this test procedure are as set forth in the regulatory text of this rule (10 CFR 431.462).  At this location, DOE has considered public comments, that attachment to a rigid foundation should not be used and DOE has revised the definition of IL pump as shown below.
    • 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.
• When we sell pump end kits, we do not know if they will be assembled into an ESFM or ESCC or if they will be 2-pole or 4-pole. How should these pump end kits be labeled when they are sold if the final configuration is not known?

  DOE Response:  Manufacturers should certify the products in the manner in which they are distributed in commerce.  Presumably they would be labeled with the least efficient configuration relevant to the kit given it’s the same bare pump until it is installed.

• The minimally compliant PER is a function of specific speed, flow at best efficiency point and a specified C-value. PER for the given pump model is the weighted average of the electric input power supplied to the pump over a specified load profile. For a RSV pump, shouldn’t the HI PEI calculator return the same PEI and PER values if one inputs test data for a basic model (3 stage or different) or if one inputs the same data normalized to one stage? For the example I tested, the PEI calculator version I have today returns the same PEI values but different PER values.
  • DOE requires that the number of stages tested is reported in certification of the pump.
  • Therefore, the answer to the question is no, PEI should be the same, but the PER value should increase with more stages and decrease with less stages.
  • The PER and other performance values reported to DOE and entered into the HI calculator must be consistent with the number of stages tested.  The PER reported in the HI PEI calculator is consistent with the number of stages entered into the calculator.
  • See question 29 in the compliance section, for the proper number of stages to test RSV and ST pumps.
• For multi-stage pumps how do I determine the number stages for testing to conform to the regulation?
  • For Multi-stage Pumps, RSV and ST pumps, perform testing on the pump with (3) three stages for RSV pumps and (9) nine stages for ST pumps.
    • If the basic model of pump being tested is only available with fewer than the required number of stages, test the pump with the maximum number of stages with which the basic model is distributed in commerce in the United States.
    • If the basic model of pump being tested is only available with greater than the required number of stages, test the pump with the lowest number of stages with which the basic model is distributed in commerce in the United States.
    • If the basic model of pump being tested is available with both fewer and greater than the required number of stages, but not the required number of stages, test the pump with the number of stages closest to the required number of stages.
      • For example if you distribute in commerce a ST pump with 4 or 11 stages, you would test the pump with 11 stages.
    • If both the next lower and next higher number of stages are equivalently close to the required number of stages, test the pump with the next higher number of stages.
      • For example if you offer RSV pumps with only even number of stages (i.e. 2, 4, 6, 8, etc.), you would test the pump with 4 stages.
• It is common practice in the pump industry to include catalog pages that do not reference a pump’s efficiency including sectional drawings, dimensional drawings and pages describing a pump’s materials of construction. It is also common to have marketing collateral that focuses on a products features, benefits or application success stories. Is it the intent to include the PEI on all pages as stated, or rather only on those catalog pages or marketing materials that would typically include efficiency information such as product curves, selection guidelines or specifications as examples?

  The regulatory text at 10 CFR 431.466 (b) Disclosure of efficiency information in marketing materials, indicates the following:

  (1) The same information that must appear on a pump’s permanent nameplate pursuant to paragraph (a)(1) of this section, must also be prominently displayed:

  1. On each page of a catalog that lists the pump; and
  2. In other materials used to market the pump.

  HI does not know if it is DOE’s intent that the PEI be listed on all pages of marketing material such as product features, benefits or application success stories.  HI believes it is important and required to list the pump basic or individual model number and the corresponding PEI anywhere claims to energy efficiency or energy consumption are made for the model.

  HI believe sectional drawings, dimensional drawings or pages that describe materials of construction are not marketing materials for the pump and therefore, would not require listing of the PEI on those pages.

• For pumps that are privately labeled who is responsible for certifying the privately labeled brands with DOE?
  • §429.12 outlines the general requirements applicable to certification (reference compliance FAQ 3).  Within §429.12 some of the general requirements DOE lists are:
    • Certification. Each manufacturer, before distributing in commerce any basic model of a covered product or covered equipment subject to an applicable energy conservation standard set forth in parts 430 or 431, and annually thereafter on or before the dates provided in paragraph (d) of this section, shall submit a certification report to DOE certifying that each basic model meets the applicable energy conservation standard(s).
    • Certification report. A certification report shall include a compliance statement (see paragraph (c) of this section), and for each basic model, the information listed in this paragraph (b).
      • Product or equipment type;
      • Product or equipment class (as denoted in the provisions of part 430 or 431 of this chapter containing the applicable energy conservation standard);
      • Manufacturer’s name and address;
      • Private labeler’s name(s) and address(es) (if applicable);
      • Brand name;
      • For each brand, the basic model number and the manufacturer’s individual model number(s) in that basic model.
  • Based on §429.12 (a) & (b)(4) and §429.12 (a) & (b)(5) the pump manufacturer (reference compliance FAQ 15 & 16) is required to list the private labeler(s) and private labeler brand(s) of the pump(s) they manufacture if a private labeling agreement exists for that model.
  • Based on §429.12 (b)(6), for pump model(s) that are manufactured by a single manufacturer and are otherwise identical, but sold under multiple brands, the manufacturer must submit a basic model number and manufacturer’s individual model number(s) in that basic model for each private label brand listed.
  • Each private label is listed as a unique entry in the CCMS database (reference general FAQ 3) and the “manufacturer’s individual model numbers” would refer to the individual model numbers associated with the listed brand.
  • The same underlying test data can be used for determining the representative PEI for the same pump distributed in commerce under multiple brands.
  • The DOE’s CCMS database, lists pumps by brand only, so publically it will not be evident who manufacturers the brand listed.
• What constitutes a “permanent” label? §431.466 clearly defines what the label must contain, but does not define what a permanent label is. Can you offer some guidance as to what the DOE is looking for i.e. a sticker vs. stamped plate?

  HI believes the “permanent” nameplate marked with the information required in  §431.466 should be affixed to the pump when it is distributed in commerce in a way that is not designed to be removed after installation and designed so markings remain permanent under normal usage and handling. HI believes examples of this are sticker or stamped plates, etc., which are attached through adhesive, fastener, or welding/soldering, or other permanent method. HI does not believe there is a specific DOE criterion for outlining minimum requirements for this.

• As I understand it the deadline for data submission to the CCMS is September 1st. Assuming data is accepted, meeting this deadline will guarantee compliance and certification status by January 27th, when the rules go fully into effect. What happens if data is submitted after the September 1st deadline (i.e. redesign hydraulic parts, new pump design, etc.)?

  10 CFR 429.12(a)(d) states the following: “(a) Certification. Each manufacturer, before distributing in commerce any basic model of a covered product or covered equipment subject to the applicable energy conservation standard set forth in parts 430 or 431, and annually thereafter on or before the dates provided in paragraph (d) of this section, shall submit a certification report to DOE certifying that each basic model meets the applicable energy conservation standard(s). The certification report(s) must be submitted to DOE in accordance with the submission procedures of paragraph (h) of this section.”

  “(d) Annual filing. All data required by paragraphs (a) through (c) of this section shall be submitted to DOE annually, on or before the following dates:”

  Product category	Deadline for data submission
  Torchieres, Residential dehumidifiers, Metal halide lamp fixtures, External power supplies, and Pumps	Sept. 1.

   

  Based on these citation, the manufacturer must submit certification data before distributing the covered equipment into commerce and annually thereafter on or September 1st.

• Can a PEI[VL] be listed on the nameplate of a replacement bare pump (originally sold as PEI[VL] pump+motor+drive) so that it matches the VL rating that was originally sold in 2020? Assuming the existing VFD is not replaced so it will not be distributed with the replacement bare pump.

  Information on pump labeling requirements can be found at 10 CFR 431.466. As provided below, it states bare pumps and pumps sold with electric motors, but not non-continuous, or continuous controls, the rated pump energy index – constant load (PEI_CL) is required on the permanent nameplate.

  §431.466   Pumps labeling requirements.

  (a) General pumps. For the pumps described in §431.464(a), the following requirements apply to units manufactured on the same date that compliance is required with any applicable standards prescribed in §431.465.

  (1) Pump nameplate—(i) Required information. The permanent nameplate must be marked clearly with the following information:

  (A) For bare pumps and pumps sold with electric motors but not continuous or non-continuous controls, the rated pump energy index—constant load (PEI_CL), and for pumps sold with motors and continuous or non-continuous controls, the rated pump energy index—variable load (PEI_VL)

• When we say the motor should be DOE regulated, what exactly does it mean? Are we saying that it should be NEMA compliant? What about IEC motors that are sold in USA? What are the requirements to be DOE regulated? What exactly does DOE regulated motor mean?

  Committee Response:

  • For ESCC, ESFM, IL, and RSV pumps covered at 10 CFR 431.465, Only “Polyphase Motors Covered by DOE’s Electric Motor Energy Conservation Standards” can be tested using the calculation-based methods in Section V, and Section VII of the pump test procedure.
  • For ST pumps, each motor offered in the basic model has a full load motor efficiency at the default nominal full load submersible motor efficiency shown in Table 2 of appendix A to subpart Y of 10 CFR 431 or the same number of bands above the default nominal full load submersible motor efficiency for each respective motor horsepower (see Table 3 of appendix A to subpart Y of 10 CFR 431)”.

  DOE Response:

  • The test procedure in Appendix A to Subpart Y of Part 431 specifies different applicable test methods listed in Table 1. Some of these methods are only applicable in the case of pumps sold with a “Polyphase Motor Covered by DOE’s Electric Motor Energy Conservation Standards”. The note under Table 1 in Appendix A to Subpart Y of Part 431 specifies that “All references to “Motors Covered by DOE’s Electric Motor Energy Conservation Standards” refer to those listed at §431.25(g) of this chapter.” The motors subject to standards are characterized using nine criteria listed at 10 CFR 431.25 (g) and include both NEMA motors and IEC equivalent motors.
  • Motors that are not regulated by DOE’s Electric Motor Energy Conservation Standards and not listed at 431.25(g) can also be used with pumps.  For these pumps, Table 1 specifies different applicable test methods.
• Does the DOE energy band rule apply to induction motors only or to both Induction and Permanent Magnet Motors?

  Committee Response:

  • Per 10 CFR 431.462 (3) (i), For ESCC, ESFM, IL, and RSV pumps, each motor offered in the basic model has a nominal full load motor efficiency rated at the Federal minimum (see the current table for NEMA Design B motors at §431.25) or the same number of bands above the Federal minimum for each respective motor horsepower (see Table 3 of appendix A to subpart Y of this part)

  DOE Response:

  • Manufacturers may also apply clause (3)(i) of the basic model definition in §431.462 to non-covered motors with rated efficiency that exceeds the federal minimum for NEMA Design B motors at §431.25 (based on HP, poles, and frame construction of the non-covered motor).
• Can Single Phase and three phase motors be put on same basic model of same PEI if the single phase motor satisfies the Energy band rule with the 3-phase motor efficiencies?

  Committee Response:

  • In regards to single phase and three phase motors, the following text is from the Federal Register Vol. 81 No. 15 page, January 25, 2016 Page 4104: “….DOE proposed that pumps sold with single- phase induction motors be tested and rated in the bare pump configuration, using the calculation-based method (see section III.E.1.a for a more detailed description of this method). DOE believed that such an approach would more equitably rate pumps sold with single-phase motors and prevent pumps sold with single-phase motors from being penalized by the reduced energy efficiency of the paired single-phase motor, as compared to similarly-sized polyphase motors. 80 FR 17586, 17600–01 (April 1, 2015).  As such, DOE is adopting provisions in this final rule that allow manufacturers the option of rating pumps sold with single-phase motors as bare pumps (using a calculation-based method) or as pumps with motors using the testing-based methods.”

  DOE Response:

  • In the test procedure final rule notice, DOE noted that, consistent with DOE’s practice with other products and equipment, pump manufacturers may elect to group similar individual pump models within the same equipment class into the same basic model to reduce testing burden, provided all representations regarding the energy use of pumps within that basic model are identical and based on the most consumptive unit. Manufacturers may pair a given bare pump with several different motors with different performance characteristics and can include all combinations under the same basic model if the certification of energy use and all representations made by the manufacturer, are based on the most consumptive bare pump/motor combination for each basic model and are determined in accordance with DOE’s test procedure in Appendix A to Subpart Y of Part 431and applicable sampling plan. (See 81 FR 4086, 4093) Each manufacturer must decide how to group their individual models of pumps based on the definition of basic model in 10 CFR 431.462. In addition, 10 CFR 429.12 contains information regarding certifying compliance of each basic model.
• I have a Permanent Magnet Motor which also uses NEMA frame but no NEMA Premium stamp. The efficiency of the Motor is same as that given by DOE Table 5 of 10 CFR § 431.25 – Energy conservation standards. Can I use the energy band to have my pumps grouped together into a basic model with one PEI or Do I need to test every one of the Pump that uses the Permanent Magnet IEC Motor?

  Committee Response:

  • Under the basic model definition requirements at § 431.462, if all the motors meet the federal minimum, or are the same or greater number of bands above the federal minimum compared to the tested motor, they can be grouped in a single pump basic model.

  DOE Response:

  • Manufacturers may also apply clause (3)(i) of the basic model definition in §431.462 to non-covered motors with rated efficiency that exceeds the federal minimum for NEMA Design B motors at §431.25 (based on HP, poles, and frame construction of the non-covered motor).
• For RSV and ST pumps with permanent magnet motors (not regulated at 431.25), rated as a pump and motor, can multiple motor horsepowers and/or differing number of stages be offered in a single basic model?

  Committee Response:

  • The definition of basic model indicates “all bare RSV and ST pumps must be considered a single basic model”, and
  • “For ESCC, ESFM, IL, and RSV pumps, each motor offered in the basic model has a nominal full load motor efficiency rated at the Federal minimum (see the current table for NEMA Design B motors at §431.25) or the same number of bands above the Federal minimum for each respective motor horsepower (see Table 3 of appendix A to subpart Y of this part) [See DOE response below related to applying the band requirements in clause (3)(i) for the basic model definition in §431.462]
  • For ST pumps, each motor offered in the basic model has a full load motor efficiency at the default nominal full load submersible motor efficiency shown in Table 2 of appendix A to subpart Y of this part or the same number of bands above the default nominal full load submersible motor efficiency for each respective motor horsepower (see Table 3 of appendix A to subpart Y of this part)”.

  DOE Response:

  • Manufacturers may also apply clause (3)(i) of the basic model definition in §431.462 to non-covered motors with rated efficiency that exceeds the federal minimum for NEMA Design B motors at §431.25 (based on HP, poles, and frame construction of the non-covered motor). Based on the definition of basic model at 10 CFR 431.462,  pump models for which the bare pump differs in number of stages or impeller diameter and which are sold with motors (or motors and controls) of varying horsepower may only be considered a single basic model if the “energy band” rule applies. In addition, manufacturers should certify the products in the manner in which they distribute them into commerce.
• Do all PM motor pumps need actual testing of each pump to get PEI, thus there is no need for individual basic models even if their efficiencies are better than the stipulated DOE minimum efficiency value? Is there a way that the PMs can be grouped into basic model?

  DOE Response:

  • (Compliance # 37) In the test procedure final rule notice, DOE noted that, consistent with DOE’s practice with other products and equipment, pump manufacturers may elect to group similar individual pump models within the same equipment class into the same basic model to reduce testing burden, provided all representations regarding the energy use of pumps within that basic model are identical and based on the most consumptive unit. Manufacturers may pair a given bare pump with several different motors with different performance characteristics and can include all combinations under the same basic model if the certification of energy use and all representations made by the manufacturer, are based on the most consumptive bare pump/motor combination for each basic model and are determined in accordance with DOE’s test procedure in Appendix A to Subpart Y of Part 431and applicable sampling plan. (See 81 FR 4086, 4093
  • Each manufacturer must decide how to group their individual models of pumps based on the definition of basic model in 10 CFR 431.462. In addition, 10 CFR 429.12 contains information regarding certifying compliance of each basic model.
• Can we sell pumps as bare pumps and pumps with motors under the same basic model number?

  DOE Response:

  • In the test procedure final rule notice, DOE noted that, consistent with DOE’s practice with other products and equipment, pump manufacturers may elect to group similar individual pump models within the same equipment class into the same basic model to reduce testing burden, provided all representations regarding the energy use of pumps within that basic model are identical and based on the most consumptive unit. (See 81 FR 4086, 4093)
  • Each manufacturer must decide how to group their individual models of pumps based on the definition of basic model in 10 CFR 431.462. In addition, 10 CFR 429.12 contains information regarding certifying compliance of each basic model.
• We noted that the DOE submittal template for certification and 10 CFR 429.59(b)(iii), indicate that for variable load pumps tested per section VI and VII of the test procedure, that “driver power input (measured as the input power to the driver and controls) at each load point i (Piin), corrected to nominal speed of rotation” should be reported. This nomenclature is not used in sections VI or VII of the test procedure, and correcting reduced speed load point data to nominal speed is not described in the test procedure. What should be reported?

  DOE Response:

  Thank you for bringing this to the attention of the Department.  For pumps sold with motor and continuous or non-continuous controls, do not correct driver power input at 25%, 50%, and 75% load points to nominal speed. When using section VI, do correct those values to the exact intended head and flow conditions per Sections VI.E.2.1 and VI.E.2.2 of the test procedure.  The template will be updated shortly.

• When using the CCMS template for General Pumps, what values should be reported in the ‘Driver Power Input’ columns if the pump was tested following the instructions for pumps with BEP at run out [Appendix A to Subpart Y of Part 431, Section I.D.4(3)]? Columns AA-AC, and AE-AG, specify the standard load points of 75, 100, and 110 percent of BEP rate of flow, and there is no obvious way to indicate that the alternate load points were used. In this case, should the manufacturer enter values for load points of 65, 90, and 100 percent of BEP rate of flow, as used to calculate PER_CL and PER_STD?

  DOE Response:

  In the case where a pump was tested following section I.D.4, please enter values in columns AA-AC or AE-AG for load points of 65, 90, and 100 percent of BEP flow rate.

• If you have a configuration of a RSV pump that is not offered as a three stage but may have higher or lower staging does it follow the rules for the next closest number of stages?

  HI Committee Response:

  Yes, RSV pumps should follow the rules for the next closest number of stages as cited at Appendix A of 10 CFR 431 Subpart Y, section C.2.

• I have a pump that is driven by Permanent Magnet (PM) Motors via VFD. This PM Motors can be driven by separate VFDs based on Voltage (230V or 460V). My question then is whether the PEI from 460V can be used for the 230V if: (1) Both 230V and 460V VFDs have same efficiency, and (2) Both 230V and 460V VFDs have different efficiency?

  HI Committee Response:

  •  If you wanted to group 230V and 460V VFD driven PM motor pumps as individual models under the same basic model, you would need to test the most consumptive configuration, and rate the basic model accordingly.
  •  Alternatively you could test each configuration and rate them as separate basic models with different PEI ratings.
  • Each manufacturer must decide how to group their individual models of pumps based on the definition of basic model in 10 CFR 431.462. In addition, 10 CFR 429.12 contains information regarding certifying compliance of each basic model.
• Can single phase and three phase pumps driven by Permanent Magnet (PM) Motors via VFD be put on same basic model if: (1) Both 230V (single and 3-Phase) VFDs have same efficiency, and (2) Both 230V (single and 3-Phase) VFDs have different efficiency?

  HI Committee Response:

  • If you wanted to group 230V single and three phase driven PM motor pumps as individual models under the same basic model, you would need to test the most consumptive configuration, and rate the basic model accordingly
  • Alternatively you could test each configuration and rate them as separate basic models with different PEI ratings
  • Each manufacturer must decide how to group their individual models of pumps based on the definition of basic model in 10 CFR 431.462. In addition, 10 CFR 429.12 contains information regarding certifying compliance of each basic model
• Is a pump that is designed to run above 4320 rpm, but can also be operated between 2880 rpm and 4320 rpm, within scope of the regulation, and how should it be rated?

  HI Committee Response:

  • Generally, If a pump meets the definition of clean water pump at 10 CFR 431.462, is one of the equipment classes listed at 10 CFR 431.465(b)(4), is not listed at 10 CFR 431.465(c), and meets the characteristics listed in 10 CFR 431.465(d), then it is subject to standards.
  • Per 10 CFR 431.465 (d)(4), The energy conservation standards apply only to pumps that have the following motor characteristics:
    i. 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 and/or 1,440 and 2,160 revolutions per minute; and
    3. In either case, the driver and impeller must rotate at the same speed
  • Based on the regulatory text, the committee believes the pump would be within scope if it is also offered to operate between 2880 rpm and 4320 rpm (i.e. published curves within this speed range). The pump would need to be tested in the speed range outlined in HI 40.6, and would be rated at the appropriate pole speed.
• How many pumps do I need to test to calculate the Pump Energy Index for submittal to DOE?

  HI Committee Response:

  • As required in 10 CFR §429.11 (b), the minimum number of units tested shall be no less than two.  The representative value for the sample tested is determined as outlined in §429.59 (a).   Exceptions are listed in 10 CFR §429.11 (b.1 and b.2).

  DOE Response:

  •  DOE requires testing of a sample of sufficient size, but not less than 2 distinct units, to determine that the population of pumps in a basic model meets the standards.  DOE provides the statistical formulas to make the determination of how many units to test (if >2 is needed) and the “best” possible rating given a particular sample.  10 CFR 429.59(a). The test procedure in Appendix A to 10 CFR Subpart Y is to be applied to a single unit.  Each unit in the sample must be tested per the test method.  The test procedure allows manufacturers to determine the test result for each unit in that sample using either a “testing” method or a “calculation” method.  Both methods require some testing of a physical unit.   Next you take the test results from each of the tested units (the final values coming out of the TP) and apply the statistics in 429.59(a) to determine your permissible ratings for the basic model (or decide to do additional testing to increase your sample size/improve your permissible rating).

Test Procedure FAQs

• Does supply power to the motor need to be within the Test Procedure spec if a torque meter is being used to determine pump power input?
  • The supply power specifications need to be adhered too if sections IV or VI are used as well as if section III, V or VII is used and a calibrated motor is used to determine pump power input.
  • When using a torque meter to determine pump power input, the determination is independent of the power supplied to the motor; therefore, the power supply specifications are not applicable.
• As specified in HI 40.6, if the pump is not being tested with a calibrated motor but a dyno or torque meter, must the pump be operated for 20 min before data collection?

  HI 40.6 states “Allow the pump to operate at the expected BEP rate of flow for a minimum of 20 minutes (to allow for warm up and break-in for the driver and other mechanical equipment)”.  This statement is not specific to the motor; therefore, it applies to testing with dynamometer, torque meter or calibrated motor.

• Can you elaborate on the Maximum Permissible Measurement Device Uncertainty section 40.6.3.2.3? Is there a certain method prescribed by HI standards to calculate the total system uncertainty? For example, given the sensor accuracy and the data acquisition device accuracy, is the total measurement accuracy (uncertainty) the root mean square of the two?
  • The values in 40.6.3.2.3 are the overall uncertainty for the quantity measured, including the entire system used to make that measurement.  HI 40.6 does not indicate a specific method to determine the measurement device uncertainty.
  • HI understood that guidance on this would be beneficial, so appendix G covering uncertainty was included in HI 40.6-2016.  In appendix G the square root of the sum of the squares of all the uncertainty values is prescribed
• In HI 40.6 the actual measurement of BEP must be within 5% of expected BEP for the test to be valid. Does this 5% margin also apply to the 50%, 60%, etc. measured points as well?

  HI 40.6 states that the other required flow points are approximate and does not give a tolerance requirement.

• How is the motor power determined for the default loss calculations? Specifically if the pump power falls between standard motor sizes?
  • For section III tests (Bare pump) the motor power selected for the default losses is based on the 120% of BEP rate of flow pump input power, determined in accordance with the DOE test procedure (reference Section III.E.1.1 of appendix A).  If this power is between the standard motor sizes in 10 CFR 431.25 the next larger size motor is selected.
  • For ST bare pumps, determine the motor horsepower by selecting the horsepower rating listed in Table 2 of appendix A of subpart Y that, is either 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 divided by a service factor of 1.15.
  • If a Non-NEMA frame motor is used with the pump, it must be tested in a wire-to-water configuration per section IV or VI of the uniform test procedure (Appendix A of Subpart Y to 10 CFR 431).
• Does the HI definition of “Clear water” in HI 40.6.5.5 conflict with the DOE definition of “Clean water pump” in Subpart Y of 431.462?
  • These definitions are not in conflict with each other because:
    • The HI definition of clear water defines the fluid that must be used when testing a pump
    • DOE’s definition of clean water pump defines the design intent of the pumps that are subject to the test procedure and standard.
• What αi values should be used when testing pumps with BEP at runout?

  DOE Response: Per Appendix A section I.D.4:  α_i = 0.947 for 65 percent of the BEP flow rate, 1.000 for 90 percent of the BEP flow rate, and 0.985 for 100 percent of the BEP flow rate. In addition, DOE notes that I.D.4(3) applies only to the pump power input load points (with which the alpha values are associated), not to the calculation of Ns or η_pump,STD.

• The regulation says: “Perform all calculations using raw measured values without rounding. Round PERCL and PERVL to three significant digits, and round PEICL and PEIVL values, as applicable, to the hundredths place (i.e., 0.01).” Microsoft Excel only stores 15 significant figures, is this acceptable to satisfy the first sentence?

  HI believes the figure resolution in Microsoft excel is sufficient.

If you have a question related to scope or compliance, use the content here as a guide only and submit your specific question to the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B

Address: 1000 Independence Avenue SW., Washington, DC, 20585-0121
Phone: 202-287-1692

If you have a question related to scope or compliance, use the content here as a guide only and submit your specific question to the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B

Address: 1000 Independence Avenue SW., Washington, DC, 20585-0121
Phone: 202-287-1692