### Appliance Standards and Rulemaking Federal Advisory Committee Commercial and Industrial Pumps Working Group Interim Report

June 4 , 2014

Background On June 27, 2013, members of the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) voted unanimously to form a working group to negotiate a proposed regulation setting energy efficiency standards for C ommercial and Industrial P umps

.

A notice of intent to form the Pumps WG was published in the Federal Register on November 12 , 2013

. DOE received 19 nominations for membership

. Of the 1 9 nominations

, 1 6 were selected to serve as members, including one member from ASRAC, and one DOE representative (see Appendix A). The Pumps W G held its first two

- day meeting at the U.S. Department of Energy’s headquarters in Washington, DC on December 18

- 19, 2013

. This is t he first time that the pumps industry would be subject to energy efficiency regulation.


### Getting Started During the working group’s first meeting, members discussed :

• M odifications to the draft Working Group Ground Rules and voted unanimously to adopt them , including a consensus definition: no more than two votes again st a proposal to adopt

• DOE’s preliminary thinking on the definition of pump and pote ntial scope

• S cheduling issues

— how the potential scope of the negotiation would fit/correspond to the proposed WG schedule . The WG established seven additional two

- day meeting dates.

Over the course of the next three 2

- day meetings (January 30

– 31; M arch 4

- 5; and March 26

– 27, 2014) the WG focused on the definition of covered product, defining the scope of negotiations and determining a metric for pump ef ficiency.



### Definition of Covered Product Regarding the definition of covered product, the WG voted (15 yes/1 no on 3/4/14) to define ‘pump’ as follows: “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 manufac turer, the mechanical equipment, driver, and controls.” The WG also separately defined (15 yes/1 absent on 3/4/14) ‘bare pump,’ ‘mechanical equipment,’ ‘driver,’ and ‘controls.’

While the definition of the covered product includes pumps driven by non

- elec tric drivers, the WG voted ( u nanimous on 3/26/14) that in this rulemaking, the metric will not include non

electric drivers. Instead, pumps with non

- electric drivers will be subject to standards for bare
pumps.

### In

- Scope Pumps The WG voted by consensus (15 yes/1 abstain on 3/26/14) that the scope of this rulemaking be limited to the following pump types:

• 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)

The scope is consistent with that originally proposed by HI. The HI scope is also consistent with the European regulatory regime included in ‘Lot 11’.



### P arameters for Standards The WG adopted by conse nsus (15 yes/1 absent on 3/4/14) parameters for this rulemaking

, which were a slightly modified version of the manufacturers’ caucus proposal :

• Full impeller diameter

• 1

- 200 Horsepower (shaft power at BEP)

• 25 gallons/minute and greater (at BEP)

• 459 feet of head maximum (at BEP)

• 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 (VT

- S/HI VSO)


### Excluded Pump s The discussion on parameters was accompanied by detailed discussion on the potential scope of negotiations, specifically the pump types that should be excluded

. Of particular interest was limit ing the scope to pumps designed for use in pumping clean water

. Over the span of the three meetings

, the WG ultimately decid ed to exclude (by various votes: unanimous on 1/31/14, 14 yes/2 absent on 3/4/14, and unanimous on 3/26/14) the following pump types that might otherwise meet the definition of an in

- scope pump type (i.e. ESCC, ESFM, etc.) :

• Wastewater, sump, slurry, solids handling

• API 610 pumps

• ASME/ISO c hemical process pumps

• F ire p umps (which meet N FPA 20 , UL listed or FM approved )

• Self

- priming pumps

• Prime

- assisted pumps

• Nuclear pumps

• Navy pumps

• Sanitary pumps

By limiting the scope of this rulemaking to the five pump types previously identified as in

- scope, the WG determined (by various votes: unanimous on 1/31/14, 15 yes/1 abstain on 3/26/14) t hat various other pump types that may have been previously considered as part of this rulemaking would be excluded:• Positive displacement

• Axial/mixed flow

• Double suction

• Multistage axially split

• Multistage radial split

- horizontal

• Multistage radial split v ertical immersible

• Vertical turbine (non

- submersible)

Finally, the WG voted (15 yes/1 abstain on 3/26/14) to hold circulators and dedicated

- purpose pool pumps for a second negotiation , for which they planned to make a recommendation to ASRAC.



### Determining a Metric As the WG voted to define the covered product, a pump, as inclusive of driver and controls, the existing industry metrics (i.e., pump efficiency, MEI) were not adequate to represent the energy use of a covered product. As a result, the WG spent a significa nt amount of time in meetings five and six (April 29

- 30, May 28

- 29) engaged in developing a new metric that includes not only bare pump performance, but can also capture performance of motors and controls

. It seem s that the WG is very close to accepting a version of the metric ( some members called for a preliminary vote of acceptance, but other members wanted more time to test the impacts of the proposal )

. As currently proposed (and largely accepted by a large majority of the WG

— an individual or two seem to be undecided ) , the construct of the metric would include a numerator of equally weighted average electric input power to the ‘pump’ measured (or calculated) over a specified load profile and a denominator of the weighted average electric input power fo r a minimally compliant pump (i.e.

, the maximum power allowed for a given pump based on an uncontrolled/constant load). The load points (and speed for testing at each of those points) used in the numerator would be different for bare pumps and pumps with m otors (e.g., a constant load rating) versus any pump sold into the market in combination with a motor and/or controls (e.g., a variable load rating). This construct demonstrates significantly lower power for pumps with controls.

This metric will likely be called the Pump Efficiency Index (PEI). In order to pass the standard, the PEI would have to be less than or equal to 1. The manufacturers’ caucus has proposed that both constant and variable load ratings would be shown on every pump ; but details on st andards and levels have not yet been determined

. The beauty of this construct is that it enables a pump consumer to do efficiency comparisons across various pumps and pump /motor/controls combinations.



### Initial Standard Level Proposals Also in meetings num ber five and six, the WG conducted a detailed review/discussion on the:

• Engineering Analysis (noting significant data/analysis gaps and deficiencies that were corrected )

• Life Cycle Cost (LCC) Analysis

• Shipments Analysis• National Impact Analysis (NIA) and

• Manufacturer Impact Analysis (MIA)

After reviewing all provided results, in meeting #6, the t wo principal caucuses exchanged, for the first time, standard

- setting proposals. The manufacturers ’ caucus proposed meeting a standard of PEI

- 15, which would set a level which presumes to eliminate 15% of current pumps from the market by the compliance date. The caucus leader noted this level is higher than where the European Union (EU) set its initial efficiency threshold

, which was designed to eliminate only 10% of pumps from the market

. This resurfaced a consistent theme that had emerged in discussion and analysis

— at higher efficiency levels, manufacturer impacts are very significant

. The energy

- efficiency advocates caucus responded by set ting a performanc e target for the industry. The caucus spokesperson said they would like to achieve .25 q uads of cumulative national energy savings over the analysis period. This would correspond to PE I

- 40

. It was noted that this corresponded to a higher efficiency leve l than the EU’s new MEI

- 40 standard, which goes into effect on January, 2015

– MEI

- 40 is roughly equivalent to PEI

- 25

- 30

. As the meeting concluded, in response to WG request, the DOE General Counsel’s office reported that the compliance date was not a rigid five years after the rule is published, as presented earlier. This means the WG could be more flexible and, for example, choose rolling compliance dates for different pump types. However, the six

- year presumed follow

- up window remains in effect.



### T est Procedure Members of the WG also expressed an interest in having a detailed consideration/discussion on the test procedure. DOE has said it intended to create a pumps test procedure by its normal rulemaking methods. HI has just completed its test pro cedure deliberation and established its method for bare pumps. DOE’s effort would expand the test procedure coverage to include
pump

- motor

- controls combinations to account for the entire covered product

. Some members were cautious about taking on new res ponsibilities g iven the time that remains (two, three

- day meetings) and the work load to be completed. After discussion, the WG concluded that it would take up the test procedure if time allows.



### Conclusion With initial proposals on the table and a metr ic ready for a consensus vote, the WG seems poised to complete its task. While moving very deliberately, the WG has nevertheless established an effective collaboration. The WG has functional caucuses and effective caucus leadership. While nothing is cer tain in this environment, these features bode well for completion of a term sheet in the next two scheduled meetings.

Interim Report prepared by Doug Brookman and Alison Williams publicsolutions@earthlink.net ; aawilliams@lbl.gov

### Appendix A

— Members

U.S. Department of Energy

— ASRAC Commercial and Industrial Pumps Negotiated Rulemaking Working Group

Lucas Adin U.S. Department of Energy Tom Eckman Northwest Power and Conservation Council (ASRAC Member) Robert Barbour TACO, Inc. Charles Cappelino ITT Industrial Process Greg Case Pump Design, Development and Diagnostics Gary Fernstrom California IOUs Mark Handzel Xylem Corporation Albert Huber Patterson Pump Company J oanna Mauer Appliance Standards Awareness Project Doug Potts American Water Charles Powers Flowserve Corporation, Industrial Pumps Steve Rosenstock Edison Electric Institute Louis Starr Northwest Energy Efficiency Alliance Greg Towsley Grundfos USA Me g Waltner Natural Resources Defense Council