Pump efficiency regulations and labeling in the USA Greg Towsley

Abstract Currently no energy conservation standards for commercial and industrial pumps exist in the United States of America (USA). However, the Department of Energy (DOE) of the USA has had the authority to issue energy conservation standards, test procedures and labeling requirements for commercial and industrial pumps since the Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94-163). In June 2011, the rulemaking process to establish standards, procedures and labeling requirements for commercial and industrial pumps began. It is expected that by the end of 2015, DOE will have published a Final Rule for efficiency standards and a pump test procedure. This paper will discuss actions and industry standards that provide the basis supporting requirements of regulatory efficiency and test procedure rules for commercial and industrial pumps in the USA. The paper will also analyze potential effects on the USA market. In addition, a bridge to a USA initiative for industry collaboration developing voluntary measures that accelerate high performance extended pump product adoption in the market will be explained. Introduction

The overall regulatory landscape related to pumps in the United States of America (USA) is limited. Those regulations that do exist primarily deal with personal safety. For those types of regulations, third party organizations exist to develop safety standards for pumps related to the integration of pumps with electrical motors, or with the pump materials that may come in contact with liquids for human consumption. These organizations also provide the associated testing and certification that provides the public with likely safer equipment and peace of mind. Example of the organizations include Underwriters Laboratories Inc. (“UL”), Intertek Group plc, and NSF International. Standards related to the design and construction of pumps are developed by the primary trade association of manufacturers of pumps in North America, Hydraulic Institute (HI). Specific end use markets or applications may also develop design and construction standards that provide for specific needs for that market. Pumps used in the petroleum industry are designed to the American Petroleum Institute standard API-610. Pumps used in chemical process plants are typically designed to ANSI/ASME B73 standards. Fire pumps will be designed to meet National Fire Protection Association NFPA 20. While these design standards exist, no national regulations exist that require pump buyers to require pumps designed to those standards. The market is somewhat self-regulating in requiring pumps of those design standards, as buyers are involved in the development of the standards. Building codes provide a method of regulating the selection, application and control of pumps into buildings, primarily for commercial use. The building codes will reference other existing safety standards or how the pumps are applied to a pumping system. It is up to the local jurisdiction to insure that the codes and standards are being complied with during building construction. For many USA government funded infrastructure projects, a requirement of “Buy American” can be incorporated into the project. If an American-made pump product cannot be found for the service, and waiver can be obtained for non-domestic manufactured projects. In the state of Pennsylvania, there is a strict requirement in their Steel Products Procurement Act that any products, or pumps in this case, that are to be purchased and installed in state or state-funded projects, must have a certain percentage of raw materials that came from Pennsylvania steel mills and foundries. Pump Efficiency Regulations As of the writing of this publication, no energy conservation standards for commercial and industrial pumps exist in the USA. However, Title III of the Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94-163), as amended (42 U.S.C. 6291 et seq.) [1], established an energy conservation program for certain commercial and industrial equipment. This program, as set forth in Part C of Title III

of EPCA, includes pumps as covered equipment and authorizes DOE to issue standards, test procedures and labeling requirements for them (42 U.S.C. 6311(1)(A)). More specifically, the law states that the DOE has the authority to regulate energy conservation standards and test procedures for covered industrial equipment which includes “electric motors and pumps” [2]. On 13 June 2011, the Office of Energy Efficiency and Renewable Energy, within the DOE, published a notice in the Federal Register, requested information regarding product markets, energy use, test procedures, and designs for energy efficiency for commercial and industrial pumps. This request for information from the DOE officially began the process for the energy conservation standards and test procedure rulemakings. Department of Energy Rulemaking Process Overview During the process of setting standards, EPCA requires the DOE to consider seven factors during their analysis in an attempt to insure that the standards are achievable and economically defensible [3].

1. Economic impact on consumers and manufacturers 2. Lifetime operating cost savings compared to increased equipment cost 3. Total projected energy savings 4. Impact on utility or performance 5. Impact of any lessening of competition 6. Need for national energy conservation 7. Other factors the Secretary considers relevant

To meet the requirements of EPCA, the DOE will complete various types of analysis that correspond to the factors. The analyses include screening of design options, engineering, life-cycle costs, and impact on the manufacturers, energy savings, consumer economics, emissions, and employment.

The rulemaking process consists of two parallel processes: Energy Conservation Standards and Test Procedure. While these two processes are separate, the timing of them, and their inherent activities, are integral. The Test Procedure process may take up to 1.5 years within the total approximate 3 year process of the Energy Conservation Standard. Initial Preliminary Rulemaking Timeline In February 2013, the DOE communicated that the planned pump rulemaking schedule would be as shown in Figure 2 below.

Figure 1 Standards and Test Procedure Process Overview

Figure 2 The Initial Planned Pumps Rulemaking Schedule

Framework Document The first step in DOE’s standards development process is issuing a Framework Document. The purpose of the Framework Document is to communicate to all interested stakeholders the process and analyses that the DOE will use to develop new energy conservation standards for pumps. It is intended to be the initial starting point of discussions and to communicate the DOE’s initial understanding of the market and potential path forward for the standards and test procedure. The DOE announced in the Federal Register that the Framework Document was available on 1 February 1 2013 [4]. The DOE held a public meeting on 20 February 2013 in Washington, DC to provide further information about the process and to take questions from industry stakeholders. Among other information, they had advised that all documents and public communications could be found in the future at a summary document location on a government web site [5]. In the instance of the pumps rulemaking, the Framework Document provided information on the scope of coverage DOE is considering for the initial standard, communicate their understanding of equipment definitions, discuss the various metrics used to describe pump efficiency, and communicate test procedure methods that the DOE found that could be used to measure pump efficiency. The desire of the DOE with the Framework Document is to engage stakeholders in the process early and to get comments on their approach and potential issues. Preliminary Analysis From the feedback that the DOE receives from the Framework Document and subsequent investigative meetings that are held with stakeholders of the process, a technical support document is created that provides a preliminary analysis by the DOE that includes analysis on:

o An engineering analysis on potential design options that could increase pump efficiency o Profitability of the products within the value chain of the pump products (markups) o Energy consumption of pump products in scope o Consumer life-cycle cost (LCC) and payback period for product changes and energy

savings o Unit shipment for products in scope o Impacts on national energy savings, consumer net present value, and the

manufacturers o Discussion of comments received in response to the Framework Document

A public meeting would be held after the technical support document for the Preliminary Analysis is made available. The DOE encourages interested stakeholders to provide further comments to the Preliminary Analysis.

Notice of Proposed Rule (NOPR) After a period of time to review the comments received from the public and stakeholders on the technical support document of the Preliminary Analysis, the DOE modifies assumptions used in the process, adjusts the proposed standard accordingly, and revises the various analyses conducted. The DOE will then provide a notice in the Federal Register about the availability of a Proposed Rule, and will have an accompanying public meeting. The Proposed Rule will include the scope of the products covered and the standard levels. As with the Framework Document and the technical support document for the Preliminary Analysis, the DOE encourages additional comment and feedback from stakeholders of an efficiency standard on pumps. Final Rule Based on the comments and feedback received from the stakeholders from the Proposed Rule in the process’ previous step, the DOE will consider all written and verbal (from public meetings) input. That input will be used in preparing the Final Rule by revising all analyses on impacts, determining the efficiency levels standards that will be adopted, and establishing a date for compliance for standards adoption. Upon development of the Final Rule, the availability will be communicated in the Federal Register. It must be noted that the typical DOE rulemaking process includes a concurrent activity of announcing a proposed testing procedure prior to releasing the technical support document for the Preliminary Analysis, and releasing the Final Rule for the test procedure before the notice of Proposed Rule. Appliance Standards and Rulemaking Federal Advisory Committee The Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) was established by the Appliance and Equipment Standards Program within the DOE [6]. The intent of the Committee, consisting of interested stakeholders to the equipment being considered for energy efficiency standards, is to negotiate recommendations to be incorporated into a Final Rule. The negotiating stakeholders meet to attempt to reach consensus recommendation through discussions about information about the equipment to be regulated and to gather data to be used in analysis. The recommendations obtained through consensus by a subcommittee and the primary Committee are forwarded to the DOE with the desire for the recommendations to be included into the Final Rule. It is the expectation of DOE that recommendations from ASRAC will be more acceptable to the entire stakeholder population of the equipment to be regulated and that the efficiency standards will be implemented at earlier dates than under the typical rulemaking process. On 23 July 2013, as communicated in the Federal Register, ASRAC provided a notice on the intent to establish a working group to negotiate recommendations for energy conservation standards for pumps [7]. As announced on 12 November 2013 [8], the membership of the working group was established and later, a series of meetings to develop recommendations were identified. The working group consisted of representation from the DOE and the primary ASRAC committee, as well as representatives from pump manufacturing sector, electric motor manufacturing sector, energy efficiency advocacy, utility sector, and the pump end user sector. During multiple sets of meetings held from December 2013 through June 2014, the working group met to discuss and negotiate recommendations for the Final Rule. During the entire period of meetings, the DOE provided information on recommended metrics and analysis based on data provided to them from stakeholders within the industry. The outcome of multiple meetings of the working group through June 2014 was a term sheet of recommendations that were forwarded to ASRAC [9]. These recommendations were later approved by the full ASRAC committee and forwarded to DOE, with the hope of being incorporated into the Final Rule. The recommendations established by consensus of the work group are summarized as follows:

1. Covered product definition • ‘Pump’ is a device that moves liquids (which may include entrained gases, free solids,

and totally dissolved solids) by physical or mechanical action and includes a bare pump and, if included by the manufacturer, the mechanical equipment, driver, and controls.

2. The components of a ‘pump’ will be defined as below: • ‘Bare pump’ is a ‘pump’ excluding mechanical equipment, driver, and controls. • ‘Mechanical equipment’ is any component that transfers energy from the driver to the

bare pump. • ’Driver’ is the machine providing mechanical input to drive the bare pump directly or

through the mechanical equipment, and may include an electric motor, internal combustion engine, or gas/steam turbine.

• ‘Controls’ means any device that can be used to control the driver. 3. For this first initial DOE energy conservation standard for pumps, it is recommended that the

metric will not cover non-electric drivers. The test procedure will specify that the bare pump rating calculations for the energy conservation standard also apply to pumps with non-electric drivers.

4. The ASRAC working group recommended that the scope of this initial rulemaking should include the following pump types (DOE designation/Hydraulic Institute designation). It should be noted that these pump types are the same as was covered in the initial European Commission regulations for energy efficient pumps.

• End suction frame mounted/own bearings (ESFM/OH0, OH1) • End suction close coupled (ESCC/OH7) • Inline (IL/OH3, OH4, OH5) • Radial split (multistage) vertical (RS-V/VS8) • Vertical turbine submersible (VT-S/VS0)

5. Ensuing standard development activities • Circulators (CP1, CP2, and CP3 as defined by Hydraulic Institute) should not be

included in the initial rulemaking. Recommendations for energy conservations standards for circulators should be developed through an additional informal negotiation between manufacturers, efficiency advocates, and other stakeholders. March or April 2015 was targeted for the stakeholders to present a joint proposal to the DOE. An ASRAC negotiating working group would began following the presentation of the proposal to DOE. A date of September 2015 was targeted for a Notice of Proposed Rule for an energy conservation standard for circulators.

• A separate rulemaking on dedicated-purpose pool pumps should begin by the end of calendar year 2014.

6. The ASRAC working group recommended that specific types of pumps be excluded in this initial rulemaking.

• Positive displacement pumps • Axial/mixed flow pumps • Horizontal split case, double suction pumps • Multistage axially split pumps • Multistage radial split-horizontal pumps • Multistage radial split vertical immersible pumps • Vertical turbine (non-submersible) pumps

7. The ASRAC working group intended that the initial rulemaking be for pumps in clean water applications. As the DOE cannot regulate applications, only covered products, additional pumps that are designed for specific applications were recommended to be excluded from the initial rulemaking.

• Wastewater, sump, slurry, solids handling • API-610 pumps • ASME/ISO chemical pumps • Fire pumps that are compliant with NFPA 20 and UL listed or FM approved • Self-priming pumps • Prime-assisted pumps • Nuclear pumps that comply with ASME Boiler and Pressure Vessel Code Section III or

10 CFR 50

• “Navy” pumps that are MIL Specification Compliant (MIL-P-17639, MIL-P-17881, MIL-P-17840, MIL- P-18682, MIL-P-18472)

• “Sanitary” or “hygienic” pumps that are typically used in food processing and pharmaceutical applications. Certifications for hygienic or sanitary products include, but are not limited to 3-A Sanitary Standards, EHEDG (European Hygienic Equipment Design Group) recommendations, or QHD (Qualified Hygienic Design)

8. It was recommended that this rulemaking will be limited to pumps with the following characteristics:

• Driver size of 1-200 horsepower (0.75-150 kW), based on the shaft power at the best efficiency point (BEP) for the full impeller diameter

• Capacity rating of 25 gallons per minute (5.7 cubic meters per hour) and greater, based on the flow at BEP for the full impeller diameter

• Total pump head of 459 feet (140 meters) maximum at BEP for the full impeller diameter)

• Design temperature range from -10 to 120 degrees C • Pumps designed for nominal 3600 or 1800 rpm driver speeds • 6-inch or smaller bowl diameter for vertical turbine submersible pumps

Additional requirements recommend that the pump certified rating for a given model should be based on testing at full impeller diameter. Pump models that otherwise meet all the above characteristics will not be excluded on the basis of having a trimmed impeller. Full impeller means the largest impeller diameter offered for sale for a given model.

9. The pump test procedure is recommended to be based in accordance with HI Standard 40.6 for determining bare pump performance.

10. The metric for assessing compliance with the standard should be the Pump Energy Index (PEI), which is constructed based on values for a given pump model’s Pump Energy Rating (PER). A PEI could be developed for a pump applied with constant speed, PEICL, and a pump applied with a variable speed, PEIVL. The PEI is found by the ratio of the PERCL and PERVL of a particular pump model and its rating at the full impeller diameter, to the PERCL for a minimally compliant pump (PERSTD) with the same hydraulic load, as shown in Table 1.

The Pump Energy Rating (PER) CL and VL used in the PEI is an equally weighted average electric input power to the ‘pump’ measured or calculated at the driver input or, when present, controls input, over a specified load profile:

Table 1 Summary of Proposed Metrics [10]

Pump Energy Index Constant Load Pump Energy Index (PEICL) (uncontrolled)

Variable Load Pump Energy Index (PEIVL)

(with motor and controls)

Ratio 𝑃𝑃𝑃𝑃𝑃𝑃𝐶𝐶𝐶𝐶 = � 𝑃𝑃𝑃𝑃𝑃𝑃𝐶𝐶𝐶𝐶𝑃𝑃𝑃𝑃𝑃𝑃𝑆𝑆𝑆𝑆𝑆𝑆

� [1] 𝑃𝑃𝑃𝑃𝑃𝑃𝑉𝑉𝐶𝐶 = � 𝑃𝑃𝑃𝑃𝑃𝑃𝑉𝑉𝐶𝐶𝑃𝑃𝑃𝑃𝑃𝑃𝑆𝑆𝑆𝑆𝑆𝑆

� [2]

Pump Energy Rating (PER) 𝑃𝑃𝑃𝑃𝑃𝑃𝐶𝐶𝐶𝐶 = ∑ 𝜔𝜔𝑖𝑖(𝑃𝑃𝑖𝑖𝑖𝑖𝑖𝑖)𝑖𝑖 [3] 𝑃𝑃𝑃𝑃𝑃𝑃𝑉𝑉𝐶𝐶 = ∑ 𝜔𝜔𝑖𝑖(𝑃𝑃𝑖𝑖𝑖𝑖𝑖𝑖)𝑖𝑖 [4]

PER Load Profile i = 75%, 100%, 110% of BEP flow at nominal speed for uncontrolled

pumps

i, for VL = 25%, 50%, 75%, and 100% of BEP flow at

nominal speed for pumps sold with motors and controls

PERSTD PERCL for Minimally Compliant Pump of the same equipment class serving the same hydraulic load

Applicable Pump Configurations

Pumps sold without continuous or non-continuous controls

Pumps sold with continuous or non-continuous controls

Where: • ωi = weight at each load point i • Pini = power input to the “pump” at the driver, inclusive of the controls if present, (hp) • i = Percentage of flow at the BEP of the pump

Note: All formulas have been developed for typical units used in the USA at 60 Hz. Conversion to metric units and 50 Hz is not being considered.

For the equations shown in Table 1 above, PERSTD can be expanded as:

𝑃𝑃𝑃𝑃𝑃𝑃𝑆𝑆𝑆𝑆𝑆𝑆 = 𝜔𝜔75% �𝑃𝑃𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻,75%

0.95×𝜂𝜂𝑝𝑝𝑝𝑝𝑝𝑝𝑝𝑝,𝑆𝑆𝑆𝑆𝑆𝑆+ 𝐿𝐿75%�+ 𝜔𝜔100% �

𝑃𝑃𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻,100%

𝜂𝜂𝑝𝑝𝑝𝑝𝑝𝑝𝑝𝑝,𝑆𝑆𝑆𝑆𝑆𝑆+ 𝐿𝐿100%� +

𝜔𝜔110% �𝑃𝑃𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻,110%

0.985×𝜂𝜂𝑝𝑝𝑝𝑝𝑝𝑝𝑝𝑝,𝑆𝑆𝑆𝑆𝑆𝑆+ 𝐿𝐿110%� [5]

And 𝜂𝜂𝑝𝑝𝑝𝑝𝑝𝑝𝑝𝑝,𝑆𝑆𝑆𝑆𝑆𝑆 = −0.85 × 𝑙𝑙𝑙𝑙(𝑄𝑄100%)2 − 0.38 × 𝑙𝑙𝑙𝑙(𝑁𝑁𝑁𝑁) × 𝑙𝑙𝑙𝑙(𝑄𝑄100%)− 11.48 × 𝑙𝑙𝑙𝑙(𝑁𝑁𝑁𝑁)2 +

17.80 × 𝑙𝑙𝑙𝑙(𝑄𝑄100%) + 179.80 × 𝑙𝑙𝑙𝑙(𝑁𝑁𝑁𝑁) − (𝐶𝐶 + 555.6) [6] Where:

• Ns = the specific speed at 60 Hz, • Q = the flow rate of the pump at BEP in GPM, • C = constant which is set based on the speed of rotation of the pump, and the pump

equipment class

ηpump, STD is a similar formula utilized in the EuP regulations for energy conservation standards for pumps in the European Union. Expanding on Equation [1]:

𝑃𝑃𝑃𝑃𝑃𝑃𝐶𝐶𝐶𝐶 = �13×�𝑃𝑃𝑖𝑖𝑖𝑖75%+𝐶𝐶75%�+

13×�𝑃𝑃𝑖𝑖𝑖𝑖100%+𝐶𝐶100%�+

13×�𝑃𝑃𝑖𝑖𝑖𝑖110%+𝐶𝐶110%�

𝑃𝑃𝑃𝑃𝑃𝑃𝑆𝑆𝑆𝑆𝑆𝑆� [7]

Expanding on Equation [2]:

𝑃𝑃𝑃𝑃𝑃𝑃𝑉𝑉𝐶𝐶 = �14×�𝑃𝑃𝑖𝑖𝑖𝑖25%+𝐶𝐶25%�+

14×�𝑃𝑃𝑖𝑖𝑖𝑖50%+𝐶𝐶50%�+

14×�𝑃𝑃𝑖𝑖𝑖𝑖75%+𝐶𝐶75%�+

14×�𝑃𝑃𝑖𝑖𝑖𝑖100%+𝐶𝐶100%�

𝑃𝑃𝑃𝑃𝑃𝑃𝑆𝑆𝑆𝑆𝑆𝑆� [8]

Pini are the values of the tested input electrical power to the pump (speed x torque) or driver (motor or control) at each load point i. It must be noted that the proposed PERCL and PERVL calculations require assumptions for part load motor performance. Analysis by the DOE developed a conservative equation to provide fractional motor losses at each load point i (Li) that are calculated as the rated full load motor losses (Lrated) multiplied by the part‐load loss factor (yi), which is calculated as a cubic polynomial of the load fraction on the motor (xi) that is used in the PEI calculations [11]. At the time of publication of this paper that equation with its coefficients is:

𝐿𝐿𝑖𝑖 = 𝐿𝐿𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 × �−0.4508 × � 𝑃𝑃𝑖𝑖𝑀𝑀𝑀𝑀𝑟𝑟𝑀𝑀𝑟𝑟𝑆𝑆𝑖𝑖𝑀𝑀𝑟𝑟

�3

+ 1.2399 × � 𝑃𝑃𝑖𝑖𝑀𝑀𝑀𝑀𝑟𝑟𝑀𝑀𝑟𝑟𝑆𝑆𝑖𝑖𝑀𝑀𝑟𝑟

�2

+ (−0.4301) ×

� 𝑃𝑃𝑖𝑖𝑀𝑀𝑀𝑀𝑟𝑟𝑀𝑀𝑟𝑟𝑆𝑆𝑖𝑖𝑀𝑀𝑟𝑟

� + 0.6410� [9]

Where:

• Li = the fractional load loss of the motor at load point i (hp); • Lrated = the rated full load motor losses as determined in accordance with the DOE test

procedure for motors at 10 CFR 431 subpart B (hp); • yi = the part‐load loss factor; • xi = the load fraction for the motor at each load point i; • Pi = the shaft input power to the bare shaft pump (hp); • MotorSize = the nominal rated output power of the motor (hp); and • i = Percentage of flow at the best efficiency point (BEP) of the pump.

11. It was recommended that the energy conservation standards will set the index at PEI 25 for

pumps designated by the DOE as ESCC, ESFM, IL, and VT-S pumps in both 1800 and 3600 rpm speeds. This index has been calculated through DOE analysis to remove approximately 25% of the least efficient pumps sold in the USA market. For pumps designated by the DOE as RS-V, the PEI and energy conservation standards should be set to harmonize with the European Union No 547/2012 MEI 40 level, with the intent that no models known to pass the EU standard would fail the US standard. By consensus agreement of the working group, it was recommended that the compliance date to the energy conservation standards for all equipment classes will be four (4) years from the publication of the Final Rule.

12. A basic labeling configuration was recommended by the ASRAC working group. The pumps should include the information below on the pump nameplate for the configuration in which they were sold.

Table 2 Recommended Labelling Information by Sold Configuration

Bare Pump Bare Pump + Motor Bare Pump + Motor + Controls PEICL Model number Impeller diameter for each unit

PEICL Model number Impeller diameter for each unit

PEIVL Model number Impeller diameter for each unit

13. To support the DOE's certification and compliance activities, it was recommended that

specific data determined from the required test procedures be included in a DOE-maintained database. It was agreed by consensus that the follow information be included in that database for each certified pump. • Manufacturer name • Model number(s) • Equipment class • PEICL or PEIVL as applicable • BEP flow rate and head • Rated speed

• Number of stages tested • Full impeller diameter (in.) • Whether the PEICL or PEIVL is calculated

or tested • Input power to the pump at each load

point i (Pini)

14. Certification for the pump types that the DOE has designated as RS-V and VT-S pumps should be based on testing the same number of stages as has been included in the EU pump efficiency regulations. If a pump model is not available with that specific number of stages in the given scope, the model would be tested and certified with the next closest number of stages offered for sale by the manufacturer. If only fewer than the required number of stages are available, the testing and certification should be with the highest number of stages offered for sale to the market for that pump model. If only more than the required number of stages are available, the testing and certification should with the least number of stages offered for sale to the market for that pump model. • RS-V: 3 stages • VT-S: 9 stages

Example of the Effect of High Efficiency Motors and Control Technology on the PEI The PEI methodology to reduce the energy consumption of pumps has been developed to provide manufacturers various opportunities for solutions to the market. Simply improving the hydraulic performance of the pump itself can provide an acceptable PEI that would allow the pump to be sold in the USA. The addition of a more efficient motor, with or without controls, can improve the PEI of a bare pump, allowing it to be sold into the market only with those components. Table 3 provides examples of outcomes to a bare pump with less than adequate performance. Alternative to the calculation, similar or improved outcomes could be expected from testing the pump with a motor different than the regulated minimum efficient allowed by federal regulations or with controls.

Table 3 Examples of Calculated PEI for Various Configurations

ESCC, 1800 rpm

Bare Pump,

Baseline

Bare Pump, Improved

Hydraulics

Bare Pump, Baseline + High

Eff. Motor

Bare Pump, Base Line +

Motor + Controls

Q, gpm 1845 1845 1845 1845

H, feet 70 70 70 70

Pump Efficiency 79 83 79 79

Pump input power (hp) 41.32 35.28 41.32 41.32

Motor Efficiency, Minimum 94.50 94.50 96.80 94.50

PEICL/VL 1.02 0.99 0.99 0.46 PASS/FAIL FAIL PASS PASS PASS

Status of USA DOE Rulemaking for Commercial and Industrial Pumps Test Procedure NOPR On 13 March 2015, the Department of Energy issued a pre-publication NOPR and announcement of a public meeting regarding test procedures for commercial and industrial pumps [12]. The public hearing on the NOPR was held 29 April 2015 in Washington, DC. This proposed rule will establish definitions and a test procedure that will be used for pumps, inclusive of motors and controls if applicable, and energy conservation standards that will be established. The DOE concurs with ASRAC that the HI Standard 40.6-2014 shall be the basis of their test procedure with minor modifications related to excluding specific reference found in HI 40.6, sampling and data collection, additional requirements for test consistency and repeatability, normalization of pump shaft input power at the specified flow rates, and equipment used to measure “wire-to-water” power consumption of a pump tested with a motor and variable speed drive. They also agree with the use of a Pump Energy Index (PEI) metric included in the ASRAC recommendations. The test procedure proposed by the DOE includes methods for determining the PEI for pumps sold with or without motors and controls, by use of physical testing or calculation methods. The proposed rule for the test procedure also includes a sampling plan that would follow their minimum requirements of two units of a specific model. The public comment period for the test procedure was closed on 15 June 2015. Energy Conservations Standards for Pumps NOPR On 17 March 2015, the Department of Energy issued a pre-publication NOPR and announcement of a public meeting regarding energy conservation standards for commercial and industrial pumps [13]. The public hearing on the NOPR was held 29 April 2015 in Washington, DC in conjunction with the public hearing on the test procedure NOPR. As with the information provided with the test procedure NOPR, the proposed standards in the NOPR for the energy conservation standards for pumps have incorporated the consensus recommendations of ASRAC. The proposed rule is in full correlation with the test procedure NOPR. The PEI proposed in the NOPR correlates to values for ESCC, ESFM, IL, and VTS pumps that would not allow those pumps with efficiencies in the lowest 25th percentile to be sold in the United States. The PEI for the RSV pumps would be set a values to harmonize with the standards recently set for the same style pumps in the European Union [14].

In the analysis completed by the DOE, it was found that the proposed standards provided a simple payback period of less than half the estimated average lifetime of the pumps for all of the pumps types within the scope of the NOPR [15]. The DOE also conducted various analyses on the benefits for the United States. They estimate that the energy savings from the standards over a 30 year period beginning with a full year of compliance would be 0.28 quadrillion Btu, which is approximately one percent of the base case energy use of the pumps within scope of the NOPR. The environmental benefits through 2030 amount to a cumulative CO2 reduction of 2.5 Mt, which is equivalent to the annual electricity used by 360,000 homes in the United States. The DOE also concluded that the standards proposed in the NOPR, based on technology that is currently commercially available, is the maximum energy efficiency improvement for pumps the would provide significant energy savings and would be economically justified. A public comment period on the proposed Test Procedure and Proposed Rule was closed on 1 June 2015. After closing of the public comment period, it is expected that the DOE will take an additional 6-8 months to review and consider all of the comments and feedback, and, based on the comments and feedback, revise all analyses on impacts, determine the final efficiency levels standards that will be adopted, and establish a date for compliance for standards adoption. The final action is targeted to be the end of December 2015.

Figure 3 Updated Pumps Rulemaking Schedule

Voluntary labeling Electric utilities in the USA provide nearly $1 billion in demand management incentives that help reduce energy consumption [16]. As pumps have been identified as a top candidate minimum energy-efficiency standards, coordinating the implementation of an informative and useful energy label will support demand management programs that encourage the purchase high efficiency pumps [17]. Industry experience has shown that an informative energy efficiency label will stimulate manufacturers to remove lower efficiency products and to expand efforts to develop more efficient solutions for the market. Currently in the USA, there are no energy labeling requirements for commercial and industrial pumps. California and the Environmental Protection Agency (EPA) have established a labeling scheme for residential swimming pool pumps. With the establishment of energy conservation standards for pumps by the DOE, a simplistic categorical label, as described previously, will communicate how efficient the pump is compared to similar models.

In July 2013, The American Council for an Energy-Efficiency Economy (ACEEE) invited the trade associations, and their members, of the pump industry (Hydraulic Institute, HI), the fan industry (Air Movement and Control Association, AMCA), and the compressor industry (Compressed Air and Gas Institute, CAGI), and organizations from the utility sector that administer energy efficiency programs, to an introductory meeting to propose a collaboration to develop labeling schema for equipment driven by electric motors, inclusive of the motors and applicable controls. The intent of the collaboration is to develop “extended motor product” labels for each type of motor-driven equipment that can be used in utility programs, such as with prescriptive rebate programs or custom programs [18]. An “extended motor product” is considered the electric motor plus the driven equipment, such as pump, fan or compressor, and other controlling equipment, such as a variable speed drive, as depicted in Figure 3. The concept of the “extended motor product” was developed by EUROPUMP, the European Association of Pump Manufacturers. It is planned that the “extended motor product” will also become incorporated into the energy conservation legislation for pump in the Energy Related Products (ErP) Directive. The definition of an extended motor product for pumps used in the collaboration conforms to the recommendations of ASRAC and the proposed rules of the DOE.

Figure 4 - Example of an extended motor product for a pump

ACEEE designated the collaborative effort as the Extended Motor Product Label Initiative (EMPLI). Within EMPLI, three working groups were created for pump, fans and compressors. The membership of the pump working group consisted of a representative of HI, representative of major pump manufacturers (of whom some were also part of ASRAC), and partners from the utility and energy efficiency interests, include the California investor owned utilities, Bonneville Power Administration and National Grid. The objective of the pump working group is for HI to develop a voluntary extended product label that will meet the requirements of the energy efficiency programs that provide incentives to the market to purchase the most efficiency extended motor product available for their application. The EMPLI pump working group meets in person or via teleconferences to develop the label. Since initial meetings at the end of 2013, the pump working group determined that utilizing the DOE proposed metric and test procedure would be the basis of the extended motor product label standard. In addition, the initial focus would be on those pumps that are also within the scope of the proposed regulations from the DOE. Upon development of the label, the members from organizations that have efficiency programs would conduct field studies and analyze the results of energy savings on the concept. Adjustments would be made to the label standard and program, and, eventually, a minimal launch would be initiated. In addition to regular label development meetings, parallel communication and development activities have taken place. The DOE was informed by the EMPLI stakeholders of the activities of the working groups. Reaction from the DOE was positive, as the pump working group label development is

Extended Motor Product

VSD

Motor Pump

Input Power

expected to utilize their regulations and will support the transformation of the market towards increased energy efficiency. In addition, HI established a technical committee whose purpose is to develop and maintain a voluntary label program to support the energy efficiency incentive programs. Their deliverable included developing a program guide, policies and procedures for the program, marketing concepts and tools, and an educational awareness plan for the program. The target for completion of the guide is targeted for Q1 2016. Summary While the United States may be considered lagging to other global regions for regulations on efficiency conservation standards for industrial equipment, activities related to commercial and industrial pumps are moving forward, and at a substantial pace. Energy conservation standards and test procedures for the most commonly used pumps in the USA is targeted for completion by the end of 2015, with a effective date of four years later. In addition, a collaborative effort through EMPLI is developing a voluntary labelling program that will allow the utility sector to establish incentives to more rapidly transform the market to purchasing and operating more efficient pumps and motors. Acknowledgements The author acknowledges the support of John H. White, Jr. and Steve Thompson of Taco, Inc. in developing and presenting this paper at EEMODS 2015. The author also acknowledges the support of Ethan Rogers of the American Council for an Energy-Efficient Economy for his contribution to the development of this paper. References [1] United States Congress. Energy Policy and Conservation Act of 1975 (EPCA), as amended (42

U.S.C. 6291 et seq.) to increase domestic energy supplies and availability and to restrain energy demand. Can be downloaded at: http://www.gpo.gov/

[2] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. Standards and Test Procedures: Commercial and Industrial Pumps. Can be accessed at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/44

[3] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2013-02-20 Presentation Slides - Energy Conservation Standards for Commercial and Industrial Pumps - Framework Public Meeting: EERE-2011-BT-STD-0017. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0031-0017

[4] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2013-02-

01 Energy Efficiency Program for Commercial and Industrial Equipment: Public Meeting and Availability of the Framework Document for Commercial and Industrial Pumps; Notice of public meeting and availability of the Framework Document.: EERE-2011-BT-STD-0014. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0031-0014

[5] United States Department of Energy, Office of Energy Efficiency & Renewable Energy.

Commercial and industrial pumps energy conservation standards rulemaking docket: EERE-2011-BT-STD-0031. Can be accessed at: http://www.regulations.gov/#!docketDetail;D=EERE-2011-BT-STD-0031

[6] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. Appliance

Standards and Rulemaking Federal Advisory Committee. Can be accessed at: http://energy.gov/eere/buildings/appliance-standards-and-rulemaking-federal-advisory-committee

[7] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2013-07-

23 Appliance Standards and Rulemaking Federal Advisory Committee: Notice of Intent To Establish the Commercial/ Industrial Pumps Working Group To Negotiate a Notice of Proposed Rulemaking (NOPR) for Energy Conservation Standards for Commercial/Industrial Pumps. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-NOC-0039-0001

[8] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2013-11-

12 Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC); Notice of open meeting and further solicitation of members for the Commercial and Industrial Pumps Working Group. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-NOC-0039-0002

[9] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2014-06-

19 ASRAC Commercial and Industrial Pumps Working Group Term Sheet. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-NOC-0039-0092

[10] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2015-04-

29 Presentation: Notice of Proposed Rulemakings for Pumps Test Procedure and Standards. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-TP-0055-0006

[11] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. 2014-05-

29 Meeting slides - ASRAC Pumps Working Group Webinar Meeting Metric and Test Procedure. Can be accessed at: http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-NOC-0039-0081

[12] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. Energy

Conservation Program: Test Procedure for Pumps, Notice of Proposed Rulemaking. Can be accessed at: http://energy.gov/eere/buildings/downloads/energy-conservation-program-test-procedure-pumps-notice-proposed-rulemaking

[13] United States Department of Energy, Office of Energy Efficiency & Renewable Energy.

Rulemaking for Commercial and Industrial Pumps Energy Conservation Standards. Can be accessed at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/14

[14] Council of the European Union. 2012. Commission Regulation (EU) No 547/2012 of 25 June 2012

implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps. Official Journal of the European Union. L 165, 26 June 2012, pp. 28-36.

[15] United States Department of Energy, Office of Energy Efficiency & Renewable Energy. Energy

Conservation Program: Energy Conservation Standards for Pump, Notice of Proposed Rulemaking. Can be accessed at: http://energy.gov/eere/buildings/downloads/energy-conservation-program-energy-conservation-standards-pump-notice

[16] Chittum, A. and S. Nowak. 2010. Money Well Spent: 2010 Industrial Energy Efficiency Program

Spending. Washington, DC: American Council for an Energy-Efficient Economy.

[17] Wiel, Stephen, and James E. McMahon. Energy-Efficiency Labels and Standards: A Guidebook for Appliances, Equipment, and Lighting - 2nd Edition. Berkeley: Lawrence Berkeley National Laboratory, 2005

[18] Rogers, Ethan A. (2014, August) Development of a New Extended Motor Product Label for

Inclusion in Energy Efficiency Programs. Paper presented at the 2014 ACEEE Summer Study on Energy Efficiency Buildings, Pacific Grove, California. Washington, DC: American Council for an Energy-Efficiency Economy.