Frequently asked questions related to the DOE Energy Conservation Standard and Test Procedure for certain clean water pumps

    • 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
      Contact DOE

      The responses to the frequently asked questions were reviewed by a committee of 10 HI members, partners and staff with expertise on the subject.

      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.

      Submit additional questions


      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

    • 1)    Where can I get a copy of the final rule?
      2)    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).
      3)    Will there be a common directory to review where distribution curves and percentile rankings can be determined?
      4)    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 PEICL/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 and it can be sold with different motors and/or controls with the same PEI ratin
      • 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.
      5)    Is the PERSTD 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.  
      6)    Will the PERSTD 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.
      7)    DOE provided an Excel spreadsheet for PEICL and PEIVL 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 www.pumps.org/doerulemaking.
    • Scope

    • 1)     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 at: http://www.pumps.org/DOE_Pumps.aspx
      2)     Are BB1 pumps covered under the definitions of in-line pumps?
      • BB1 type pumps are excluded from the regulation.  HI believes the intent of the regulation was to include only overhung impeller pumps. Between bearing pumps were not intended to be within scope nor were they included in the performance data survey in the consideration of standards levels.
      • Between Bearing Pumps (BB1, horizontal (axially) split case) serve a different utility than inline pumps because they are equipped with double entry “suction” impeller to improve the suction performance or Net Positive Suction Head (NPSH) characteristics for a given flow rate.

           To improve the definition of inline pump to meet the intent of the negotiation, HI suggests the following modified definition of Inline pump and the
           additional definition of overhung impeller.

      • Inline pump definition from uniform test procedure: In-line pump means a pump that is either a) a twin-head pump, or b) a single-stage, overhung impeller, 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 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 include, but are not limited to, pumps complying with ANSI/HI nomenclature OH3, OH4, or OH5, as described in ANSI/HI 1.1-1.2–2014, within the specified horsepower range
      • Overhung Impeller means the impeller is mounted on the end of a shaft that is cantilevered or “overhung” from the bearing supports.
      3. 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 such as
        • 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)
      4)     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.
      5)    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 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.
      • In the Test Procedure Notice of Proposed Rule, “DOE notes that, when determining whether a given pump would satisfy the definition of clean water pump, DOE would consider marketing materials, labels and certifications, equipment design, and actual application of such equipment.” 
      6)     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. 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.
      7)    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 questions 5 and 6. 
      8)    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. 
      9)     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.
      10)     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?
      • Yes the entire offering would be excluded.
      • The scope criteria for clean water pumps are defined by the number of stages for testing (3 for RSV & 9 for ST).  HI does not believe that a 9 stage ST or 3 stage RSV pump that exceed 200 shaft horsepower or 459 ft of head at the best efficiency point would 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.

      11) I have a question regarding the DOE regulations and my company's line of vertical pumps; specifically, if our pumps fall under the regulations?  We have heard conflicting information regarding if they do or do not fall under the regulations, and would appreciate clarification. 

      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. This seems to me to fall in the category of ESFM pumps, which are covered under the regulations. However, one of the other engineers has heard otherwise.  Is there any specific exemption for this style of pump or does it too fall under the DOE regulations?

        HI does not believe that VS4 and VS5 pump types were included in the data survey that underpins the standard levels and they were not intended to be within scope.  VS4 and VS5 pumps have construction differences that could result in higher PEI values than the OH1, OH2 and OH7 pump types that were intended to be within scope.  As currently written the ESFM definition is vague and could include the VS4 and VS5 pump types, which HI does not believe was the intent of the ASRAC negotiations.  HI proposes a change to the ESFM definition as indicated below in underlined text to clearly exclude VS4 and VS5 pumps.

         

        End suction frame mounted/own bearings (ESFM) pump means a mechanically-coupled, dry rotor, end suction 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 where the bare pump is not submerged in the pumped liquid and that is not a dedicated-purpose pool pump. Examples include, but are not limited to, pumps within the specified horsepower range that comply with ANSI/HI nomenclature OH0 and OH1, as described in ANSI/HI 1.1-1.2-2014.

         
        1. 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.
        2. 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.
        3. 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.
        12) 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.
      1. Compliance

      2. 1)    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.
        2)     When will the certification template be made available?
        • HI is does not know when DOE will make the template available.  It would be of significant benefit to the pump manufacturing industry if the U.S. Department of Energy would make available as soon as possible, the data template for certification.  Releasing the certification template, will help ensure that the requirements for certification as outlined in section 429.59 of Subpart B to 10 CFR Part 429 – Certification, compliance, and enforcement for consumer products and commercial and industrial equipment, are understood uniformly across the industry and will lessen the chance that the certification requirements are misunderstood.
        3)    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  

        4)    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?
        • 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
        5)    Does a manufacturer have to have their test lab certified?
        • The DOE regulation does not require an approved laboratory.
        6)    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.
        7)    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.
        8)    What model number must be listed on the pump nameplate?
        • The regulatory text at § 431.466 (a) (1) (ii) indicates the “bare pump model number” is required on the pump nameplate.  
        • § 429.12 General requirements applicable to certification reports, requires the basic model number and manufacturer (individual) model number.  
        • Manufacturer's model number means the identifier used by a manufacturer to uniquely identify the group of identical or essentially identical covered products or covered equipment to which a particular unit belongs. The manufacturer's model number typically appears on the product nameplates, in product catalogs and in other product advertising literature.  
        • Per § 429.59 (c) (1) & (2) The manufacturer’s (individual) model number must consist of the bare pump, driver and controls individual model number(s) when applicable or must otherwise provide sufficient information to identify the specific driver model and/or controls model(s) with which the bare pump is distributed
        • The FAQ review committee believes the basic or individual model number should appear on the nameplate as the bare pump model number is not necessarily associated with the published PEI value and may not be able to be traced back to the certification.


        9)    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. 
        10)     How are the representative PEI, flow rate, head and powers to be determined that are submitted for certification?
        • 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
        • 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.
        • HI has requested that DOE provide a specific method to be followed for the industry to review and comment on.
        11)    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.
        12)    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 (PEICL).
        • Labeling requirements are shown in Table VI.1.
        13)    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.
        14)     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  
        15)    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.
        16)     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.
        17)     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.
        18)    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.
        19)    If the distributor wants to update the PEI for a previously rated pump and become the manufacturer can they?
        • HI believes that a distributor can choose to become a “manufacturer” when they add a driver or control to a previously rated pump.
        • 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.
        20)    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.
        21)     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?
        22)    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.
        23)     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.
        24)    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 0.965).  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.
        25)    If we have a pump that 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)?
        • Because ESFM and ESCC pumps are different equipment categories, you would need to certify compliance of the “wet end” in both configurations for rating and certification with DOE.
        • 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. 
        26) 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.

        27) 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?
        • The review committee understands this is how a significant amount of pumps are sold and the DOE regulation does not provide clear guidance on what the OEM should do in this case.  In the case that the OEM does not know how the pump end kit will be distributed in commerce, the committee recommends labeling the pump end kit as the basic model with the highest PEI listed with the DOE. 
        28) 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.
        29) 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.
        30) 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.

        31) For pumps that are privately labeled who is responsible for certifying the privately labeled brands with DOE?

        A: §429.12 outlines the general requirements applicable to certification (reference compliance FAQ 3).  Within §429.12 some of the general requirements DOE lists are:

        (a) 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).

        (b) 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).

        (1) Product or equipment type;     

        (2) Product or equipment class (as denoted in the provisions of part 430 or 431 of this chapter containing the applicable energy conservation standard);

        (3) Manufacturer's name and address;

        (4) Private labeler's name(s) and address(es) (if applicable);

        (5) Brand name;

        (6) 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.

      3. Test Procedure

      4. 1)     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.
        2)    As specified in HI 40.6-2014, 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 40.6-2014 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.
        3)    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?
        4)     In HI 40.6-2014 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 40.6-2014 states that the other required flow points are approximate and does not give a tolerance requirement.
        5)    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).
        6)     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.
        7)    What αi values should be used when testing pumps with BEP at runout?
        • HI believes that the following equivalent “αi” values are used when a pump cannot be tested to 120%
        • No test flow limitation
          Pump cannot be tested out to 120% of BEP
          Load Points “i”
          α
          Load Points “i”
          α
          75% BEP
          0.947
          65% BEP
          0.947
          100% BEP
          1
          90% BEP
          1
          110% BEP
          0.985
          100% BEP
          0.985
        • The regulatory text is provided below.  Note the highlighted word “instead” which HI believes to mean that manufacturer should substitute “α” values directly 65% for 75%, 90% for 100% and 100% for 110%.
        • Regulatory Text:  To determine PERCL and PERSTD, use load points of 65, 90, and 100 percent of the BEP flow rate determined with the modified flow points specified in this section I.D.4 of this appendix instead of 75, 100, and 110 percent of BEP flow.
        8)    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